25-002253.pdf

Cristina M Guerrieri, Petitioner V Township Of Bloomfield, Respondent · 25-002253-TT

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STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

Cristina M Guerrieri, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 25-002253 

 

Bloomfield Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner’s appeal, which was filed on June 4, 2025. Based on the information 

provided in the petition, Petitioner is seeking a principal residence exemption (PRE) for 

the 2021 tax year. The petition indicates that there has been no denial of the PRE by 

Respondent for this year. The Tribunal’s authority is limited to “a proceeding for direct 

review of a final decision, finding, ruling, determination, or order of an agency relating to 

assessment, valuation, rates, special assessments, allocation, or equalization, under 

the property tax laws of this state.” 1 If there is no final decision, finding, ruling, 

determination or order, the Tribunal has no jurisdiction or authority. 

 

Further, MCL 211.7cc, which governs PREs, states than an exemption is claimed “by 

filing an affidavit on or before . . . June 1 for the immediately succeeding summer tax 

levy and all subsequent tax levies or on or before November 1 for the immediately 

succeeding winter tax levy and all subsequent tax levies . . . . ”2 As such, the affidavit 

must typically be filed in the year the exemption is sought. Although retroactive claims 

can be made for years in which the exemption was not on the tax roll, MCL 211.7cc(19) 

limits such claims to “the current calendar year or the immediately preceding 3 calendar 

years.”3 Consequently, neither the Tribunal nor the assessor has authority to grant an 

exemption in 2025 for the 2021 tax year. As such, and inasmuch as the Tribunal has no 

equitable power to waive or otherwise disregard a statutory filing requirement deadline, 

it has no authority to grant Petitioner the relief requested.4 Therefore, 

 

IT IS ORDERED that the case is DISMISSED. 

 

This order resolves all pending claims in this matter and closes this case. 

 

 

1 MCL 205.731. 

2 MCL 211.7cc(2). 

3 Id. 

4 The Tribunal’s powers are limited to those authorized by statute and do not include powers of equity. 

See Federal-Mogul Corp v Dep’t of Treasury, 161 Mich App 346 (1987), Elec Data Sys Corp v Flint Twp, 

253 Mich App 538 (2002), and VanderWerp v Plainfield Twp, 278 Mich App 624 (2008).

MTT Docket No. 25-002253 

Page 2 of 2 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal. 

 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

 

 

Entered: July 25, 2025 

 

 

 

By _____________________________ 

ejg/sb 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

 

By: Tribunal Clerk

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