2026 Petition - Gathergrounds.pdf
Gathergrounds Michigan LLC Petitioner Vs. Township Of Leoni Respondent · 26-000996-TT
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Page 1
1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS GATHERGROUNDS MICHIGAN LLC, Petitioner, v TOWNSHIP OF LEONI, Respondent. MICHIGAN TAX TRIBUNAL Docket No. 26-____________ Parcel No.: 000-04-35-400-001-02, and additional parcels _____________________________________________________________________________/ PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use 000-04-35-400-001-02 7800 Cutler Rd. Commercial Campground 000-04-35-400-001-13 Roarkeys Ln. Agriculture-Vac Vacant 2. ☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: ☐ March, ☐ July, ☐ December Board of Review. 3. Respondent, identified above, assesses and collects taxes on the subject property. 4. The subject property is located in the County of Jackson and school district of East Jackson Community Schools. 5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 6. The Petitioner’s principal office/legal residence address is: 1883 W. Royal Hunte Dr., Suite 200A, Cedar City, UT 84720.
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2 7. This appeal involves issues related to: ☒ the subject property’s true cash and taxable values ☐ the subject property’s taxable value only there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No ☐ uniformity of the subject property’s assessment ☐ the subject property’s exemption from ad valorem taxation under MCL ______ 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values 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 assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection and due process of law.
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3 Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable to the reductions, with interest, as provided by the Tax Tribunal Act. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 Dated: May 15, 2026 lhallahan@hallahanlaw.com Filing Fee: $450
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4 ATTACHMENT TO PETITION (Subject Property) VALUES Respondent’s Board of Review -and- Petitioner’s Contention Parcel Number Respondent Petitioner TCV SEV TV TCV SEV TV 000-04-35-400-001-02 985,164 492,582 492,582 350,000 175,000 175,000 000-04-35-400-001-13 482,030 241,015 241,015 100,000 50,000 50,000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Totals 1,467,194 733,597 733,597 450,000 225,000 225,000 VALUES IN DISPUTE Parcel Number TCV SEV TV 000-04-35-400-001-02 635,164 317,582 317,582 000-04-35-400-001-13 382,030 191,015 191,015 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Totals 1,017,194 508,597 508,597
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JER Department of Treasury 818 . 11-12) Petition to Board of Review 03/05/2026 09:03 AM L-4035 This form Is Issued under the authority of P.A. 206 of 1893, as amended. Filing is voluntary, however you may not appeal to the Michigan Tax Tribunal or the State Tax Commission unless you first protest to the Board of Review TO BE COMPLETED BY OWNER OR OWNER'S AGENT Owners Name (Please Print or Type) GATHERGROUNDS MICHIGAN LLC ‘Petitioner's Name (If Other than Owner. Please Print or Type) Mathew Barker, President | Township or City LEONI TOWNSHIP County JACKSON the following described property: The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified agricultural property exemption of ‘Property (dentified (Parcel code required. Property address & legal description optional) | 000-04-35-400-001-02 COM AT THE E 1/4 POST OF SEC 35 TH S00°32'24E 660 FT ALG E LN THW 1737.25 FT FOR POB TH CONT W625 FT TH S 455 FT TH E 300 FT TH S 625 FT TH E 260 FT TH $ 480 FT TH E 180 FT TH N 200 FT TH E 845 FT THN 350 FT TH W 242 FT TH N 1010 FT THW 748 FT TO BEG. SEC 35 T1S RIE 37.54A SUBJECT TO A 66 7800 CUTLER RD FT WIDE EASEMENT FOR INGRESS & EGRESS Protested tem [XI] Assessed Value [Xd Tentative Taxable Value [ Classification 0 Qualifed Agricultural Property Exemption 1. PROTEST OF ASSESSMENT (Complete this section for a protest of assessed value and/or tentative taxable value) [Assassed Amount er's Estimated True Cash Value ‘entative Taxable Value 492,582 ,000 cash valus / $112,500 Taxable Value 492,582 2026 2. PROTEST OF CLASSIFICATION (Complete this section for a request to change the classification. The Board of Review must make their decision regarding classification in accordance with section 211.34c of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular classification has on that property's status as a homeowner's principal residence or qualified agricutural property.) Classification of property on this year's assessment roll: 201 Classification should be: (Please check one of the following) . OO Agricuttural O Industrial CITimber Cutover [utility (Personal Property Only) El Commercial [J Residential - COObevelopmental "3. PROTEST OF EXEMPTION FOR QUALIFIED AGRICULTURAL PROPERTY (If the assessor has denied or changed the percentage of the exemption from the 18 mills of local schocl aperating tax for qualified agricultural property, the owner may appeal this action to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT UPON THE EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.) Percent qualified agricultural exemption granted by assessor: (Enter 0 if exemption is denied) | Percent qualified agricultural exemption requested by Owner: (Enter 100 f full exemption requested) 4. REASON FOR PROTEST State reason(s) for protest of assessed value and/or the tentative taxable value and/or classification and/or qualified agricultural property exemption. See the attached valuation assessment. Per our conversations it does not appear that there was an accurate valuation performed based on the formulas that are widely accepted for our class of commercial real estate. CERTIFICATION Signature Date Broke. 03/05/2026 Address Phone Number ty Address: 7800 Cutier Road, Munith, MI, 49259 989-715-4205 Malling Address: 1883 W Royal Hunie Drive, Suite 200A Cedar City, UT 84720 www.michigan.gov/treasury
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A
y
Department of Treasury
orm 618, Page 2
FOR BOARD OF REVIEW USE ONLY
INSTRUCTIONS: Incorporate a copy of this form and the assigned number in the Board of Review minutes.
Petition Number
Code
000-04-35-400-001-02
1. ASSESSED VALUE
Disposition by Board of Review. The Board of Review must state the reason for its action below.
Xl
Denied
O
Assessed Value Changed From:
a
o:
|
]
Record of Vote - Board or three member committee of board
jp
i
.
£5
5%
g/d
Chairperson: [Aves
,
No BEE
Member:
ves
[J no
-
Member:
Xi ves
[nN
Reason for Board Action:
Assessment determi ied Cai and
qo ele
If you disagree with the decision of the Board of Review regarding tentative assessed valus, you may appeal that decision by filing a petition
with the Michigan
Tax Tribunal at
P.0.Box 30232, Lansing, Ml. 48909. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, Industrial Personal and Utility Personal
may be
appealed by May 31. Agricultural Real, Residential Real, Timber - Cut Over Real, and Agricultural Personal Property may be appealed by July 31. The petition must be filed
lon a Michigan Tax Tribunal for or a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at ‘www.michigan.govitaxtrib.
2. TENTATIVE TAXABLE VALUE
Disposition by Beard of Review. The Board of Review must state the reason for its action below.
[X
Denied
[J
Tentative Taxable Value Changed From:
492,582
To;
Record of Vote - Board or three member committee of board.
Bs +
WW
A
Chairperson: [}] ves
[] No ==
=
—
Member:
KJ ves
[7] No 3%
Member: X] ves
[7] Nno-LreT
Reason for Board Action:
{
Assessment determined Gain
and
&U 1hable
If you disagree with the decision of the Board of Review regarding tentative taxable value, you may appeal that decision by filing a petition with the Michigan Tax Tribunal at
‘Commercial Personal, |
P.0.Box 30232, Lansing, Mi. 48909. Commercial Real, Industrial Real, Developmental Real,
Industrial Personal and Utitity Personal Property may be
pealed by May 31. Agricultural Real, Residential Real, Timber - Cut Over Real, and Agricultural Personal Property may
be appealed by July 31. The petition must
be filed
ap)
on a Michigan Tax Tribunal for or a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at 'www.michigan.gov/taxtrib.
3. CLASSIFICATION
Disposition by Board of Review. The Board of Review must state the reason for its action below.
[Xd
Denied
[]
Classification Changed From:
201
To:
Record of Vote - Board or three member committee of board.
