26-000650 Brief MTT.pdf
Capital Hill Investments LLC Petitioner V City Of Inkster Respondent · 26-000650-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATION HEARING SYSTEM MICHIGAN TAX TRIBUNAL CAPITAL HILL INVESTMENTS, LLC MTT Docket No: 26-000650 Petitioner, v. CITY OF INKSTER Respondent / JEAHAD KADAF (P82492) Marwan Abdullah Attorneys for the Petitioner 26215 Trowbridge 22174 Michigan Ave Inkster MI 48141 Dearborn MI 48124 City of Inkster Assessor (313) 290-0000 jkadafi@kadaflaw.com PROOF OF SERVICE STATE OF MICHIGAN ) WAYNE COUNTY ) On JULY 24, 2026, I served a copy of the Petitioner Brief, by placing the envelope with sufficient postage in an official U.S. postal receptable located in the City of Dearborn, Michigan. /s/ Jeahad Kadaf' Jeahad Kadaf
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATION HEARING SYSTEM MICHIGAN TAX TRIBUNAL CAPITAL HILL INVESTMENTS, LLC MTT Docket No: 26-000650 Petitioner, v. CITY OF INKSTER Respondent / JEAHAD KADAF (P82492) Marwan Abdullah Attorneys for the Petitioner 26215 Trowbridge 22174 Michigan Ave Inkster MI 48141 Dearborn MI 48124 City of Inkster Assessor (313) 290-0000 jkadafl@kadaflaw.com PETITIONER’S RESPONSE TO RESPONDENT’S ANSWER & PETITIONERS FACTUAL BASIS FOR APPEAL PETITIONER’S CHALLENGE TO RESPONDENT’S ANSWER PETITIONER’S ARGUMENT 3821 Wellington, Inkster MI 48141 Tax ID# 44025041161000 BACKGROUND Petitioner owns the property commonly known as 3821 Wellington, Inkster MI 48141. The property was purchased under a trust, whereas the beneficiary of the trust is Capital Hill Investments, LLC. Thereafter, the trustee settled the trust and deeded the property to the beneficiary. The important factor is that the trustee and the beneficiary are 100% owned by the same person, Mike Ghani. Here is a history of ownership with a timeline below:
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eo 3/12/2019 Petitioner purchased the property 3821 Wellington Inkster Trust also being “Capital Hill Investments” the beneficiary of the trust. o 7/3/2024 Petitioner moved the property to Capital Hill Investments LLC, who is the beneficiary of the trust and same owners as the trustee and the LLC. (EXHIBIT A) The City of Inkster treated the transfer as an uncapping under the statute as a sale. The Petitioner provided the City Assessor all the relevant information that meets the MCL 211.27(a), and further sent it by Certified Mail return receipt, USPS # 9589 0710 5270 1257 2731 45, in an attempt to assist the assessor in rectifying the issue. (EXHIBIT B). Although the Petitioner met the burden of proof, the City Assessor uncapped the property taxable value. Additionally, the City Assessor argument is that we are petitioning the wrong year, yet if you look at the notice sent by the assessor of their decision, it has the wrong address of the Petitioner. (EXHIBIT C). LAW AND ARGUMENT MCL 211.27a(7)(m) is a provision in Michigan's General Property Tax Act that excludes specific corporate changes from triggering a property tax "uncapping" event. Specifically, it states that a direct or indirect transfer of real property or ownership interests resulting from a transaction qualifying as a tax-free reorganization under section 368 of the Internal Revenue Code does not constitute a “transfer of ownership”. In TRJ & E Properties, LLC v. City of Lansing, 323 Mich App 664; 919 NW2d 795 (2018), the Michigan Court of Appeals interpreting the "commonly controlled" exception to Michigan's property tax "uncapping” rules under the General Property Tax Act (GPTA). The case is significant because it rejected a rigid administrative definition of common control and instead focused on who actually possessed the power to control the entities involved. The decision established that common control is a functional concept rather than a fixed ownership percentage. The court looked to whether the same persons possessed the practical ability to control each entity, recognizing that different organizations may require
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different voting thresholds. For example, an entity requiring a supermajority might require a higher level of common ownership to establish control than one governed by a simple majority. The court held that there is an exemption when the transfer is between “commonly controlled” entities. Here, it is the same circumstances, the transfer is not only between commonly controlled entities and a common denominator of ownership, but the Beneficiary of the trust is the entity. The trust is a legal entity as well as the single member LLC, and the same individual is effective control and ownership, notwithstanding the it was deeded from the trust to the beneficiary. Therefore, pursuant to the MCL 211.27a(7)(m) and case law, this DOES NOT trigger uncapping of the taxable value under Michigan Law. In Anderson v. Chocolay Township (MTTT Docket No. 433005), the Tribunal treated a conveyance from a trust, the Tribunal ruled it was not a transfer and exempt under MCL 211.27a(7)(m). There is no other person(s) involved in the transfer, still the same commonly controlled and ownership. Again in Shvartsman (MTT Docket Nos. 449484, 449485, 449532, 449533, 449534), Revenue Administrative Bulletin (RAB) 1989-48 recognizes that a sole proprietor can be considered part of a commonly controlled group. Evidenced in the trust, the same as the beneficiary. COURT POWERS TO ADJUST PRIOR YEARS In uncapping cases under MCL 211.27a, argument that correcting the year of transfer necessarily requires correcting every subsequent year's taxable value because each year's taxable value is derived from the prior year's taxable value. If the tribunal determines the uncapping was in error, the MTT has full authority to go back and amend prior years. These inherent powers with the MTT are to correct errors, those of
