2026 Petition - POS.pdf
Gathergrounds Michigan LLC Petitioner Vs. Township Of Leoni Respondent · 26-000996-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Gathergrounds Michigan LLC, Petitioner, vs. Leoni Township, Respondent. MTT Docket No. 26-000996 _____________________________________________________________________________/ PROOF OF SERVICE (Property Tax Petition) On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: Township Assessor Leoni Township 913 Fifth Street Michigan Center, MI 49254 Township Supervisor Leoni Township 913 Fifth Street Michigan Center, MI 49254 On the date below I sent by first class mail a copy of the Petition to: Equalization Director Jackson County 120 W. Michigan Avenue, 16th Floor Jackson, MI 49201 County Clerk Jackson County 312 S. Jackson Street Jackson, MI 49201 Secretary, Board of Education East Jackson Community Schools 1404 North Sutton Road Jackson, MI 49202 State Treasurer Department of Treasury 430 W. Allegan Street Lansing, MI 48922 I declare that the statements above are true to the best of my information, knowledge and belief. /s/ Laura M. Hallahan Dated: August 14, 2026
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS GATHERGROUNDS MICHIGAN LLC, Petitioner, v TOWNSHIP OF LEONI, Respondent. MICHIGAN TAX TRIBUNAL Docket No. 26-000996_______ Parcel No.: 000-04-35-400-001-02, and additional parcels _____________________________________________________________________________/ PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use 000-04-35-400-001-02 7800 Cutler Rd. Commercial Campground 000-04-35-400-001-13 Roarkeys Ln. Agriculture-Vac Vacant 2. ☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: ☐March, ☐ July, ☐ December Board of Review. 3. Respondent, identified above, assesses and collects taxes on the subject property. 4. The subject property is located in the County of Jackson and school district of East Jackson Community Schools. 5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 6. The Petitioner’s principal office/legal residence address is: 1883 W. Royal Hunte Dr., Suite 200A, Cedar City, UT 84720.
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2 7. This appeal involves issues related to: ☒ the subject property’s true cash and taxable values ☐ the subject property’s taxable value only there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No ☐ uniformity of the subject property’s assessment ☐ the subject property’s exemption from ad valorem taxation under MCL ______ 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values are based upon an erroneous determination of the true cash value of that portion of Petitioner’s property that is taxable under Michigan law and are based upon the application of wrong principles; and d. The assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection and due process of law.
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3 Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable to the reductions, with interest, as provided by the Tax Tribunal Act. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 Dated: May 15, 2026 lhallahan@hallahanlaw.com Filing Fee: $450
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4 ATTACHMENT TO PETITION (Subject Property) VALUES Respondent’s Board of Review -and- Petitioner’s Contention Parcel Number Respondent Petitioner TCV SEV TV TCV SEV TV 000-04-35-400-001-02 985,164 492,582 492,582 350,000 175,000 175,000 000-04-35-400-001-13 482,030 241,015 241,015 100,000 50,000 50,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Totals 1,467,194 733,597 733,597 450,000 225,000 225,000 VALUES IN DISPUTE Parcel Number TCV SEV TV 000-04-35-400-001-02 635,164 317,582 317,582 000-04-35-400-001-13 382,030 191,015 191,015 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Totals 1,017,194 508,597 508,597