2025 Petition - FSB Jackson.pdf

Flagstar Bank, N.A., Petitioner Vs. City Of Jackson, Respondent · 25-001690-TT

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STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

FLAGSTAR BANK, N.A., 

Petitioner, 

vs. 

CITY OF JACKSON, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 4-0264.1000 

 

PETITION 

 

 

FLAGSTAR BANK, N.A. (“Petitioner”), through its attorneys, Law Office of 

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

 

1. 

Petitioner's principal office address is 5151 Corporate Dr., Troy, MI 

48098. Petitioner is a party in interest with respect to property taxes on real 

property tax parcel no. 4-0264.1000 ("Petitioner's Property"), at 301 W Michigan , 

Jackson, MI. 

 

2. 

Respondent, City of Jackson assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

 In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $773,085 and assessed Petitioner's Property at $971,100 resulting in 

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

factor.

4. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is an office Building. 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. 

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 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, 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 

value of that portion of Petitioner's Property that is taxable under Michigan law, 

and are 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. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2025 taxable value of Petitioner's Property from $773,085 to 

$500,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $971,100 to $500,000, and requiring Respondent to pay 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 29, 2025 

Respectfully submitted, 

 

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

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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