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which are impacted by prior years. The MTT in order to correct the current tax years, must go back and cure the error that created the issue before this tribunal. The Michigan Supreme Court has consistently held that The Tax Tribunal does have the authority to reduce an unconstitutional previous increase in taxable value for purposes of adjusting a taxable value that was timely challenged in a subsequent year. "Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers and duties as those assigned to a March board of review..., including the duty to adjust erroneous taxable values to bring the current tax rolls into compliance with the GPTA.". In. Toll Northville Limited Partnership v. Northville Township, The Supreme Court stated: The Tax Tribunal has the same powers as the March Board of Review and may adjust previously entered erroneous taxable values for purposes of bringing the current tax roll into compliance with the GPTA. The Court emphasized that correcting an earlier year's value does not reopen that year's tax liability. Instead, the earlier value is corrected because it is the mathematical basis for the current year's taxable value. In, Mikelonis v. Township of Alabaster 313 Mich App 679 (2015), earlier years were addressed by the court as erroneous uncapping, therefore granting powers to make subsequent adjustments. Similarly here, the MTT has authority to address prior year error in order to adjust the subsequent years and correct the initial issue. Michigan Properties. LLC v. Meridian Township (PDF) Page 20 (491 Mich at 537). The Court explains the core issue: "The failure to adjust the taxable value in the year immediately
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following the transfer produced an erroneous taxable value because the taxable value was not in compliance with the GPTA." Pages 24-26 (491 Mich at 541-543) , ID. Here the Court explains why correcting a prior year's taxable value does not reopen prior tax years."..may correct the taxable value in a subsequent year in order to bring the current taxable value into compliance with the GPTA. The Court states: "Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers and duties as those assigned to a March board of review..." the Court continues: "...the Tax Tribunal has the authority to reduce an unconstitutional previous increase in taxable value for purposes of adjusting a taxable value that was timely challenged in a subsequent year. CONCLUSION The facts are clear and concise that the “Trust” had Capital Hill Investments LLC as the trustee. The Trust settlor who is also the same as the Single Member of Capital Investments LLC, deeded the property back to the beneficiary, as the same single person with common control. This same analysis as can be reviewed in this brief has been upheld by the Michigan Court of Appeals and this very Michigan Tax Tribunal. The exemption under MCL 211.27(a)7(m) and as designed by the Michigan Legislature, therefore the City of Inkster assessor made an error in uncapping the taxable value. The Tribunal has inherent authority as also substantiated by the Michigan Supreme Court for the authority to adjust prior errors that impact the current tax year.
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Wherefore, Petitioner respectfully requests this Honorable Tribunal to reverse the uncapping of the taxable value in line with the Michigan Legislature intent and case law established by Michigan Courts and this Honorable Tribunal. Dated: July 23, 2026 /s/ Jeahad Kadaf Jeahad Kadaf P82492 Attorney for Petitioner 22174 Michigan ave Dearborn MI 48124
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATION HEARING SYSTEM MICHIGAN TAX TRIBUNAL CAPITAL HILL INVESTMENTS, LLC MTT Docket No: 26-000650 Petitioner, v. CITY OF INKSTER Respondent / JEAHAD KADAF (P82492) Marwan Abdullah Attorneys for the Petitioner 26215 Trowbridge 22174 Michigan Ave Inkster MI 48141 Dearborn MI 48124 City of Inkster Assessor (313) 290-0000 jkadaff@kadaflaw.com PETITIONER’S RESPONSE TO RESPONDENT'S ANSWER & PETITIONERS FACTUAL BASIS FOR APPEAL PETITIONER’S CHALLENGE TO RESPONDENT’S ANSWER PETITIONER’S ARGUMENT 3821 Wellington, Inkster MI 48141 Tax ID# 44025041161000 BACKGROUND Petitioner owns the property commonly known as 3821 Wellington, Inkster MI 48141. The property was purchased under a trust, whereas the beneficiary of the trust is Capital Hill Investments, LLC. Thereafter, the trustee settled the trust and deeded the property to the beneficiary. The important factor is that the trustee and the beneficiary are 100% owned by the same person, Mike Ghani. Here is a history of ownership with a timeline below:
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eo 3/12/2019 Petitioner purchased the property 3821 Wellington Inkster Trust also being “Capital Hill Investments” the beneficiary of the trust. o 7/3/2024 Petitioner moved the property to Capital Hill Investments LLC, who is the beneficiary of the trust and same owners as the trustee and the LLC. (EXHIBIT A) The City of Inkster treated the transfer as an uncapping under the statute as a sale. The Petitioner provided the City Assessor all the relevant information that meets the MCL 211.27(a), and further sent it by Certified Mail return receipt, USPS # 9589 0710 5270 1257 2731 45, in an attempt to assist the assessor in rectifying the issue. (EXHIBIT B). Although the Petitioner met the burden of proof, the City Assessor uncapped the property taxable value. Additionally, the City Assessor argument is that we are petitioning the wrong year, yet if you look at the notice sent by the assessor of their decision, it has the wrong address of the Petitioner. (EXHIBIT C). LAW AND ARGUMENT MCL 211.27a(7)(m) is a provision in Michigan's General Property Tax Act that excludes specific corporate changes from triggering a property tax “uncapping’ event. Specifically, it states that a direct or indirect transfer of real property or ownership interests resulting from a transaction qualifying as a tax-free reorganization under section 368 of the Internal Revenue Code does not constitute a "transfer of ownership". In TRJ & E Properties, LLC v. City of Lansing, 323 Mich App 664; 919 NW2d 795 (2018), the Michigan Court of Appeals interpreting the "commonly controlled" exception to Michigan's property tax "uncapping” rules under the General Property Tax Act (GPTA). The case is significant because it rejected a rigid administrative definition of common control and instead focused on who actually possessed the power to control the entities involved. The decision established that common control is a functional concept rather than a fixed ownership percentage. The court looked to whether the same persons possessed the practical ability to control each entity, recognizing that different organizations may require
