The Michigan Court of Appeals held that a provider of event planning and coordination services presented sufficient evidence to support its costs of performance sales factor sourcing method, under which it sourced services receipts to the location where the event occurred. Over the Department’s arguments that the taxpayer failed to prove its costs of performance, the court found the taxpayer’s witness testimony, together with spreadsheets documenting each year’s costs of performance, to be “competent, material, and substantial evidence” sufficient to prove the taxpayer’s claim. The court reversed the lower court’s award of attorney fees to the taxpayer, however. Although it may have been the case, as the lower court found, that the state “failed to follow the clear language of the statute . . . and its own guidance,” the court concluded that the state’s misconduct occurred at the audit level, and no improper documents had actually been filed with the lower court. Schoeneckers, Inc. v. Dep’t of Treasury, Dkt. No. 313311, 2014 WL 308856 (Mich. App. Jan. 28, 2014) (unpublished).