26 - Trillium POS.pdf

Cmg Trillium LLC Petitioner Vs. Township Of Clinton Respondent · 26-001567-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CMG TRILLIUM LLC, 

Petitioner, 

v. 

MTT Docket # 26-001567 

TOWNSHIP OF CLINTON, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

} ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on Qa 

l 

2026 he served a 

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

Aaron M. Fales

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

CLINTON TWP. - MACOMB 

40700 ROMEO PLANK ROAD 

CLINTON TWP., MI 48038-2917 

ASSESSOR 

CLINTON TWP. - MACOMB 

40700 ROMEO PLANK ROAD 

CLINTON TWP., MI 48038-2917 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

| 8. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

CLINTONDALE COMMUNITY SCHOOLS 

35100 LITTLE MACK AVENUE 

CLINTON TWP., MI 48035-2633 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

T.ANSING. MT4R927

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

|. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

CMG Trillium LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001567 

Township Of Clinton, 

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 205.735a, 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), “[flhe 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 Tribunal’s rules. 

By: Tribunal Clerk 

Entered: August 19, 2026 

PROOF OF SERVICE 

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

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG TRILLIUM, LLC, 

Petitioner, 

MIT Docket #26- UD (5767) 

ve 

Parcel No. 16-11-19-477-005 

CLINTON CHARTER TOWNSHIP, 

Respondent. 

/ 

PETITION 

CMG TRILLIUM, 

LLC 

(“Petitioner”), through 

its attorneys, Law Office 

of 

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

1. 

Petitioner's principal office address 

is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. 

Petitioner is a party in interest with respect to property 

taxes on real property fax parcel no. 16-11-19-477-005 {Petitioner's Property"), at 

37399 Garfield, Clinton Twp., MI 48036. 

2. 

Respondent, Clinton Township assesses and collects property taxes 

on Petitioner's Property. 

3. 

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

Property 

to 

be 

$1,840,440 and 

assessed 

Petitioner's 

Property 

at 

$2,670,100 

resulting in a state equalized value of the same amount based on the tenafive

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 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 Constifution 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 $1,840,440 

to 

$1,000,000, and reducing 

the 

2026 assessed and 

state equalized values 

of 

Petitioner's Property from $2,670,100 to $1,000,000, 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 

Aaron M, Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, Ml 48009 

(248) 767-9840 

Dated: May 

27,2026

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