Response to Motion to Amend Petition to Contest 2026 Assessed and Taxable Value & POS.pdf

Flagstar Bank, N.A., Petitioner Vs. City Of Marquette, Respondent · 25-001691-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

FLAGSTAR BANK, N.A. 

 

 

Petitioner, 

 

v 

 

 

 

 

 

 

 

 

MTT Docket No. 25-001691 

 

 

 

 

 

 

 

 

 

Parcel No. 0400420 

CITY OF MARQUETTE, 

 

 

Respondent. 

______________________________________________________________________________ 

 

Aaron M. Fales (P72864) 

 

 

 

 

 

Suzanne Larsen (P57017) 

330 Hamilton Row, Ste. 350 

 

 

 

 

City of Marquette 

Birmingham, Michigan 48009 

 

 

 

 

300 W. Baraga Avenue 

(248) 767-9840 

 

 

 

 

 

 

Marquette, Michigan 49855 

Attorney for Petition 

 

 

 

 

 

(906) 225-8563 

 

 

 

 

 

 

 

 

 

slarsen@marquettemi.gov 

 

 

 

 

 

 

 

 

 

Attorney for Respondent 

______________________________________________________________________________ 

 

RESPONSE TO MOTION TO AMEND PETITION TO CONTEST 

2026 ASSESSED AND TAXABLE VALUES 

 

 

NOW COMES Respondent City of Marquette, by and through its attorney, Suzanne C. 

Larsen and for its Response To Motion To Amend Petition To Contest 2026 Assessed and Taxable 

Values and responds as follows: 

 

1. In 2026, Respondent determined the following values: 

 

True Cash Value 

 

Assessed & State Equalized Value 

 

Taxable Value 

$1,082,000 

 

 

$542,000 

 

 

 

 

$355,233 

 

ANSWER: Respondent admits the Assessed Value, State Equalized Value and 

Taxable Value have been determined as indicated for 2026. However, an Assessed 

Value of $542,000 is equivalent to $1,084,000 True Cash Value. 

 

2. 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, 

exceed the amounts 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 permission 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 moves that this Motion to Amend be granted, and Petitioner 

requests that the Tribunal enter and Order reducing the values to the following: 

 

True Cash Value 

 

Assessed & State Equalized Value 

 

Taxable Value 

$400,000 

 

 

$200,000 

 

 

 

 

$200,000 

 

and requiring that Respondent pay to Petitioner the refunds attributable to such reductions, plus 

interest and costs. 

 

ANSWER: Respondent denies the statements made in Paragraph 2 and further 

denies all statements made in subparagraphs (a)-(d) and states that the property’s 

true cash value, assessed and taxable values for 2026 have been accurately assessed. 

 

WHEREFORE, while Respondent does not object to the addition of 2026 tax year to Petitioner’s 

petition; however Respondent respectfully requests this tribunal determine that the True Cash 

Value, Assessed Value and Taxable Values are accurate as assessed and deny Petitioner’s request 

for relief. 

 

 

 

 

 

 

Respectfully Submitted, 

 

Dated: June 19, 2026 

 

 

 Suzanne C. Larsen 

 

 

 

 

 

 

 

Suzanne C. Larsen, attorney for Respondent 

 

 

 

 

 

 

City Attorney, City of Marquette 

 

 

 

 

 

 

300 W. Baraga Avenue 

 

 

 

 

 

 

Marquette, Michigan 49855

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

FLAGSTAR BANK, N.A. 

 

 

Petitioner, 

 

v 

 

 

 

 

 

 

 

 

MTT Docket No. 25-001691 

 

 

 

 

 

 

 

 

 

Parcel No. 0400420 

CITY OF MARQUETTE, 

 

 

Respondent. 

______________________________________________________________________________ 

 

Aaron M. Fales (P72864) 

 

 

 

 

 

Suzanne Larsen (P57017) 

330 Hamilton Row, Ste. 350 

 

 

 

 

City of Marquette 

Birmingham, Michigan 48009 

 

 

 

 

300 W. Baraga Avenue 

(248) 767-9840 

 

 

 

 

 

 

Marquette, Michigan 49855 

Attorney for Petition 

 

 

 

 

 

(906) 225-8563 

 

 

 

 

 

 

 

 

 

slarsen@marquettemi.gov 

 

 

 

 

 

 

 

 

 

Attorney for Respondent 

______________________________________________________________________________ 

 

 

PROOF OF SERVICE 

 

 

The undersigned hereby certifies that on June 22, 2026 a copy of the following documents: 

Response to Motion to Amend Petition to Contest 2026 Assessed and Taxable Values were 

served on: 

 

Aaron M. Fales 

330 Hamilton Row, Ste. 350 

Birmingham, Michigan 48009 

 

by enclosing the same in a properly addressed, sealed envelope, with first class postage fully 

prepaid, and by depositing the envelope in the United States mail. 

 

 

I declare that the statements above are true to the best of my information, knowledge and 

belief. 

 

 

 

Dated: June 22, 2026 

 

 

Suzanne C. Larsen 

 

 

 

 

 

 

 

Suzanne C. Larsen

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