Re Ar
,
O No-fze-
Member: [Hl ves
[1 No Rms
Member:
[I ves
[1 no iiss
Uass
Ts
already 20].
9 classification, appeal is made by sanding Form 2167 to the State Tax Commission, P.O. Box 30471, Lansing, Mi. 48809 by June 30.
Chairperson: Fa YES
Reason for Board Action:
tf you
with the
of the Board of
9:
4. QUALIFIED AGRICULTURAL PROPERTY EXEMPTION
Disposition by Board of Review. The Board of Review must state the reason for its action below.
O
Exemption Request Denied
O
Exemption percent modified from
% To:
%
Record of Vote - Board or three member committee of beard.
Chairperson: [J yes
[J No
Member:
[J ves
[J] no
Member:
[] ves
[] no.
Initials.
Initials
Initials |
Reason for Board Action:
If you disagree with the decision of the Board of Review regarding tentative taxablo value, you must appeal that decision by filing a petition with the Michigan Tax Tribunal, P.O, Bax 30232, Lansing, Mi.
48509 by July 31. The petition must be filed on a Michigan Tax Tribunal form of a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan govitaxtrib.
5. Adjournment
Date of Final adjoumment of Board of Review
MAR
1 12026
EET [re ong
"MAR 10 2006
&Page 7
< Mi Department of Treasury 03/05/2026 09:04 AM 818 (Rev. 11-12) L-4035 Petition to Board of Review This form is Issued under the authority of P.A. 206 of 1893, as amended. Filing is voluntary, however you may not appeal to the Michigan Tax Tribunal or the State Tax Commission unless you first protest to the Board of Review TO BE COMPLETED BY OWNER OR OWNER'S AGENT [Owners Name (Please Print or Type) Ti ’s Name ( than Owner. Please Print or Type) GATHERGROUNDS MICHIGAN LLC Mathew Barker, Presidant | Township or City County LEONI TOWNSHIP JACKSON The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified agricultural property exemption of tho following described property: Property Identified (Parcal code required. Property address & legal description optional) : - N0O°G0'00°E 480 FT TH N90°00°'00°W 280 FT TH N00°00'00°E 625 FT TH NS0°00'00°W 300 FT TH N00°00'00°E 000-04-35-400-001-13 1161.21 FT TO E&W % LN OF SEC 35 TH CONT N00°00'00°E 351.48 TO CL OF AN UNNAMED DRAIN TH N50°04'09°W 228.81 FT ALG CL OF SD DRAIN TH N88°52'49"W 135.93 FT TO N&S % LINE OF SEC 35 TH CONT N88°52'49°W 927.17 FT TH S00°43'47°E 495.25 FT TO E&W % LN OF SD SEC TH S00°46'05°E 886.11 ROA SIN FT TH $18°25'08°E 433.24 FT TH N84°30'22°F 397.32 FT TH S03°49'08°E 1319.53 FTTOAPTLYING 30 FTN Protested Item [x] Assessed Value [El Tentative Taxable Value [ Classification 0 Qualifed Agricultural Property Exemption 1. PROTEST OF ASSESSMENT (Complete this section for a protest of assessed value and/or tentative taxable value) [ASs5886d Amount Gwners Estimated True Cash Vale ‘eniative Taxable Value ear 241,015 225k Cash Value / $112,500 Taxable Value 241,015 2026 2. PROTEST OF CLASSIFICATION (Complete this section for a request to change the classification. The Board of Review must make thelr decision regarding classification in accordance with section 211.34c of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular classification has on that property's status as a hameownar's principal residence or qualified agricultural property.) [Classtiication of property on this year's assessment roll: 102 Classification should be: (Please check one of the following) X Agricultural [O Industrial OI Timber Cutover Clutility (Personal Property Only) [0 Commercial [J Residential [Ibevelopmental 3. PROTEST OF EXEMPTION FOR QUALIFIED AGRICULTURAL PROPERTY (If the assessor has denied or changed the percentage of the exemption from the 18 mills of local school operating tax for qualified agricultural property, the owner may appeal this action to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT UPON THE EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.) Percent qualified agricuftural exemption granted by assessor: (Enter 0 if exemption is denied) | Percent