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different voting thresholds. For example, an entity requiring a supermajority might require a higher level of common ownership to establish control than one governed by a simple majority. The court held that there is an exemption when the transfer is between “commonly controlled” entities. Here, it is the same circumstances, the transfer is not only between commonly controlled entities and a common denominator of ownership, but the Beneficiary of the trust is the entity. The trust is a legal entity as well as the single member LLC, and the same individual is effective control and ownership, notwithstanding the it was deeded from the trust to the beneficiary. Therefore, pursuant to the MCL 211.27a(7)(m) and case law, this DOES NOT trigger uncapping of the taxable value under Michigan Law. In Anderson v. Chocolay Township (MTTT Docket No. 433005), the Tribunal treated a conveyance from a trust, the Tribunal ruled it was not a transfer and exempt under MCL 211.27a(7)(m). There is no other person(s) involved in the transfer, still the same commonly controlled and ownership. Again in Shvartsman (MTT Docket Nos. 449484, 449485, 449532, 449533, 449534), Revenue Administrative Bulletin (RAB) 1989-48 recognizes that a sole proprietor can be considered part of a commonly controlled group. Evidenced in the trust, the same as the beneficiary. COURT POWERS TO ADJUST PRIOR YEARS In uncapping cases under MCL 211.27a, argument that correcting the year of transfer necessarily requires correcting every subsequent year's taxable value because each year's taxable value is derived from the prior year's taxable value. If the tribunal determines the uncapping was in error, the MTT has full authority to go back and amend prior years. These inherent powers with the MTT are to correct errors, those of
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which are impacted by prior years. The MTT in order to correct the current tax years, must go back and cure the error that created the issue before this tribunal. The Michigan Supreme Court has consistently held that The Tax Tribunal does have the authority to reduce an unconstitutional previous increase in taxable value for purposes of adjusting a taxable value that was timely challenged in a subsequent year. "Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers and duties as those assigned to a March board of review..., including the duty to adjust erroneous taxable values to bring the current tax rolls into compliance with the GPTA.". In, Toll Northville Limited Partnership v. Northville Township, The Supreme Court stated: The Tax Tribunal has the same powers as the March Board of Review and may adjust previously entered erroneous taxable values for purposes of bringing the current tax roll into compliance with the GPTA. The Court emphasized that correcting an earlier year's value does not reopen that year's tax liability. Instead, the earlier value is corrected because it is the mathematical basis for the current year's taxable value. In, Mikelonis v. Township of Alabaster 313 Mich App 679 (2015), earlier years were addressed by the court as erroneous uncapping, therefore granting powers to make subsequent adjustments. Similarly here, the MTT has authority to address prior year error in order to adjust the subsequent years and correct the initial issue. Michigan Properties, LLC v. Meridian Township (PDF) Page 20 (491 Mich at 537). The Court explains the core issue: "The failure to adjust the taxable value in the year immediately
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following the transfer produced an erroneous taxable value because the taxable value was not in compliance with the GPTA." Pages 24-26 (491 Mich at 541-543) , ID. Here the Court explains why correcting a prior year's taxable value does not reopen prior tax years."..may correct the taxable value in a subsequent year in order to bring the current taxable value into compliance with the GPTA. The Court states: "Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers and duties as those assigned to a March board of review..." the Court continues: "...the Tax Tribunal has the authority to reduce an unconstitutional previous increase in taxable value for purposes of adjusting a taxable value that was timely challenged in a subsequent year. CONCLUSION The facts are clear and concise that the “Trust” had Capital Hill Investments LLC as the trustee. The Trust settlor who is also the same as the Single Member of Capital Investments LLC, deeded the property back to the beneficiary, as the same single person with common control. This same analysis as can be reviewed in this brief has been upheld by the Michigan Court of Appeals and this very Michigan Tax Tribunal. The exemption under MCL 211.27(a)7(m) and as designed by the Michigan Legislature, therefore the City of Inkster assessor made an error in uncapping the taxable value. The Tribunal has inherent authority as also substantiated by the Michigan Supreme Court for the authority to adjust prior errors that impact the current tax year.
