Petition - Manoj Mt. Clemens.pdf
135 River LLC Petitioner Vs. City Of Mt Clemens Respondent · 26-001276-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL 135 RIVER, LLC, Docket No. 26- Parcel No. 05-11-13-102-015 Petitioner, v. CITY OF MOUNT CLEMENS, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com ENTIRE TRIBUNAL PROPERTY TAX PETITION Petitioner 135 RIVER, LLC, by and through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. The Parties 1. Petitioner 135 RIVER, LLC is a Michigan limited liability company whose address is 380 N Old Woodward Avenue, Suite 300, Birmingham, MI 48009. 2. Respondent City of Mount Pleasant is a Michigan municipal corporation with its primary offices located at One Crocker Blvd, Mount Clemens, MI 48043.
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The Subject Property 3. Petitioner owns property identified as Parcel No. 05-11-13-102-015 and commonly known as 135 North River Road, Mount Clemens, MI (the “Subject Property”). 4. The Subject Property is located in Macomb County and is within the Mount Clemens Community school district. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2026 Assessment 6. For the 2026 tax year, Respondent classified the Subject Property as commercial improved property. 7. For the 2026 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value 3,050,800 1,525,400 1,525,400 8. Petitioner contends that a lawful assessment of the Subject Property for the 2026 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value 1,800,000 900,000 900,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value 1,250,800 625,400 625,400 10. This Petition presents issues involving the Subject Property’s valuation for assessment purposes. Petitioner does not believe that this Petition presents any issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),
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defines those terms, but reserves its right to assert issues involving losses should information supporting such issues become available. 11. The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 12. Petitioner does not assert that the Subject Property’s 2026 assessment is not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Property’s values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Brian E. Etzel Brian E. Etzel (P54905) Dated: May 22, 2026 Attorneys for Petitioner