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"Rule 5. Tangible personal property embraces all goods, wares, merchandise, products and commodities, all tangible things and substances which are dealt in, capable of being possessed and exchanged."

Thanks for finding that. I'm not a lawyer or tax expert, but I have a reasonably good command of language. It seems to be that the part I've formatted as bold would exclude non-tangible goods.

The music on a CD is in digital form, but the CD itself is tangible.

It doesn't seem to me that a string of zeros and ones is a tangible thing.

I'm not a lawyer either. I focussed on "Tangible personal property embraces all goods, wares, merchandise, products ...". Knowing that legal language often is interpreted differently from the common usage, my guess is that there has been a court decision in MI that established that downloaded music fits one of these categories and is subject to MI sales tax.

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