Petition - Surnow-Jackson.pdf

Jackson Properties LLC Petitioner Vs. City Of Jackson Respondent · 26-000695-TT

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Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JACKSON PROPERTIES, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 2-1742.0100 

 2-1737.5000 

 

Petitioner, 

v. 

 

CITY OF JACKSON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Jackson Properties, LLC, by and through its attorneys, Williams 

Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner Jackson Properties, LLC is a Michigan limited liability 

company with its registered office located at 2900 Union Lake Road, Ste. 102, 

Commerce Township, Michigan 48382. 

2. 

Respondent City of Jackson is a Michigan municipal corporation with 

its primary offices located at 161 W. Michigan Avenue, Jackson, Michigan 49201.

Petition Page 2 

The Subject Properties 

3. 

Petitioner owns properties identified as Parcel No. 2-1742.0100, 

commonly known as 1089 N. Wisner, Jackson, Michigan, 49202, and Parcel No. 2-

1737.5000, commonly known as 925 N. Wisner, Jackson, Michigan, 49202. These 

parcels are physically contiguous to each other. They are referred to collectively in 

this Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Jackson County and are within the 

Jackson Public Schools school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Properties. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ 

assessments for property taxes in the amounts set forth in paragraph 1 of the 

attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties 

for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the 

attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in 

paragraph 3 of the attached Multiple Parcel Form. 

10. 

This Petition presents issues involving the Subject Properties’ valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any

Petition Page 3 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan 

Constitution, the GPTA, and other Michigan law, (b) are based on erroneous 

principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments 

are not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Properties’ 2026 assessments to amounts that do 

not exceed Petitioner’s contentions of value set forth on the attached Multiple Parcel 

Form and granting Petitioner all other relief to which it is entitled under Michigan 

law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JACKSON PROPERTIES, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 2-1742.0100 

 2-1737.5000 

 

Petitioner, 

v. 

 

CITY OF JACKSON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s 

March 2026 Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 3,623,800 

 1,811,900 

 1,811,900 

2-1737.5000 

 1,612,800 

 806,400 

 740,158 

Totals: 

 5,236,600 

 2,618,300 

 2,552,058 

 

 

2. 

Petitioner contends that lawful 2026 assessments for the Subject 

Properties cannot exceed the following amounts: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 2,800,000 

 1,400,000 

 1,400,000 

2-1737.5000 

 1,200,000 

 600,000 

 600,000 

Totals: 

 4,000,000 

 2,000,000 

 2,000,000

Multiple Parcel Form Page 2 

 

 

3. 

The amounts in dispute for the 2026 tax year are therefore as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 823,800 

 411,900 

 411,900 

2-1737.5000 

 412,800 

 206,400 

 140,158 

Totals: 

 1,236,600 

 618,300 

 552,058

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