25-001642 Corrected FOJ.pdf

The Huntington National Bank Petitioner V Township Of Chesterfield Respondent · 26-003770-TT

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STATE OF MICHIGAN
GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA
 GOVERNOR LANSING DIRECTOR

 The Huntington National Bank, MICHIGAN TAX TRIBUNAL
 Petitioner, SMALL CLAIMS DIVISION

 v MTT Docket Nos. 25-001642
 & 26-003770

 Chesterfield Township, Presiding Judge
 Respondent. Patricia L. Halm

 CORRECTED FINAL OPINION AND JUDGMENT

 ORDER SEVERING 2026 TAX YEAR AND ASSIGNING IT
 DOCKET NUMBER 26-003770

 The Tribunal has reviewed the file in this case and finds that on September 16, 2026, a
 Final Opinion and Judgment (FOJ) was issued in the above-captioned matter.
 However, following the issuance of the FOJ, the Tribunal discovered an administrative
 error within the FOJ with respect to the tax years at issue. Specifically, the 2026 tax
 year was not addressed within the FOJ. MCL 205.737 provides that “[i]f the residential
 property and small claims division of the tribunal has jurisdiction over a petition, the
 appeal for each subsequent year for which an assessment has been established shall
 be added automatically to the petition.”1 Here, neither party offered any testimony or
 evidence as to the value of the subject property as of December 31, 2025. Thus, the
 record lacks sufficient detail to allow the Tribunal to render a decision for the 2026 tax
 year.

 A petitioner has “the burden of proof in establishing the true cash value (TCV) of the
 property” under MCL 205.737(3).2 The petitioner’s burden “encompasses two separate
 concepts”: (1) the burden of persuasion; and (2) the burden of going forward with the
 evidence.3 Generally, in a valuation case, to meet the burden of going forward with the
 evidence, the petitioner must present evidence for the Tribunal to consider in making its
 independent determination of value.4 As noted above, neither party provided any
 relevant evidence of value and “[t]he Tribunal may not automatically accept a
 respondent's assessment, but must make its own findings of fact and arrive at a legally
 supportable true cash value.”5 As a result, the Tribunal finds good cause to correct the

 1 See MCL 205.737(5)(b).
 2 See also Kern v Pontiac Twp, 93 Mich App 612, 620; 287 NW2d 603 (1979).
 3 Jones & Laughlin Steel Corp v City of Warren, 193 Mich App 348, 355; 483 NW2d 416 (1992).
 4 See Jones & Laughlin.
 5 Id. at 355. (Citing Pinelake Housing Cooperative v Ann Arbor, 159 Mich App 208, 220; 406 NW2d 832
 (1987)); Consolidated Aluminum Corp v Richmond Twp, 88 Mich App 229, 232-233; 276 NW2d 566
 (1979)).

 MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760
 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

MTT Docket No. 25-001642 & 26-003770
Page 2 of 3

FOJ, sever the 2026 tax year and assign it a new docket number. As instructed below,
the parties are ordered to file pleadings specific to the 2026 tax year.

All other information contained within the FOJ remains the same and is incorporated by
reference in this Corrected Final Opinion and Judgment.

 JUDGMENT

IT IS ORDERED that the 2026 tax year shall be SEVERED and assigned Docket No.
26-003770.

IT IS FURTHER ORDERED that Petitioner shall file a petition pertaining to the 2026 tax
year within 21 days of entry of this order.6 The petition shall note the docket number
assigned by the Tribunal for the 2026 tax year and if filed utilizing the Tribunal’s e-filing
system, must be filed on the assigned 2026 docket number as a “Severed Petition.”

IT IS FURTHER ORDERED that the Tribunal shall issue a Notice of Docket after receipt
of Petitioner’s petition.

IT FURTHER IS ORDERED that the property’s 2025 state equalized value (SEV) and
taxable value (TV) for the tax year at issue shall be as set forth in the Summary of
Judgment section of the September 16, 2026 Final Opinion and Judgment.

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment
rolls for the tax year at issue shall correct or cause the assessment rolls to be corrected
to reflect the property’s TCV and TV within 20 days of entry of Corrected Final Opinion
and Judgment, subject to the processes of equalization.7 To the extent that the final
level of assessment for a given year has not yet been determined and published, the
assessment rolls shall be corrected once the final level is published or becomes known.

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the
affected taxes shall collect taxes and any applicable interest or issue a refund within 28
days of entry of this Corrected Final Opinion and Judgment. If a refund is warranted, it
shall include a proportionate share of any property tax administration fees paid and
penalty and interest paid on delinquent taxes. The refund shall also separately indicate
the amount of the taxes, fees, penalties, and interest being refunded. A sum
determined by the Tribunal to have been unlawfully paid shall bear interest from the
date of payment to the date of judgment, and the judgment shall bear interest to the
date of its payment. A sum determined by the Tribunal to have been underpaid shall
not bear interest for any time period prior to 28 days after the issuance of this Final
Opinion and Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after
December 31, 2020, through June 30, 2022, at the rate of 4.25%, (ii) after June 30,
2022, through December 31, 2022, at the rate of 4.27%, (iii) after December 31, 2022,
through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 2023, through December

6 Alternatively, the petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via
United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition
may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax
Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933.
7 See MCL 205.755.

MTT Docket No. 25-001642 & 26-003770
Page 3 of 3

31, 2023, at the rate of 8.25%, (v) after December 31, 2023, through June 30, 2024, at
the rate of 9.30%, (vi) after June 30, 2024, through December 31, 2024, at the rate of
9.50%, (vii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, (viii)
after June 30, 2025, through December 31, 2025, at the rate of 8.66%, (ix) after
December 31, 2025, through June 30, 2026, at a rate of 8.48%, and (x) after July 1,
2026, through December 31, 2026, at a rate of 7.85%.

This Corrected Final Opinion and Judgment resolves all pending claims in this matter
and closes this case.

 APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for
reconsideration with the Tribunal or a claim of appeal with the Michigan Court of
Appeals.

A motion for reconsideration must be filed with the Tribunal with the required filing fee
within 21 days from the date of entry of the final decision. The fee for the filing of such
motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless
the Small Claims decision relates to the valuation of property and the property had a
principal residence exemption of at least 50% at the time the petition was filed or the
decision relates to the grant or denial of a poverty or disabled veterans exemption and,
if so, there is no filing fee. You are required to serve a copy of the motion on the
opposing party by mail or personal service or by email if the opposing party agrees to
electronic service, and proof demonstrating that service must be submitted with the
motion. Responses to motions for reconsideration are prohibited and there are no oral
arguments unless otherwise ordered by the Tribunal.

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the
claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If
the claim is filed more than 21 days after the entry of the final decision, it is an “appeal
by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the
record on appeal. There is no certification fee.

 By: /s/ Patricia L. Halm
Entered: October 14, 2026
smm/gc

 PROOF OF SERVICE

I 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
or email addresses on file, as provided by those parties, attorneys, or authorized
representatives.

 By: Tribunal Clerk

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