2026 AMENDED Petition - JK - 4598 State.pdf

Canyon Venture III LLC Petitioner Vs. Township Of Saginaw Respondent · 26-001448-TT

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STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURES III LLC, 

Petitioner, 

vs. 

SAGINAW CHARTER TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 23-12-4-16-3008-006 

 

AMENDED PETITION 

 

 

CANYON VENTURES III LLC (“Petitioner”), through its attorneys, Law Office 

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

 

1. 

Petitioner's principal office address is 30201 Orchard Lake Rd. , Ste. 

110, Farmington Hills, MI 48334. Petitioner is a party in interest with respect to 

property taxes on real property tax parcel no. 23-12-4-16-3008-006 ("Petitioner's 

Property"), at 4598 State St., Saginaw, MI, 48603. 

 

2. 

Respondent, Saginaw Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $977,300 and assessed Petitioner's Property at $977,300 resulting in 

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

factor. 

001448

4. 

Petitioner's Property is classified as Commercial Real Property. 

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

Property was designed to be used as a 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 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 2026 taxable value of Petitioner's Property from $977,300 to 

$500,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $977,300 to $500,000, and requiring Respondent to pay 

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

 

 

 

 

 

 

 

 

 

 

 

 

Dated: 

Respectfully submitted, 

 

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

Attorney for Petitioner 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Suite 350 

 Birmingham, MI 48009 

 (248) 767-9840 

 

 

 

 

9/14/26

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