Severed Petition 2024.pdf
300 Mill St LLC, Petitioner Vs. City Of Cheboygan, Respondent · 24-003573-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 300 Mill St, LLC Petitioner, vs. City of Cheboygan, Respondent. MOAHR Docket No. 24-003573 _____________________________________________________________________________/ Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Hallahan & Associates, P.C. Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 _____________________________________________________________________________/ SEVERED PETITION (Entire Tribunal, 2024 Tax Year) Petitioner, the taxpayer/party-in-interest, petitions this Tribunal as follows: 1. The property that is the subject of this appeal consists of: ☒ one real parcel ☐ multiple contiguous real parcels ☐ personal property. 2. The subject property is: Parcel Number Address Real/ Personal Classification 16-055-006-200-005-00 300 W. Mill Street Real Comm Imp 3. ☐ N/A. If the assessment at issue was protested, the protest was made to Respondent’s ☒ March, ☐ July, ☐ December Board of Review. 4. The subject property is located in Cheboygan County. 5. The assessment(s) were established by the Respondent identified above.
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6. Petitioner’s legal residence or principal office address is: PO Box 38, Union Lake, MI 48387. 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 2024. 9. The values established by Respondent’s Board of Review for the subject property are: (TCV=true cash value, AV=assessed value, TV=taxable value) Parcel Number TCV AV TV 16-055-006-200-005-00 $812,200 $406,100 $367,500 10. Petitioner contends that the values for the subject property are: (TCV=true cash value, SEV=state equalized value, TV=taxable value) Parcel Number TCV SEV TV 16-055-006-200-005-00 $400,000 $200,000 $200,000 11. The values in dispute are. (TCV=true cash value, SEV=state equalized value, TV=taxable value) Parcel Number TCV SEV TV 16-055-006-200-005-00 $412,200 $206,1000 $167,500 12. Petitioner requests that the Tribunal reduce the 2024 values from those established by Respondent’s Board of Review to those contended by Petitioner, and order a refund with interest, as provided by the Tax Tribunal Act. 13. Petitioner relies upon the following to support the relief requested: The 2024 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;
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(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 is 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, its constitutional rights of uniformity, equal protection and due process of law. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302-0179 (248) 731-3089 Dated: October 11, 2024 lhallahan@hallahanlaw.com Filing Fee: 400.00