Bringing a semblance of order to the prior proceedings, the Michigan Court of Appeals reversed the Michigan Court of Claims ruling that defied the remand instructions from the Michigan Supreme Court. International Business Machines Corp. v. Dep’t of Treasury, Dkt. 327359 (Mich. Ct. App. July 21, 2016). The appellate court’s ruling would result in granting to International Business Machines Corp. (“IBM”) a total of nearly $6 million in Michigan Business Tax (“MBT”) refunds for the company’s 2008 tax year.