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Wherefore, Petitioner respectfully requests this Honorable Tribunal to reverse the uncapping of the taxable value in line with the Michigan Legislature intent and case law established by Michigan Courts and this Honorable Tribunal. Dated: July 23, 2026 /s/ Jeahad Kadaf Jeahad Kadaf P82492 Attorney for Petitioner 22174 Michigan ave Dearborn MI 48124
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EXHIBIT A
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os oN CERTIFICATION OF TRUST The undersigned, trustee(s) of the 3821 Wellington Inkster Trust confirm the following The above trust is in existence and the trust instrument was executed 9" day of March 2019 (date). The Beneficiary of the trust is/are: Capital Hill Investments, LLC The trustee or trustees of the trust is/are: Danny Haldar, Mike Abdul-Ghani The trust is Revocable (revocable or irrevocable) If there is a power to revoke the trust, the person holding the power to revoke is Beneficiaries If there are multiple trustees, the signature authority of the trustees is Danny Haidar or Mike Abdul-Ghani If there are multiple trustees, the number of the currently acting trustees required to sign in order to exercise various powers of the trustee is ONE The trust identification number is TBD (social security number or an employer identification number). The manner in which title to trust assets should be taken is 3821 Wellington Inkster Trust 10. The trust has not been revoked, modified, or amended in any manner which would cause the representations contained in the certification of trust to be incorrect. 11. This Certification is being signed by all of the currently acting trustees of the trust. Dated: 3/09/2019 N— Danny Haidar, Trustee Mi Abdul-Ghni, co-Trustee
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CERTIFICATE OF ACKNOWLEDGEMENT OF NOTARY PUBLIC KAIANA M SCISLOWICZ Notary Public ~ State of Michigan STATE OF MICHIGAN, ) COUNTY OF WAYNE On 03 -07-20( q before me, Hut AA u Snghuce. Notary Public personally appeared Danny Haidar and Mike Abdul-Ghani, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) isfare subscribed to the within instrument and acknowledged to me that helshelthey executed the same in his/herl/their authorized capacity(ies), and that by his/herftheir signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. | certify under PENALTY OF PERJURY under the laws of the State of Michigan that the foregoing paragraph is true and correct. » WITNESS my hand and officia f Signature
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2024203522 L:58967 P: 641 QCD 07/11/2024 02:31:00 PM Total Pages: 1 Benard J. Youngblood, Register of Deeds - Wayne County, MI ELECTRONICALLY RECORDED QUITCLAIM DEED (387) The Grantor, 3821 Wellington Inkster Trust whose address is 3821 Wellington, Inkster, MI 48141 quit claim to Capital Bill Investments, LLC, 8 Wyoming Limited Liability Company whose address is 109 East 17th Street, Suite 420, Cheyenne, WY 82001 the following described premises situated in: Land in the City of Inkster, County of Wayne, State of Michigan: Lot 1161, HOLTZMAN AND SILVERMAN SUBDIVISION NO. 6, according to the plat thereof as recorded in Liber 76, Page 13 of Plats, Wayne County Records. COMMONLY KNOWN AS: 3821 Wellington St., Inkster, M1 48141-3177 Tax LD. No: 44-025-04-1161-600 for the sum of One Dollar ($1.00) Dollars. Exempt from revenue MCL 207.505, Section S (a) and exempt from revenue MCL. 207.526, Section 6 (a). Dated: July 3.2024 Signed in the presence of: Signed and Sealed: 3821 Wellington /” fr STATE OF MICHIGAN COUNTY OF WAYNE Acknowledged by Mike Abdul Ghani, Trustee and Danny Haidar, Trustee before me on 3rd day of July, 2024. Notary name Notary public, State of Michigan, COUNTY OF WAYNE My Commission Expires: Drafted by: When recorded, return to: Mike Abdul-Ghani Capital Hill Investments, LLC 3821 Wellington 109 East 17th Street, Suite 420 INkster, MJ 4814} Cheyenne, WY 82001 Revenue stamps: State: 0.00 County: 0.00 Quitetzim Deed File No VT-2024-12643 Page lof |
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81 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE CINCINNATI OH 45999-0023 Date of this notice: 01-13-2017 Employer Identification Number: 81-4975575 Form: SS-4 Number of this notice: CP 575 B CAPITAL HILL INVESTMENTS LLC MIKE ABDUL GHANI MBR 109 E 17TH ST STE 430 For assistance you may call us at: CHEYENNE, WY 82001 1-800-829-4933 IF YOU WRITE, ATTACH THE STUB AT THE END OF THIS NOTICE. WE ASSIGNED YOU AN EMPLOYER IDENTIFICATION NUMBER Thank you for applying for an Employer Identification Number (EIN). We assigned you EIN 81-4975575. This EIN will identify you, your business accounts, tax returns, and documents, even if you have no employees. Please keep this notice in your permanent records. ’ When filing tax documents, payments, and related correspondence, it is very important that you use your EIN and complete name and address exactly as shown above. Any variation may cause a delay in processing, result in incorrect information in your account, or even cause you to be assigned more than one EIN. If the information is not correct as shown above, please make the correction using the attached tear off stub and return it to us. Based on the information received from you or your representative, you must file’ the following form(s) by the date(s) shown. Form 1065 03/15/2018 If you have questions about the form(s) or the due date(s) shown, you can call us at the phone number or write to us at the address shown at the top of this notice. If you need help in determining your annual accounting period (tax year), see Publication 538, Accounting Periods and Methods. We assigned you a tax classification based on information obtained from you or your representative. It is not a legal determination of your tax classification, and is not binding on the IRS. If you want a legal determination of your tax classification, you may request a private letter ruling from the IRS under the guidelines in Revenue Procedure 2004-1, 2004-1 I.R.B. 1 (or superseding Revenue Procedure for the year at issue). Note: Certain tax classification elections can be requested by filing Form 8832, Entity Classification Election. See Form 8832 and its instructions for additional information. A limited liability company (LLC) may file Form 8832, Entity Classification Election, and elect to be classified as an association taxable as a corporation. If the LLC is eligible to be treated as a corporation that meets certain tests and it will be electing S corporation status, it must timely file Form 2553, Election by a Small Business Corporation. The LLC will be treated as a corporation as of the effective date of the S corporation election and does not need to file Form 8832. To obtain tax forms and publications, including those referenced in this notice, visit our Web site at www.irs.gov. If you do not have access to the Internet, call 1-800-829-3676 (TTY/TDD 1-800-829-4059) or visit your local IRS office.
