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Marjorie B. Gell

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Marjorie Gell

Distinguished Professor Emeritus

B.A. The University of Michigan
J.D. Wayne State University Law School
LL.M. (Taxation) Wayne State University Law School

[email protected]

“Details are confusing. It is only by selection, by elimination, by emphasis, that we get at the real meaning of things.” - Artist Georgia O’Keeffe

I taught federal income tax, and wills, trusts & estates at the J.D. level, as well as federal tax research in Cooley's LL.M. program.

I am a Past Chair of the Taxation Section of the State Bar of Michigan, and was a member of the Past Chairs’ Committee of the Taxation Section of the State Bar of Michigan. I have also served on the Tax Council, the governing board of the Taxation Section of the State Bar of Michigan, from 2005 through 2016. In this capacity, I served as Taxation Section Chair, Vice Chair, Treasurer, Secretary, Legislation Monitor & Public Policy Liaison, Editor-in-Chief of the Michigan Tax Lawyer, and Chair of the Taxation Section Annual Conference. On behalf of the Taxation Section, I have authored or co-authored briefs for submission to the Michigan Supreme Court and Michigan Court of Appeals. I also served for several years as a member of the State Bar of Michigan Standing Committee on Libraries, Legal Research, and Legal Publications.

I am the founder of the Michigan Women's Tax Association, an organization of women accountants, attorneys, tax professors, students, and members of Michigan industry. I’m also a past member of the Grand Rapids Chamber of Commerce Tax and Regulatory Policy Committee. I served as a board member of the Grandville Avenue Arts and Humanities in Grand Rapids for almost 10 years. I previously served on both the Board of Trustees as well as the Advisory Board of the Arts Council of Greater Grand Rapids.

I was the co-editor of the Guidebook to Michigan Taxes 2019 (CCH/Wolters Kluwer), as well as the co-editor of the Guidebook to Michigan Taxes 2018 (CCH/Wolters Kluwer), the Guidebook to Michigan Taxes 2017 (CCH/Wolters Kluwer), the Guidebook to Michigan Taxes 2016 (CCH/Wolters Kluwer), the Guidebook to Michigan Taxes 2015 (CCH/Wolters Kluwer), the Guidebook to Michigan Taxes 2014 (CCH/Wolters Kluwer), the Guidebook to Michigan Taxes 2013 (CCH/Wolters Kluwer), and Guidebook to Michigan Taxes 2012 (CCH/Wolters Kluwer). I co-authored the Practical Guide to the Michigan Business Tax (CCH/Wolters Kluwer 2009).

I have written numerous articles for national and state tax journals, including the Pittsburgh Tax Review, State Tax Notes, Michigan Tax Lawyer and the Michigan Bar Journal. My column, "As a Matter of Tax," appeared in RIA State Tax Notes from 2009-2011.

From 2014 to 2018, I was an adviser to Judge Michael J. Talbot, Chief Judge of the Michigan Court of Appeals, on Michigan tax cases in the Court of Claims.

Articles (Law Reviews and Law Journals)

  • Marjorie B. Gell, Broken Silence: Congressional Inaction, Judicial Reaction, and the Need for a Federally Mandated Physical Presence Standard for State Business Activity Taxes, 6 Pitt. Tax Rev. 99 (2009).
  • Marjorie B. Gell, Death at Mrs. Cooney’s Hotel: When an Influenza Epidemic Devastated a Small Town in Alaska, Fairbanks Daily News-Miner (April 5, 2020)
  • ​​​​​Marjorie B. Gell, Doing Business in Michigan in the Age of the COVID-19 Pandemic: Traps for the Unwary and Potential Tax Ramifications of the Shift to a Telecommuting Workforce, 52 Michigan Tax Lawyer (No. 1, Spring 2021).

Books and Chapters in Books

  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2019 (Wolters Kluwer CCH 2019).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2018 (Wolters Kluwer CCH 2018).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2017 (Wolters Kluwer CCH 2017).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2016 (Wolters Kluwer CCH 2016).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2015 (Wolters Kluwer CCH 2015).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2014 (Wolters Kluwer CCH 2014).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2013 (CCH 2013).
  • Wayne D. Roberts & Marjorie B. Gell, contributing eds., Guidebook to Michigan Taxes 2012 (CCH 2012).
  • Wayne D. Roberts & Marjorie B. Gell, Practical  Guide to the Michigan Business Tax (CCH 2010).

