Petition - 3459 Miller.pdf
3459 Miller, LLC Petitioner Vs. Township Of Flint Respondent · 26-000694-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL 3459 Miller, LLC, Docket No. 26- Petitioner, Parcel No. 07-27-100-021 v. Township of Flint, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioner Entire Tribunal Property Tax Petition Petitioner 3459 Miller, LLC, by and through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. The Parties 1. Petitioner 3459 Miller, LLC is a Michigan limited liability company with its principal place of business in Michigan located at 4143 Lindow Drive, Sterling Heights, Michigan 48310. 2. Respondent Township of Flint is a Michigan township with its principal
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offices located at 1490 S. Dye Road, Flint, MI 48532. The Subject Property 3. Petitioner owns property identified as Parcel No. 07-27-100-021 and commonly known as 3459 Miller Road, Flint, Michigan 48507 (the “Subject Property”). 4. The Subject Property is located in Genesee County and is within the Carman-Ainsworth School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2026 Assessment 6. For the 2026 tax year, Respondent classified the Subject Property as commercial real property. 7. For the 2026 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value 1,310,000 655,000 646,207 8. Petitioner contends that a lawful assessment of the Subject Property for the 2026 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value 800,000 400,000 400,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value 510,000 255,000 246,207
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10. This Petition presents issues involving the Subject Property’s valuation for assessment purposes. Petitioner does not believe that this Petition presents any issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues involving losses should information supporting such issues become available. 11. The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 12. Petitioner does not assert that the Subject Property’s 2026 assessment is not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Property’s values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Jerome P. Pesick Jerome P. Pesick (P29039) Dated: April 22, 2026 Attorneys for Petitioner