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(IRS USE ONLY) 575B 01-13-2017 CAPI B 9999999999 Ss-4 IMPORTANT REMINDERS : * Keep a copy of this notice in your permanent records. This notice is issued only one time and the IRS will not be able to generate a duplicate copy for you. You may give a copy of this document to anyone asking for proof of your EIN. Use this EIN and your name exactly as they appear at the top of this notice on all your federal tax forms. * Refer to this EIN on your tax-related correspondence and documents. If you have questions about your EIN, you can call us at the phone number or write to us at the address shown at the top of this notice. If you write, please tear off the stub at the bottom of this notice and send it along with your letter. If you do not need to write us, do not complete and return the stub. Your name control associated with this EIN is CAPI. You will need to provide this information, along with your EIN, if you file your returns electronically. Thank you for your cooperation. Keep this part for your records. CP 575 B (Rev. 7-2007) Return this part with any correspondence so we may identify your account. Please CP 575 B correct any errors in your name or address. 9999999999 Your Telephone Number Best Time to Call DATE OF THIS NOTICE: 01-13-2017 ( ) EMPLOYER IDENTIFICATION NUMBER: 81-4975575 FORM: Ss-4 NOBOD INTERNAL REVENUE SERVICE CAPITAL HILL INVESTMENTS LLC CINCINNATI OH 45999-0023 MIKE ABDUL GHANI MBR Llasbslshibaduslslabsbsollsalbnsalibullibiludd 109 E 17TH ST STE 430 CHEYENNE, WY 82001
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OPERATING AGREEMENT of Capital Hill Investments LLC This Operating Agreement (the "Agreement") made and entered into this 1st day of November, 2018 (the "Execution Date"), BY: Mike Ghani of 4764 Orchard Ave, Dearborn, MI 48126 (the "Member"). BACKGROUND: A. The Member wishes to be the sole member of a limited liability company. B. The terms and conditions of this Agreement will govern the Member within the limited liability company. IN CONSIDERATION OF and as a condition of the Member entering into this Agreement and other valuable consideration, the receipt and sufficiency of which is acknowledged, the Member agrees as follows: Formation 1. By this Agreement, the Member forms a Limited Liability Company (the "Company") in accordance with the laws of the State of Wyoming. The rights and obligations of the Member will be as stated in the Wyoming Limited Liability Company Act (the "Act") except as otherwise provided in this agreement. Name 2. The name of the Company will be Capital Hill Investments LLC. Page 1 0f 13
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LLC Operating Agreement Page 2 of 13 Sole Member 3. While the Company consists only of one Member, any reference in this Agreement to two or more Members and that requires the majority consent or unanimous consent of Members, or that requires a certain percentage vote of Members, should be interpreted as only requiring the consent or vote of the sole Member. Purpose 4. This company is organized for the conduct of any or all lawful affairs for which a limited liability company may be organized. Term 5. The Company will continue until terminated as provided in this Agreement or may dissolve under conditions provided in the Act. Place of Business 6. The Principal Office of the Company will be located at 109E 17th ST, Suite 430 Cheyenne, WY 82001 or such other place as the Member may from time to time designate. Capital Contributions 7. The following table shows the Initial Contributions of the Member. The Member agrees to make the Initial Contributions to the Company in full, according to the following terms: A Value of Member Contribution Description . Contribution THE FUNDS TO PAY AND FIX ALL INVESTMENT Mike Ghani 250,000.00 ee han CONTRIBUTIONS IN REAL $25 PROPERTY
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N LLC Operating Agreement Page 3 of 13 10. 11. 12. 13. 14. Allocation of Profits/Losses Subject to the other provisions of this Agreement, the Net Profits or Losses, for both accounting and tax purposes, will accrue to and be borne by the sole Member: Mike Ghani of 4764 Orchard Ave, Dearborn, MI 48126. Where the Company consists of two or more Members, no Member will have priority over any other Member for the distribution of Net Profits or Losses. Nature of Interest A Member's Interest in the Company will be considered personal property. Withdrawal of Contribution Where the Company consists of two or more Members, no Member will withdraw any portion of their Capital Contribution without the unanimous consent of the other Members. Liability for Contribution A Member's obligation to make their required Capital Contribution can only be compromised or released with the consent of all remaining Members or as otherwise provided in this Agreement. If a Member does not make the Capital Contribution when it is due, he is obligated at the option of any remaining Members to contribute cash equal to the agreed value of the Capital Contribution. This option is in addition to and not in lieu of any others rights, including the right to specific performance that the Company may have against the Member. Additional Contributions Capital Contributions may be amended from time to time, according to the business needs of the Company. However, if additional capital is determined to be required and an individual Member is unwilling or unable to meet the additional contribution requirement within a reasonable period, and where the Company consists of two or more Members, the remaining Members may contribute in proportion to their existing Capital Contributions to resolve the amount in default. In such case, the allocation of Net Profits or Losses and the distribution of assets on dissociation or dissolution will be adjusted accordingly. Any advance of money to the Company by any Member in excess of the amounts provided for in this Agreement or subsequently agreed to, will be deemed a debt due from the Company rather than an increase in the Capital Contribution of the Member. This liability will be repaid with
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LLC Operating Agreement Page 4 of 13 interest at such rates and times to be determined by a majority of the Members. This liability will not entitle the lending Member to any increased share of the Company's profits nor to a greater voting power. Repayment of such debts will have priority over any other payments to Members. Capital Accounts 15. An individual capital account (the "Capital Account") will be maintained for each Member and their Initial Contributions will be credited to this account. Any Additional Contributions made by any Member will be credited to that Member's individual Capital Account. Interest on Capital 16. No borrowing charge or loan interest will be due or payable to any Member on their agreed Capital Contribution inclusive of any agreed Additional Contributions. Management 17. Management of this Company is vested in the Member. Authority to Bind Company 18. Only the following individuals have authority to bind the Company in contract: Mike Ghani. Duty of Loyalty 19. While a person is a Member of the Company, that person will not carry on, or participate in, a similar business to the business of the Company within any market regions that were established or contemplated by the Company before or during that person’s tenure as Member. Duty to Devote Time 20. Each Member will devote such time and attention to the business of the Company as the majority of the Members will from time to time reasonably determine for the conduct of the Company's business. Member Meetings 21. Where the Company consists of two or more Members, a meeting may be called by any Member providing that reasonable notice has been given to the other Members. 22. Regular meetings of the Members will be held only as required.
