Amended Petition - Toma Flint - Copy.pdf
Kent Group 3302 Petitioner Vs. City Of Flint Respondent · 26-000755-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL KENT GROUP 3302, LLC, Docket No. 26-000755 Parcel No. 41-16-351-052 Petitioner, v. CITY OF FLINT, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com AMENDED ENTIRE TRIBUNAL PROPERTY TAX PETITION Petitioner Kent Group 3302, LLC, by and through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Amended Entire Tribunal Property Tax Petition. The Parties 1. Petitioner Kent Group 3302, LLC is a Michigan limited liability company whose address is 10355 Capital Street, Oak Park, MI 48237. 2. Respondent City of Flint is a Michigan municipal corporation with its primary offices located at 1101 S. Saginaw Street, Flint, MI 48502.
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The Subject Property 3. Petitioner owns property identified as Parcel No. 41-16-351-052 and commonly known as 3302 Kent Street, Flint, MI 48503 (the “Subject Property”). 4. The Subject Property is located in Genesee County and is within the Flint City 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 improved 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 2,918,000 1,459,000 1,459,000 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 2,000,000 1,000,000 1,000,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value 918,000 459,000 459,000 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”),
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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/ Brian E. Etzel Brian E. Etzel (P54905) Dated: May 7, 2026 Attorneys for Petitioner