REVOCATION OF EXEMPTION CERTIFICATES. A. STANDARD OF REVIEW This Court reviews de novo issues of the interpretation and application of statutes.23 If the plain and ordinary meaning of a statute’s language is clear, we enforce the statute’s language as written.24 When interpreting a statute, our goal is to give effect to the intent of the Legislature.25 The language of the statute itself is the primary indication of the Legislature’s intent.26
B. THE POSITIONS OF THE PARTIES Xxxxx contends that the Commission improperly revoked the exemption certificates retroactive to December 2006, and that the circuit court erred by concluding that the Commission could revoke those certificates retroactively. Xxxxx contends that, since the Commission did not actually enter a signed revocation order until February 5, 2007, according to the statute that order became effective for taxes arising only on and after December 31, 2007. Thus, Xxxxx argues, the Commission’s revocation of the certificates had no valid effect on the exemptions for
REVOCATION OF EXEMPTION CERTIFICATES. A. STANDARD OF REVIEW This Court reviews de novo issues of the interpretation and application of statutes.23 If the plain and ordinary meaning of a statute’s language is clear, we enforce the statute’s language as written.24 When interpreting a statute, our goal is to give effect to the intent of the Legislature.25 The language of the statute itself is the primary indication of the Legislature’s intent.26
B. THE POSITIONS OF THE PARTIES Xxxxx contends that the Commission improperly revoked the exemption certificates retroactively to December 2006 and that the circuit court erred by concluding that the Commission could revoke those certificates retroactively. Xxxxx contends that since the Commission did not actually enter a signed revocation order until February 5, 2007, according to the statute that order became effective for taxes arising only on and after December 31, 2007. 20 Id. at 554. 21 Ever Krisp, 307 Mich at 188-189, 196. 00 Xxxx-Xxx Xxxx, 333 Mich at 557. 23 Xxxxx v Michigan, 486 Mich 468, 477; 785 NW2d 119 (2010). 24 United States Fidelity, 484 Mich at 12-13. 25 Id. at 13. 26 Id. Thus, Xxxxx argues, the Commission’s revocation of the certificates had no valid effect on the exemptions for 2006 (since the revocation was not signed and did not become effective before December 31, 2006) or for 2007 (since the revocation only became effective for taxes arising on or after December 31, 2007). Simply put, it is Xxxxx’x position that the Commission’s revocation of the certificates is void with respect to 2006 and 2007 taxes. Kentwood contends on appeal, as it argued below, that even if the Commission erred by retroactively revoking the exemption certificates, Xxxxx’x challenge is improper. According to the city, because XxxXxxxxx’x failed to appeal the Commission’s decision to the circuit court within 60 days as provided by law,27 his later challenge is an impermissible collateral attack on that decision. We conclude that Xxxxx’x challenge is an impermissible collateral attack.
C. STATUTORY PROVISIONS MCL 207.565(4) provides that [t]he order of the commission revoking the certificate shall be effective on the December 31 next following the date of the order and the commission shall send by certified mail copies of its order of revocation to the holder of the certificate, to the local legislative body, to the assessor of the assessing unit in which the facility is located, and to the legislative body of each taxing unit which levies taxes upon property i...