Short Works

  • Marjorie B. Gell, How Should Business Income from Unitary Flow-Through Businesses be Apportioned under the Michigan Individual Income Tax Act?, 38 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.)  Winter 2013 at 5.
  • Marjorie B. Gell, 3.8 Million and Counting: The Complexity and Wordiness of Tax Law, 91 Mich. B.J., July 2012, at 50.
  • Marjorie B. Gell, Party Time in the World of Michigan Tax, 61 St. Tax Notes, Nov. 7 2011 at 391.
  • Marjorie B. Gell, You've Got a Friend: The Taxation Section's Role as Amicus Curiae, 37 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Summer 2011 at 14.
  • Marjorie B. Gell & Wayne D. Roberts, Rebirth of the Michigan Corporate Income Tax, 60 St. Tax Notes, June 13, 2011 at 833.
  • Marjorie B. Gell, Michigan Business Taxes on the Rocks, 59 St. Tax Notes, Mar. 14, 2011 at 803.
  • Marjorie B. Gell, Sunshine on Our Shoulders and the Need for Tax Transparency, 57 St. Tax Notes, Aug. 16, 2010 at 447.
  • Marjorie B. Gell, Turning Back the Hands of Time: Retroactive Application of Tax Laws, 56 St. Tax Notes, May 17, 2010 at 535.
  • Marjorie B. Gell, Michigan Lawmakers Pass KMart Fix, 55 St. Tax Notes, Mar. 29, 2010 at 992.
  • Marjorie B. Gell, Attention Kmart Shoppers: Michigan Announces an SBT Blue Light Special, 55 St. Tax Notes, Mar. 22, 2010 at 869.
  • Marjorie B. Gell, The Need for State Tax Tribunal Reform, 55 St. Tax Notes, Feb. 22, 2010 at 581.
  • Marjorie B. Gell, Warhol Meets Tax: Electronic Tax Law Sites to Beautify Your Life, 88 Mich. B.J., Dec. 2009, at 50.
  • Marjorie B. Gell, Film Production Tax Credits: Why We Like Them So Much, 54 St. Tax Notes, Oct. 12, 2009, at 129.
  • Marjorie B. Gell, Back to the Future: The Hope for Enactment of BATSA Legislation, 53 St. Tax Notes, July 20, 2009 at 175.
  • Marjorie B. Gell, The Michigan Business Tax: Truism, Shakespeare, and Psychology, 47 St. Tax Notes, Mar. 14, 2008 at 879.
  • Marjorie B. Gell, A "Top Ten" List of Online Tax Law Resources, 86 Mich. B.J., Aug. 2007, at 66.
  • Thomas J. Kenny, Paul Shagen & Marjorie B. Gell, Negotiation of Tax Compacts for Developing Standards of State Taxation in Indian Country, 35 State Tax Notes, Feb. 14, 2005 at 471.
  • Marjorie B. Gell & Michael Domanski, Foreign Companies Doing Business in the US: Entity Classification and Related Tax Issues, 14 Mich. Int’l Law. Newsletter (State Bar of Michigan, Lansing, Mich.), Spring 2002 at 8.
  • JoAnn Chavez & Marjorie B. Gell, E-Commerce and the VAT: Leveling the European Playing Field for Suppliers of Digital Goods and Services, 28 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Spring/Summer 2002 at 26.
  • JoAnn Chavez, Jeffrey S. Freeman & Marjorie B. Gell, New Tax Opportunities Arising Under the FSC Repeal and Extraterritorial Income Exclusion Act of 2000, 27 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Winter 2001 at 19.
  • Marjorie Bilyeu Gell & Jennifer Troyer, State and Local Tax Updates, 26 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich) Winter  2000 at 23.
  • Marjorie Bilyeu Gell & Jennifer Troyer, State and Local Tax Updates, 26 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich) Spring 2000 at 30.
  • David S. Turzewski & Marjorie B. Gell, A Short Primer on Michigan's New Investment Tax Credit, 26 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Summer 2000 at 17.
  • Marjorie Bilyeu Gell & Jennifer Troyer, State and Local Tax Updates, 26 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Summer 2000 at 25.
  • Marjorie Bilyeu Gell & Jennifer Troyer, State and Local Tax Updates, 26 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Fall 2000 at 35.
  • Marjorie B. Gell & David S. Turzewski, The Phaseout of SBT: What Will It Mean for Taxpayers?, 17 St. Tax Notes, July 5, 1999 at 22 .
  • Marjorie Bilyeu Gell, State and Local Tax Updates, 25 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Summer 1999 at 16.
  • David S. Turzewski & Marjorie B. Gell, The Demise of Michigan's Single Business Tax: What the Recent Passage of Historic Legislation Will Mean to Michigan Taxpayers, 10 St.  & Loc. Taxes Wkly., June 28, 1999, at 15.
  • Marjorie Bilyeu Gell, State and Local Tax Updates, 25 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Spring 1999 at 23.
  • David S. Turzewski & Marjorie B. Gell, Mixed-Use Property: Does the Michigan Department of Treasury Have the Authority to Apportion Sales and Use Tax Exemptions?, 25 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Winter 1999 at 28.
  • Marjorie Bilyeu Gell & Jennifer Troyer, State and Local Tax Updates, 25 Mich. Tax Law.  Newsletter (State Bar of Michigan, Lansing, Mich. Fall 1999 at 20.
  • Marjorie Bilyeu Gell & Jennifer Troyer, State and Local Tax Updates, 25 Mich. Tax Law.  Newsletter (State Bar of Michigan, Lansing, Mich. Winter 1999 at 24.
  • Marjorie Bilyeu Gell, State and Local Tax Updates, 24 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Fall 1998 at 23.
  • Marjorie Bilyeu Gell & Marcos Mitchail, State and Local Tax Updates, 24 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Summer 1998 at 28.
  • Marjorie Bilyeu Gell, State and Local Tax Updates, 24 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Spring 1998 at 21.
  • Mitchell E. Bean & Marjorie Bilyeu, Internet Taxation in Michigan, 2/2/1998 St. & Loc. Taxes Weekly Art. 3.
  • Mitchell E. Bean & Marjorie Bilyeu, Toward Deregulation of Michigan's Electric Utility Industry, 14 St. Tax Notes 997 (Mar. 30, 1998).
  • Mitchell E. Bean & Marjorie Bilyeu, Mail Order Sales: Can Michigan Solve Its Use Tax Dilemma?, 24 Mich. Tax. Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Winter 1998 at 19.
  • Mitchell Bean & Marjorie Bilyeu, Michigan's Short Statute of Limitations Applying to Tax Laws: A Constitutional Controversy, 8 St. & Loc. Taxes Wkly., Oct. 6, 1997, at 6.
  • Mitchell Bean & Marjorie Bilyeu, Recent Legislative Changes to Michigan's Limited Liability Company Act, 23 Mich. Tax Law. Newsletter (State Bar of Michigan, Lansing, Mich.) Summer 1997 at 29.
  • Marjorie Bilyeu, Personal Property Tax Reform in Michigan, 13 St. Tax Notes, July 28, 1997 at 255.