CMG - Washington POS.pdf

Cmg Pcp Associates LLC, Petitioner Vs. Township Of Washington, Respondent · 25-001813-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES LLC, 

Petitioner, 

V. 

MTT Docket # 25-001813 

TOWNSHIP OF WASHINGTON, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

3/7 

a gll 

Aaron M. Fales, being duly sworn, deposes and says that on 

y 

2025 he served a copy of Petitioner's Petition on the parties named on the attached list. 

er 

iil 

Aaron M. Fales

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

Washington Township Assessor 

57900 Van Dyke 

Washington, MI 48094 

Washington Township Clerk 

57900 Van Dyke 

Washington, MI 48094 

AND BY FIRST CLASS UNITED STATES MAIL: 

Macomb County Equalization Director 

10 N Main, 3" Floor 

Mt. Clemens, MI 48043 

Macomb County Clerk 

1% Floor — Court Bldg. 

40 N Main Street 

Mt. Clemens, MI 48043 

Romeo Community Schools 

Secretary of the School Board 

316 N. Main St. 

Romeo, MI 48065 

State Treasurer 

Michigan Department of Treasury 

Treasury Building 

430 W. Allegan St. 

Lansing, MI 48922

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

CMG PCP Associates LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-001813 

Township Of Washington, 

Respondent. 

NOTICE OF DOCKET NUMBER 

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.7354, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case. 

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default. 

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunals rules. 

By: __ Tribunal Clerk 

Entered: July 24, 2025 

PROOF OF SERVICE 

| certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, 

if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

By: Tribunal Clerk 

MICHIGAN TAX TRIBUNAL 

- 611 W. OTTAWA ST., LANSING, MI 48933 

- 517-335-9760 

PO BOX 30232, LANSING, MI 48909 

- Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

MTT Docket #25. 001813 

Vs. 

Parcel No. 24-04-14-100-034 

WASHINGON TOWNSHIP, 

Respondent. 

/ 

PETITION 

CMG PCP ASSOCIATES, LLC (“Petitioner”), through its attorneys, Law Office 

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

1 

Petitioner's principal office address 

is 43900 Garfield 

Rd., Ste. 203, 

Clinton Twp., MI 48038. 

Petitioner 

is a party in interest with respect to property 

taxes on real property tax parcel no. 24-04-14-100-034 ("Petitioner's Property"), at 

64582 Van Dyke Ave., Washington, MI. 

2: 

Respondent, Washington Township assesses and collects property 

taxes on Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $763,221 and assessed Petitioner's Property at $1,035,300 resulting 

in 

a 

state 

equalized 

value 

of 

the same 

amount 

based 

on 

the 

tenative 

equalization factor.

4. 

Petitioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

Petitioner's Property 

is an office Building. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for 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 2025 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 

toxable 

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 

2025 

taxable 

value 

of 

Petitioners 

Property from 

$763,221 

to 

$550,000, 

and 

reducing 

the 

2025 

assessed 

and 

state 

equalized 

values 

of 

Petitioner's Property from $1,035,300 to $550,000, and requiring Respondent to 

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

Respectfully submitted, 

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

Attorney for Petitioner 

od 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

Dated: May 29, 2025

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