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M77. Taxpayer is a commercial printing and mailing company. Taxpayer provides printing and mailing services to clients throughout the U.S. Postage is billed to the client. Is the postage included in the gross receipts of the taxpayer?

Yes. Gross receipts are the "entire amount received" from "any activity" unless the amount received is expressly excluded under MCL 208.1111 or deductible as "purchases from other firms" under MCL 208.1113. Postage is neither an excluded receipt nor is it a purchase from another firm. Furthermore, the taxpayer in question ? absent a contract demonstrating otherwise ? is not a legal agent of its customers. Thus, the agency exemption under MCL 208.1111 does not apply.

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