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LLC Operating Agreement
Page 13 of 13
g.
"Operation of Law" means rights or duties that are cast upon a party by the law, without
any act or agreement on the part of the individual, including, but not limited to, an
assignment for the benefit of creditors, a divorce, or a bankruptcy.
h.
"Principal Office" means the office whether inside or outside the State of Wyoming where
the executive or management of the Company maintain their primary office.
i.
"Voting Members" means the Members who belong to a membership class that has voting
power. Where there is only one class of Members, then those Members constitute the
Voting Members.
IN WITNESS WHEREOF the Member has duly affixed their signature under hand and seal on this 1st
day of November, 2018.
Mike Ghalt{(MemPer)!
©2002-2018 LawDepot.com®Page 25
EXHIBIT B
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SENDER: COMPLETE THIS SECTI & Complete items 1, 2, and 3. ® Print your name and addi ress on the rev so that we can return the card to you. gr COMPLETE THIS'SECTIONON/ DELIVERY: B Attach this card to the back of i th . or on the front if space permits. iia xf] ( (Fr /, ~~ OJ Agent 1 i J Addres: 3 Received by (Print ) E C. D: = Jim en Toe fr; po 1, —— sooo D. Is delivery address different from item 1? LJ Yes Mayo is Office If YES, enter delivery address below: No 26215 Trowbridge Inkster M1 48141 TT === [ - Delivery Restricted Delivery 5 Pesiotnt Deane on 9589 07.0 5270 1257 2731 38 — wou ell i fa ho) | Restricted Delivery al PS Form 3811, July 2020 PSN 7530-02-000-9053 Domestic Return Receipt SENDER: COMPLETE THIS SECTION! ® Complete items 1, 2, and 3. . ® Print your name and address on the veverse so that we can return the card to you. | Attach this card to the back of the mailpiece, or on the front if space permits. ‘ COMPLETE THIS SECTION\ON/DELIVERY: 1. Article Addressed to: Assessors Office 26215 Trowbridge Inkster M1 48141 EH BAI 9590 9402 8397 3156 0755 23 Artinla Pr 958% 071 2 g oi 3 o \ pry b) bli, 3 2 Address R “Received by (Printed 9 C. Date of Deliv » = 1 iS (Evra 1 shy | Bf) D. Is delivery address different from item 1? Yes If YES, enter delivery address below: ~~ [1 No 3. Service Type 0 Priority Mall Express® 0 Adult Signature O Registered Mail™ 0 Adult Signature Restricted Delivery O Registered Mail Restricted 0 Certified Mail® Delivery 0 Certified Mail Restricted Delivery 0 Signature Confirmation™ 0 Collect on Delivery 0 Signature Confirmation ==" 1 Delivery Restricted Delivery Restricted Delivery lail 4 5 __ lal Restricted Delivery |__ (over $50 Domestic Return Receipt } PS Form 3811, July 2020 PSN 7530-02-000-9053
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EXHIBIT C
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eas Open Tor THIS IS NOT A TAX BILL L-4400 1019 (Rev, 10-24) Notice of Assessment, Taxable Valuation, and Property Classification 2 This form is issued under the authority of P.A. 206 of 1893, Sec. 211.24 (c) and Sec.211.34c, as amended. This is a mode! notice to be used by the local assessor. FROM PARCEL IDENTIFICATION ASSESSORS OFFICE CITY OF INKSTER PARCEL NUMBER: 44.025 04 1161 000 26215 TROWBRIGE PROPERTY ADDRESS: 3821 WELLINGTON INKSTER, MI 48141 INKSTER, MI 48141 OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: PRINCIPAL RESIDENCE EXEMPTION 520 % Exempt As "Homeowners Principal Reside 00% “kaa a4 *+AUTO* *MIXED AADC 493 % Exempt As "Qualified Agricultural Property 00% CAPITAL HILL INVESTMENTS LLC " in. 0; 109 E 17TH ST STE 420 % Exempt As "MBT Industrial Personal” 00% CHEYENNE, WY 82001-4543 % Exempt As "MBT Commercial Personal: 00% [LTE SUTTER TTL UE TT ETL RUT LE HR Exempt As "Qualified Forest Property: [] Yes [X] No Exempt As "Development Property []Yes [X] No LEGAL DESCRIPTION: 31P1161 LOT 1161 HOLTZMAN AND SILVERMAN SUB NO. 6 T2S R10E L76 P13 WCR ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 401 Residential PRIOR YEAR'S CLASSIFICATION: 401 Residential The change in taxable value will increase/decrease your tax bill for the 2025 PRIOR AMOUNT CURRENT TENTATIVE CHANGE FROM year by approximately: $1115 YEAR: 2024 AMOUNT YEAR: 2025 ROR Rn 1. TAXABLE VALUE: 18,822 34,300 15,478 2. ASSESSED VALUE: 28,500 34,300 3. TENTATIVE EQUALIZATION FACTOR: 1.000 [0 ERR ) 4. STATE EQUALIZED VALUE (SEV): 28.500 34.300 5,800 5. There WAS or WAS NOT a transfer of ownership on this property in 2024 WAS 6. Assessor Change Reason(s): Market Adjustment The 2025 Inflation rate Multiplier is: 1.031 Questions regarding the Notice of Assessment, Taxable Valuation; and Property Classification may be directed to the Following: Phone: Email Address: WCAUSER@CITYOFINKSTER.COM Name: ASSESSING STAFF 313-563-4267 March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: THE BOARD OF REVIEW WILL BEGIN MEETING ON MARCH 10, 2025 TO CONSIDER APPEALS ON PROPERTY ASSESSMENTS AT THE CITY OF INKSTER CITY HALL COUNCIL CHAMBERS, 26215 TROWBRIDGE. MARCH 10, 3:00 PM - 9:00 PM WITHA DINNER BREAK, MARCH 11, 9:30AM - 11:30AM AND 1:00PM - 4:30PM, AND MARCH 17, 9:30 AM - 11:30AM AND 1:00PM - 4:30PM, -BY APPOINTMENT ONLY - CALL (313)563-4267 FOR QUESTIONS AND/OR APPOINTMENTS. WRITE-IN APPEALS MUST BE RECEIVED BY 4:00PM ON MARCH 17, 2025.
