METAMORA PETITION & SUPPORT.pdf

Jupiter Land Management LLC Petitioner Vs. Township Of Metamora Respondent · 26-001115-TT

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

JUPITER LAND MANAGEMENT, LLC, 

Petitioner, 

vs. 

METAMORA TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 015-029-002-10 

 

PETITION 

 

 

JUPITER LAND MANAGEMENT, LLC (“Petitioner”), through their attorneys, 

Law Office of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is PO Box 480485, New Haven, MI 

48048. Petitioner is a party in interest with respect to property taxes on real 

property tax parcel no. 015-029-002-10 ("Petitioner's Property"), at S Lapeer Rd., 

Metamora, MI 48371. 

 

2. 

Respondent, Metamora Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

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

Property to be $404,500 and assessed Petitioner's Property at $404,500 resulting in 

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

factor.

Page 2

4. 

Petitioner's Property is classified as Agricultural Real Property. 

Petitioner's Property is Agricultural property. Petitioner believes that Petitioner's 

Property was designed to be used for Industrial 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 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,

Page 3

(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 $404,500 to 

$200,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $404,500 to $200,000, and requiring Respondent to pay 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 19, 2026 

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

Page 4

Metamora Township Assessing Department 

730 W Dryden Rd, Metamora, Ml 48455 

JUPITER LAND MANAGEMENT 

48991 JEFFERSON AVE 

CHESTERFIELD, MI 48047 

March 17, 2026 

Dear Property Owner, 

Included with this letter is a copy of the decision made by the March Board of 

Review regarding your petition. 

If you disagree with the decision, you may appeal to the Michigan Tax Tribunal by 

filing a petition to PO Box 30232, Lansing, MI 48909. Commercial Real and 

Personal, Industrial Real and Personal, Developmental Real, and Utility Personal 

Property may be appealed by May 31. Agricultural Real and Personal, Residential 

Real, and Timber-Cutover Real Property may be appealed by July 31. The petition 

must be filed on a Michigan Tax Tribunal form or a form approved by the Michigan 

Tax Tribunal. Michigan Tax Tribunal forms are available at 

www.michigan.gov/taxtrib. 

Thank You, 

Kaili Ropp, Deputy Assessor 

Metamora Township 

deputyasr@Metamoratownship.com 

Tuesday/Thursday 9am-3pm 

P: 810.678.2237 

F: 810.678.3209 

=] 

Metamora Township

Page 5

This page is blank in the source PDF.

Page 6

. 

* 

Pi 

25 

Michigan Department of Treasury 

618 (Rev, 12-25) 

Petition to Board of Review 

L-4035 

This form is issued under the authority of P.A. 206 of 1893, as amended. Filing is voluntary; however, you may not appeal to the Michigan Tax Tribunal unless you first protest 

to the Board of Review, except when the properly is classified as commercial real, industrial real, or developmental real. You may not appeal property classification to the State 

Tax Commission unless you first protest to the Board of Review. 

TO BE COMPLETED BY OWNER OR OWNER’S AGENT 

Owner's Name {Please Print or Type) 

Petitioner's Name (If Gther than Owner. Please Print or Type) 

Jupiter Land Management LLC 

Township or City 

County 

Year of Appeal 

Metamora 

Lapeer 

2026 

The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified 

agricultural property exemption of the following described property: 

Property Identified {Parcel code required. Property address and legal description optional.) 

015-029-002-10 

Protested item: 

Assessed Value SZ Fertative 

0 Taxable Status 

Classification SE qualified Agricultural 

Taxable Value 

(exemption) 

Property Exemption 

1, PROTEST OF ASSESSMENT 

Complete this section for a protest of assessed value, including assessed value changes associated with exempt status and denied or late filed 

personal property forms. 

Assessed Value 

Owner's Estimate of True Cash Value (Market Value) 

$404,500 

$400,000 

2. PROTES 

Complete this section for a protest of Taxable Value. 

Reason: 

Value of Losses 

1 Value of Additions 

Poverty Exemption 

1 Uncapping % 

3. PROTEST 

OF 

Complete this section for a request to change the classification. The Board of Review must make their decision regarding classification in accordance 

with Section 211.34c¢ of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular classification has on 

that property's status as a homeowner's principal residence or qualified agricultural property.) 

