2026-05-27 Keaton Investments LLC petition.pdf
Keaton Investments LLC Petitioner Vs. City Of Gladwin Respondent · 26-001542-TT
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1 4901-0916-1902.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL KEATON INVESTMENTS, LLC, MTT Docket No. ___________ Petitioner, v CITY OF GLADWIN, Respondent. ________________________________________/ PETITION FOR THE 2026 TAX YEAR KEATON INVESTMENTS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, files this Petition For The 2026 Tax Year, and states: 1. Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, Michigan, 48075. Petitioner is a party in interest with respect to property taxes on real property tax parcel no. 170-060-001-003-10 (the “Subject Property”), also known as 120 E Cedar Avenue, Galdwin, Michigan. 2. Respondent City of Gladwin (“Respondent”) assesses and collects property taxes on the Subject Property. 3. In 2026, Respondent determined the taxable value of the Subject Property to be $611,600, and the assessed value of the Subject Property to be $611,600, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 4. The Subject Property is classified as Commercial Real. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity.
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2 4901-0916-1902.1 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a board of review protest was filed in March, 2026. 8. The 2026 assessment, including state equalized value and taxable value, imposed on the Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; (c) The assessment, including taxable value and/or state equalized value, are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and (d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection, and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable value of the Subject Property from $611,600 to $100,000, and reducing the 2026 state equalized value of the Subject Property from $611,600 to $100,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs.
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3 4901-0916-1902.1 Respectfully submitted, FOLEY & LARDNER LLP Attorneys for Petitioner By: /s/ Jason Conti Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7177 jconti@foley.com Dated: May 27, 2026