26 - EB - POS.pdf

Juniors Place LLC Petitioner Vs. Township Of East Bay Respondent · 26-001388-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

JUNIORS PLACE LLC, 

Petitioner, 

v. 

MTT Docket # 26-001388 

TOWNSHIP OF EAST BAY, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

} 

) ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on September iS 2026 he served a 

copy of Petitioner's Petition on the parties named on the attached list. 

ee 

Aaron M. Fales

PROOF OF SERVICE 

(Property Tax Petition) 

1 sent by certified mail, return receipt requested, a copy of the Petition to: 

Township Assessor 

East Bay Charter Township 

1965 N. Three Mile Rd. 

Traverse City, MI 49696 

Township Clerk 

East Bay Charter Township 

1965 N. Three Mile Rd. 

Traverse City, MI 49696 

1 sent by first class mail a copy of the Petition to: 

Equalization Director 

Grand Traverse County 

400 Boardman Ave, Suite 103 

Traverse City, MI 49684 

Secretary, Board of Education 

Traverse City Area Public Schools 

412 Webster St 

Traverse City, MI 49686 

County Clerk 

Grand Traverse County 

400 Boardman Ave, Suite 101 

Traverse City, MI 49684 

State Treasurer 

Department of Treasury 

430 W. Allegan Street 

Lansing, MI 48922

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Juniors Place LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

\Y 

MTT Docket No.: 26-001388 

Township Of East Bay, 

Respondent. 

NOTICE OF DOCKET NUMBER 

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.7353, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case. 

Under TTR 235(1), “[tlhe respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” 

Failure to do so 

will result in Respondent being placed in default. 

The docket number also needs to be noted on all other documents submitted in this 

case. 

Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunals rules. 

By: Tribunal Clerk 

Entered: August 11, 2026 

PROOF OF SERVICE 

| certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, 

if any, utilizing either the mailing

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

JUNIORS PLACE LLC, 

Petitioner, 

MTT Docket #26- 001388 

vs. 

Parcel No. 03-207-039-10 

EAST BAY CHARTER TOWNSHIP, 

Respondent. 

; 

PETITION 

JUNIORS PLACE LLC 

("Petitioner"), through 

its attorneys, Law Office 

of 

Aaron M. Fales, P.C., says: 

1. 

Petitioner's principal office address 

is 36800 Woodward, Ste. 300, 

Bloomfield Hills, Mi 48009. 

Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 03-207-039-10 ("Petitioner's Properly"), at 

878 Munson Ave., Traverse City, Ml, 49686. 

2. 

Respondent, 

East 

Bay 

Charter Township 

assesses 

and 

collects 

property taxes on Petitioner's Property. 

3. 

In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $726,400 and assessed Petitioner's Property at $726,400 resulting in 

a state equalized value of the same amount based on the tenative equalization

4, 

Petitioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

Petitioner's Property 

is commercial property. 

Petitioner believes that Petitioner's 

Property was designed to be used as a commercial purposes. 

5. 

This matter involves issues relating to: (a) valuation, {b) assessment, 

(c) taxable value, and {d} 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. 

The 2026 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, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

(b) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable value, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes; 

(c} 

The 

assessment, 

including 

taxable 

value 

and/or 

state 

equalized value, are based upon an erroneous determination of the true cash

(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. 

WHEREFORE, 

Petitioner requests 

that 

the 

Tax Tribunal 

enter an Order 

reducing 

the 

2026 

taxable 

value 

of 

Petitioner's 

Property 

from 

$726,400 

to 

$300,000, 

and 

reducing 

the 

2026 

assessed 

and 

state 

equdlized 

values 

of 

Petitioner's Property from $726,400 to $300,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

Respectfully submitted, 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

By: 

LZ 

LZ 

Aaron M. Fales (P72864) 

330 Hamilfon Row, Suite 350 

Birmingham, Ml 48009 

(248) 767-9840 

Dated: May 24, 2026

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