In Ford Motor Credit Co. v. Department of Treasury, Michigan Court of Appeals, Docket Number 289781, January 12, 2010 a finance company that financed sales of motor vehicles by its affiliated dealers was not entitled to recover overpayments of sales tax under the general Sales Tax Act's bad debt statute.  The court rejected that taxpayer's constitutional arguments for the reasons stated in GMAC, LLC, et al. v. Department of Treasury, Michigan Court of Appeals. Docket Numbers 289261-289263 and 289266, December 3, 2009. 

The court also rejected the claim that the taxpayer remained entitled to the refund based on the definition of person contained in in the Sales Tax Act [MCL 205.51(1)(a)] as without merit.  That statute expressly provides that it does not apply where a more limited meaning is disclosed by the context.  In light of the legislature's amendment of MCL 205.54i to express its original intent that only the person who remits the tax on the specific sale at retail was entitled to the bad debt deduction, the taxpayer's position was without merit.  Finally, the taxpayer's assertion that it is entitled to the bad debt deduction based on an assignment is contrary to the legislature's expressed statement that the deduction is available only to the person who remits the tax.