qualified agricultural exemption requested by Owner: (Enter 100 if full exemption requested) 4. REASON FOR PROTEST State reason(s) for protest of assessed value and/or the tentative taxable value and/or classification and/or qualified agricuftural property exemption. See the attached valuation assessment. Per cur conversations it does not appear that there was an accurate valuation performed based on the formulas that are widely accepted for our class of commercial real estate. CERTIFICATION Signature Date Apt Boke 03/05/2026 Address Phone Number res Ta Boyal asks Dive: Site 300A, Cedar City, UT 84720 989-715-4295 www.michigan.gov/treasury
Page 8
PE a —_ . Department of Treasury Form 618, Page 2 / FOR BOARD OF REVIEW USE ONLY ! INSTRUCTIONS: Incorporate a copy of this form and the assigned number in the Board of Review minutes. Potton Number Parcel Code [® 000-04-35-400-001-13 1. ASSESSED VALUE Disposition by Board of Review. The Board of Review must state the reason for its action below. Denied O Assessed Value Changed From: [ 24 1,0 15 Tro: L ] Record of Vote - Board or three member committee of board Chairperson: fflves [J no 8s Tees Member: Kl ves [Ono Kvp Member: PX ves [1 wn Reason for Board Action: Assessment determined fare and © witeHe . If you disagree with the decision of the Board of Review regarding tentative assessad valus, you may appeal that decision by of a petition with the Michigan Tax Tribunal at P.0.Box 30232, Lansing, Mi. 48909, Commercial Real, Industrial Real, Developmental Real, Commercial Personal, Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Real, Residential Real, Timber - Cut Over Real, and Agricultural Personal Property may be appealed by July 31. The petition must be filed lon a Michigan Tax Tribunal for or a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan.gov/taxtrib. 2. TENTATIVE TAXABLE VALUE Disposition by Board of Review. The Board of Review must state the reason for its action below. ™ Denied [7] Tentative Taxable Value Changed From: 241,015 10; Record of Vote Board or three member committee of board. Chairperson: son: [J] » Yes [1] WN no BEX [7] No Kye Member: Pores 1 wClal— Rees meth Sern fain and ey Jibabte If you disagree with the decision of the Board of Review regarding 8 ontattee waxablo valuo, you may appeal hat decision by ng a petition with the Michigan Tax Tribunal at P.0.Box 30232, Lansing, Mi. 48809. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Rea, Residential Real, Timber - Cut Over Real, and Agricultural Personal Property may be appealed by July 31. The petition must be filed on a Michigan Tax Tribunal for or a form approved by the Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan.gov/taxirib. 3. CLASSIFICATION Disposition by Board of Review. The Board of Review must state the reason for its action below. x Denied O Classification Changed From: 102 To: Record of Vote - Beard or three member committee of board. oo RE 1- ; - Chairperson: [R.ves [1 nome" Member: [Mf ves [ Noma’ Member: YES NO Reason for Board Action: Property | 1s already [02 if you disagro with the decision of the Board of Review regarding classification, IRA ILA Calo Box 30471, Lansing, ML. 48909 by June 30. 4. QUALIFIED AGRICULTURAL PROPERTY EXEMPTION Disposition by Board of Review. The Board of Review must state the reason for its action below. 0 Exemption Request Denied O Exemption percent modified from % To: % Record of Vote - Board or three member committee of board. Chairperson: [J yes [J No ——— Member: Oves [wo Reason for Board Action: ~latials of the Board of regarding tentative taxabio value, you must appeal that decision by fing a petition with the Michigan Tex Tribunal, P.O, Box 30232, Lansing, Ml. pro torr Th prion mtb io on Mp Foe Tabet oro ss Br Sense Pon wih ho Miia Te Tur, 0, Box 30232 Laing 5. Adjournment Date of Final adjcumment of Board of Review MAR 1 12026 Member: [] YEs [] no. MAR 1 0 2026