Michigan’s Use Tax Act imposes a “tax for the privilege of using, storing, or consuming tangible personal property in this state.” MCL 205.93(1). The Act provides a tax exemption for fuel, supplies and repairs for vessels that are 500 tons or more and engaged in interstate commerce. The plaintiff in Andrie, Inc. v. Department of Treasury, argued that a tug and barge, which operated together, constituted a single “vessel” under the Act. The Michigan Court of Appeals disagreed, holding that under a plain reading of the statute, the exemption is intended to apply to a single vessel that is 500 tons or more, not two vessels that are connected or that operate as a single unit. “If the Legislature intended the exemption to apply to multiple vessels working in unison,” the court reasoned, “it easily could have stated as such.” Therefore, the tugs, which were less than 500 tons, did not qualify for the tax exemption.