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2026 Petition - EJP2 - Don Juan.pdf

Ejp2 LLC Petitioner Vs. City Of Detroit Respondent · 26-001078-TT

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

EJP2 LLC, 

Petitioner, 

vs. 

CITY OF DETROIT, 

Respondent. 

/

 

 

 

MTT Docket #26-00 

Parcel No. (Various – See Below) 

 

 

 

 

PETITION 

 

 

EJP2 LLC (“Petitioner”), through its attorneys, Law Office of Aaron M. Fales, 

P.C., says: 

 

1. 

Petitioner's principal office address is 8901 E Jefferson, Detroit, MI 

48214. Petitioner is a party in interest with respect to property taxes on 

contiguous real property tax parcel no(s). 19008841., 19008842., 19008843., 

19008844., and 19008845. ("Petitioner's Property"), at 1141-1167 Holcomb, Detroit, 

MI, 48226. 

 

2. 

Respondent, City of Detroit assesses and collects property taxes on 

Petitioner's Property. 

 

3. 

 In 2026, Respondent determined the values of Petitioner's Parcels to 

be: 

Address 

Parcel # 

 2026 AV/SEV 

 2026 TV 

1167 Holcomb 

19008841.

 $ 3,400 

 $ 2,114 

1161 Holcomb 

19008842.

 $ 3,400 

 $ 2,074 

1157 Holcomb 

19008843.

 $ 3,400 

 $ 2,114

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1151 Holcomb 

19008844.

 $ 3,100 

 $ 1,832 

1141 Holcomb 

19008845.

 $ 842,000 

 $ 396,856 

 

 

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

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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 Parcels from the current 

assessments down to the Following: 

Requested 

Requested 

Address 

Parcel # 

 2026 AV/SEV 

 2026 TV 

1167 Holcomb 

19008841.

 $ 500 

 $ 500 

1161 Holcomb 

19008842.

 $ 500 

 $ 500 

1157 Holcomb 

19008843.

 $ 500 

 $ 500 

1151 Holcomb 

19008844.

 $ 500 

 $ 500 

1141 Holcomb 

19008845.

 $ 200,000 

 $ 200,000 

 

and requiring Respondent to pay Petitioner the refunds attributable to such 

reductions, plus interest and costs.

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Dated: ___________, 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 

 

 

 

 

May 16

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