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M28. Do wholesale gasoline purchases and applicable excise taxes paid by a gasoline retailer qualify as "purchases from other firms" under Section 113(6) of the Michigan Business Tax Act ("MBTA")?
Yes. To the extent that the gasoline purchased by a gasoline retailer is held for resale such wholesale purchases of gasoline constitute inventory ("stock of goods held for resale in the regular course of trade of a retail ... business") and qualifies as "purchases from other firms." Further, to the extent that the gasoline retailer's purchase of wholesale gasoline constitutes inventory under MCL 208.1111(4) and thus "purchases from other firms" under MCL 208.1113(6), then the amount of excise taxes paid by the retailer for such inventory would also be included in the "purchases from other firm" amount deductible from gross receipts.

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