PNC Farser 2025 tax year petition.pdf

Pnc Bank National Association, Petitioner Vs. City Of Fraser, Respondent · 25-001811-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

PNC Bank, National Association, 

Petitioner, 

v. 

MTT Docket No. 

 

 Parcel No. 03-14-05-177-016 

City of Fraser, 

 

 

 

 

 

 

Respondent. 

/ 

 

 

PETITION 

PNC Bank, National Association ("Petitioner"), through its representatives, AD VALOREM 

PARTNERS LLC, says: 

 

Petitioner's principal office address is 300 Fifth Avenue, Pittsburgh, PA 15222-2719. 

Petitioner is a party in interest with respect to property taxes on tax parcel no. 03-14-05-177-016 ("Petitioner's 

Property"), at 32001 Groesbeck Hwy, Fraser, Michigan 48026. 

2. 

Respondent, City of Fraser, assesses and collects property taxes on Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of parcel number 03-14-05-177-016 to 

be $503,973 and the assessed value to be $619,600, which will result in a state equalized value in the same 

amount based upon the tentative equalization factor. 

4. 

Petitioner’s Property is classified as Commercial Real. Petitioner's Property is presently 

used 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) uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

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 and operate 

as a fraud upon the taxpayer for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, exceed the 

amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable statutes; 

(c) 

The assessment, including state equalized value, are based upon erroneous 

determinations 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 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.

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 2025 

taxable value of parcel number 03-14-05-177-016 from $503,973 to $250,000, and reducing the 2025 

assessed value and state equalized value from $619,600 to $250,000; and (ii) awarding Petitioner any other 

relief to which it is entitled. 

Respectfully submitted, 

 

 

 

 AD VALOREM PARTNERS LLC 

 

 

 

 Petitioner’s Representative 

 

 

 

 

 

 

 

 

 

 

 

 By:_________________________ 

 

 

 

 

Scott Aston 

 

 

 

 

21446 Columbine Court 

 

 

 

 

Grosse Ile, MI 48138 

 

 

 

 

(734) 731-0558 

 

 

 

 

aston@advalpartners.com 

Dated: May 29, 2025

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