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.
Page 3
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