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Guidance regarding Form 1019, Notice of Assessment, Taxable Valuation, and Property Classification Not less than 14 days before the first meeting of the Board of Review, the assessment notice shall be mailed to the property owner. Property taxes are calculated based on the Taxable Value (Line 1). State Equalized Value is the Assessed Value multiplied by the Equalization Factor, if any. State Equalized Value must approximate 50% of market value. The Taxable Value number entered in the “Change from Prior Year to Current Year” Column, does not indicate a change in your taxes. The change in your tax bill is estimated above Line 1. State Equalized Value is the Assessed Value multiplied by the Equalization Factor, if any. State Equalized Value must approximate 50% of market value. IF THERE WAS A TRANSFER OF OWNERSHIP on your property in 2024, your 2025 Taxable Value will be the same as your 2025 State Equalized Value. IF THERE WAS NOT A TRANSFER OF OWNERSHIP on your property in 2024, your 2025 Taxable Value is calculated by multiplying your 2024 Taxable Value by 1.031 (Inflation Rate Multiplier for the current year). Physical changes in your property may also increase or decrease your Taxable Value. Yolir 2025 Taxable Value cannot be higher than your 2025 State Equalized Value. ) The Taxable Value, the Assessed Value, the State Equalized Value, the Property Classification, or the Transfer of Ownership may be appealed by filing a protest with the Local Board of Review. Protests are made to the Board of Review by completing a Board of Review Petition Form. A Petition Form may be obtained directly from the local unit or from the Michigan Department of Treasury’s website at www.michigan.govi/taxes. Click on the “Property Taxes” box, select “Forms and Instructions,” then click on “Board of Review” to obtain a “Petition to the Board of Review,” Form 618 (L-4035). ' The denial of an exemption from the local school operating tax for “qualified agricultural properties” may be appealed to the local Board of Review. The denial of an exemption from the local school operating tax for a “homeowners principal residence” may be appealed to the Michigan Tax Tribunal by the filing of a petition within 35 days of issuance of this notice. The petition must be a form approved by the Michigan Tax Tribunal, which are available at www.michigan.gov/ taxtrib. : Filing a protest with the Board of Review is necessary to protect your right to further appeal valuation and exemption disputes to the Michigan Tax Tribunal and classification appeals to the State Tax Commission. Properties classified Commercial Real, Industrial Real or Developmental Real may be appealed to the regular March Board of Review or to the Michigan Tax Tribunal by filing a petition by May 31. Commercial Personal, Industrial Personal, or Utility Personal Property may be appealed to the regular March Board of Review or to the Michigan Tax Tribunal by filing a petition by May 31 if a personal property statement was filed with the local unit prior to the commencement of the Board of Review as provided by MCL 211.19, except as otherwise provided by MCL 211.9m, 211.9n and 211.90. The petition must be a form approved by the Michigan Tax Tribunal, which are available at www.michigan.govitaxtrib. To claim a PRE, complete the “Principal Residence Exemption Affidavit” (Form 2368) and file it with your township or city of the year of the claim. A valid affidavit filed on or before June 1 allows an owner to receive a PRE on the current year summer and winter tax levy and subsequent tax levies so long as it remains the owner's principal residence. A valid affidavit filed after June 1 and on or before November 1 allows an owner to receive a PRE on the current winter tax levy and subsequent tax levies so long as it remains the owner's principal residence.
