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Petition 2025 - TJS Flint Twp.pdf

Tjs Flint, LLC, Petitioner Vs. Township Of Flint, Respondent · 25-002166-TT

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Page 1

25-0029 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint, LLC, 

Petitioner, 

v. 

Flint Twp., 

Respondent, 

MTT Docket No. ________ 

Parcel No. 07-27-100-025 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Petition 

TJS Flint, LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 111 W. Washington Street, Suite 1300, 

Chicago, IL 60602. Petitioner is a party in interest with respect to property taxes on tax parcel 

number 07-27-100-025 ("Petitioner's Property"), with an address of 3603 Miller Road, Flint Twp., 

located in Genesee County, Michigan. 

2.

Respondent, Flint Twp., assesses and collects property taxes on Petitioner's 

Property. 

3.

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$2,062,000 and assessed Petitioner's Property at $2,087,300, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor.

Page 2

2 

60731676.1 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

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) due process, equal protection, and uniformity. 

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.

No board of review protest was required for Petitioner’s Property. 

8.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

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, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

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 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.

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3 

60731676.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $2,062,000 to $1,300,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $2,087,300 to $1,300,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: June 2, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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