Classification of property on this year’s assessment rolt 

Residential 

Classification should be (check one of the following): 

Agricultural 

Industrial 

Timber Cutover 

Utility (Personal Property Only} 

1 Commercial 

Residential 

O Developmental 

4. PROTEST OF EXEMPTION FOR/QUALIFIED 

AGRICULTURAL 

PROPERTY. 

If the assessor has denied or changed the percentage of the exemption from the 18 mills of local school operating tax for qualified agricultural proper- 

ty, the owner may appeal this action to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT UPON 

THE EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.) 

Percent qualified agricultural exemption granted by assessor {Enter 0 if exemption 

Percent qualified agricultural exemption requested by owner (Enter 100 if full 

denied) 

exemption requested) 

100 

REASON 

FOR PROTEST 

State reason(s) for protest of assessed Value and for 

Sr the Tentative axable value andlor axable status and/or classification and/or qualified 

agricultural property exemption 

Value is in excess of 50% of FMV and therefore unlawful, This classification should also be Agricultural 

CERTIFICATIO 

= 

Signaty, 

- 

a 

Date 

Phone Number 

yd 

N 

& 

oe 

; 

377126 

(248) 767-9840 

osnt-setmereon Ave, ChosTametc- 

erson Ave, Chesterfigit; 

MI 48047 - 

—

Page 7

618, Page 2

FOR BOARD OF REVIEW USE ONLY

INSTRUCTIONS: Incorporate a copy of this form and the assigned number in the Board of Review minutes

Petition Number

Parcel Code

X Denied

] Assessed Value Changed From

Record of Vote ~~ Board or three-member committee of board

Chairperson:

Yes 1 No

i 7

Member:

Ja Yes ] Noy

Initials

Agi wi adsoeasmiait

Member:

Xl Yes

No sh

Initials

Reason for Board Action

1f you disagree with the decision of the Board of Review regarding tentative assessed value, you may appeal that decision by filing a petition with the Michigan Tax Tribunal

at PO Box 30232, Lansing, MI 48809. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, Industrial Personal and Utility Personal Property may

be appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and Agricultural Personal Property may be appealed by July 31. The petition must be filed

on a Michigan Tax Tribunal form or a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan.goy/taxtrib.

ENTATIVE TAXABLE

VALUE

Oispasition by Board of Review. The Board of Review must state the reason for its action below

Xl Denied

Hl! Tentative Taxable Value Changed From

{See attached L-4035A)

Record of Vote — Board or three-member committee of board

“5 ya

Chairperson:

Xl Yes O No

% ,

Member:

hy Yes J No

Wy "Member:

X Yes I! No a

tials

Irfitial

Initials

Reason for Board Action

If you disagree with the decision of the Board of Review regarding tentative taxable value, you may appeal that decision by filing a petition with the Michigan Tax Tribunal at

PO Box 30232, Lansing Mi 48908. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, Industrial Personal and Utility Personai Property may be

appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and Agricultural Personal Property may be appealed by July 31. The petition must be filed on

a Michigan Tax Tribunal form or a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michlgan.goviiaxirib.

ASSIEN

[s}

Disposition by Board of Review. The Board of Review must state the reason for its action below.

4 Denied

X Classification Changed From Rordontost

7 77

Record of Vote — Board ar three-member committee of board

Chairperson:

Yes OO No

Member:

] Yes Il No

Member:

Ol Yes O No

Initials

Reason for Board Action (Lrdnffeiotn

[od

if you disagree with the decision of the Board of Review regarding classification, you may appeal by sending Form 2167 to the State Tax Commission at PO Box 30471,

Lansing MI 48909, by June 30.

4: QUALIFIED AGRICULTURAL

PROPERTY EXEMPTION

Disposition by Board of Review. The Board of Review must state the reason for its action below.

1 Exemption Request Denied

Bexemption percent modified from

oO)

% to

Record of Vote — Board or three-member i of board

Chairperson:

Yes [| No

Member:

Yes [No

Member:

RB Yes [| No ar

initials

Reason for Board Action

Initials

If you disagree with the decision of the Board of Review regarding qualified agricultural property exemption, you may appeal that decision by filing a petition with the

Michigan Tax Tribunal at PO Box 30232, Lansing MI 48909 by July 31. The petition must be filed ona Michigan Tax Tribunal form or a form approved by the Michigan Tax

Tribunal. Michigan Tax Tribunal forms are available at www.michigan.qov/taxiri.

\DJOURNMEN

Date of Final Adjournment of Board of Review

5 Review Secretary Signature,

Date

2orge

B23 6

PDF reading copy

← View full record