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10/17/25, 9:38 AM Parcel Number - 44 025 04 1161 000 | City of Inkster | BS&A Online (3821 'WELLIN: GTON INKSTER, MI 48141 (Property Address) Parcel Number: 44 025 04 1161 000 Account Number: 1191950 Summary Information > Residential Building Summary - Year Built: 1955 - Bedrooms: 0 Full Baths: 1 - Half Baths: 0 Sq. Feet: 1,036 - Acres: 0.115 > Utility Billing information found Item 1 0f 2 1 Image / 1 Sketch Customer Name: CAPITAL HILL INVESTMENTS LLC > Assessed Value: $34,300 | Taxable Value: $34,300 > Property Tax information found > 16 Building Department records found Owner and Taxpayer Information Owner CAPITAL HILL INVESTMENTS LLC 109 E. 17TH STREET, STE 420 CHEYENNE, WY 82001 Taxpayer General Information for Tax Year 2025 SEE OWNER INFORMATION Property Class 401 RESIDENTIAL-IMPROVED Unit 44 INKSTER School District TAYLOR SCHOOL DISTRICT Assessed Value $34,300 MAP # No Data to Display Taxable Value $34,300 User Number Index 0 State Equalized Value $34,300 User Alpha 1 Not Available Date of Last Name Change ~~ 07/17/2024 User Alpha 3 Not Available Notes Not Available Historical District Not Available Census Block Group Not Available User Alpha 2 Not Available Exemption No Data to Display Principal Residence Exemption Information Homestead Date No Data to Display Principal Residence Exemption June 1st Final 2025 0.0000 % 0.0000 % Previous Year Information Year MBOR Assessed Final SEV Final Taxable 2024 $28,500 $28,500 $18,822 2023 $26,000 $26,000 $17,926 2022 $21,300 $21,300 $17,073 Land Information Zoning Code No Data to Display Total Acres 0.115 Land Value $6,400 Land Improvements $0 Renaissance Zone No Renaissance Zone Expiration No Data to Display Date ECF Neighborhood 44-TAYLOR Mortgage Code No Data to Display Lot Dimensions/Comments No Data to Display Neighborhood Enterprise No Zone Lot(s) Frontage Depth Lot 1 50.00 ft 100.00 ft Total Frontage: 50.00 ft ee sie ] Legal Description Average Depth: 100.00 ft 31P1161 LOT 1161 HOLTZMAN AND SILVERMAN SUB NO. 6 T2S R10E L76 P13 WCR Land Division Act Information https:/bsaonline.com/SiteSearch/SiteSearchDetails?SearchFocus=Assessing&SearchCategory=Address&SearchText=3821&uid=671&Pagelndex=1... 13
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10/17/25, 9:38 AM Date of Last Split/Combine Date Form Filed Date Created No Data to Display No Data to Display No Data to Display Parcel Number - 44 025 04 1161 000 | City of Inkster | BS&A Online Number of Splits Left 0 Unallocated Div.s of Parent 0 Unallocated Div.s Transferred 0 Acreage of Parent 0.00 Rights Were Transferred Not Available Split Number 0 Courtesy Split Not Available Parent Parcel No Data to Display Sale History Sale Date Sale Price Instrument Grantor Grantee Terms of Sale Liber/Page 07/03/2024 $1.00 PTA 3821 WELLINGTON CAPITAL HILL 21-NOT USED/OTHER INKSTER TRUST INVESTMENTS LLC 03/12/2019 $11,000.00 QC WELCH, DAVID & 3821 WELLINGTON 21-NOT USED/OTHER MARILYN INKSTER TRUST 06/28/2018 $17,666.00 PTA HTC CUSTODIAN FBO WELCH, DAVID & 21-NOT USED/OTHER DAVID WELCH MARILYN 02/22/2016 $60,420.00 PTA NBC PROPERTIES LLC HTC CUSTODIAN FBO 03-ARM'S LENGTH DAVID WELCH 11/20/2014 $29,000.00 PTA VESTCO MANAGEMENT NBC PROPERTIES LLC 03-ARM'S LENGTH LLC 10/04/2013 $0.00 PTA COUNTY SHERIFF JPMORGAN CHASE 10-FORECLOSURE BANK 04/04/2013 $4,065.00 SD DUBOSE, WILL et al JPMORGAN CHASE 21-NOT USED/OTHER 2013252007 BANK et al 06/10/1997 $10.00 WD 31-SPLIT IMPROVED 98020860 Building Information - 1036 sq ft 1.00 STORY (Residential) 1 General Floor Area 1,036 sq ft Estimated TCV Not Available Garage Area 0sq ft Basement Area 0sq ft Foundation Size 1,036 sq ft Year Built 1955 Year Remodeled No Data to Display Occupancy Single Family Class C-5 Effective Age 69 yrs Tri-Level No Percent Complete 0% Heat Forced Air w/ Ducts AC w/Separate Ducts No Wood Stove Add-on No Basement Rooms 0 Water Public Water 1st Floor Rooms 0 Sewer Public Sewer 2nd Floor Rooms 0 Style 1.00 STORY Bedrooms 0 Area Detail - Basic Building Areas Height Foundation Exterior Area Heated 1 Story Slab Brick 1,036sq ft 1Story Exterior Information Brick Veneer 05sq ft Stone Veneer 05sq ft Basement Finish Recreation 0sq ft Recreation % Good 0% Living Area 05sq ft Living Area % Good 0% Walk Out Doors 0 No Concrete Floor Area 0sq ft Plumbing Information 3 Fixture Bath 1 Ceramic Tile Floor 1 Ceramic Tub Alcove Built-In Information Appliance Allow. https://bsaonline.com/SiteSearch/SiteSearchDetails?SearchFocus=Assessing&SearchCategory=Address&SearchText=3821&uid=671&Pagelndex=1... 2/3