Charwood POS.pdf

Charwood North LLC, Petitioner Vs. City Of Warren, Respondent · 25-002168-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CHARWOOD NORTH LLC, 

Petitioner, 

2 

MTT Docket # 25-002168 

CITY OF WARREN, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

nM. Fales, being duly sworn, deposes and says that on September 26, 2025 he served a 

of Patitionzr’s Petition on the parties named on the attached list. 

Aaron M. Fales

BY CERTIFIED UNITED STATES MAIL. RETURN RECEIPT REQUESTED:

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Charwood North LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

A" 

MTT Docket No.: 25-002168 

City Of Warren, 

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 205.735a, 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: August 13, 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 

CHARWOOD NORTH, LLC, 

Petitioner, 

5 

MTT Docket #285 - OD2 (6d 

Parcel No. 

12-13-13-351-054 & 

CITY OF WARREN, 

12-13-13-351-055 

Respondent. 

B 

/ 

PETITION 

CHARWOOD NORTH, LLC (“Petitioner”), through 

its attorneys, Law Office 

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 

‘axes on contiguous real property tax parcel nos. 12-13-13-351-054 and 12-13-13- 

351-055 ("Petitioner's Property"), at 27472 & 27550 Schoenherr, respectively. 

2, 

Respondent, City of Warren, assesses and collects property taxes on 

Petitioner's Property. 

3, 

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

Property 

fo 

be 

$1,315,590 

and 

assessed 

Petitioner's 

Property 

at 

$1,315,590 

resuliing in a state equalized value of the same amount based on the tenative 

equalization 

factor for parcel 

12-13-13-351-054 and determined 

the taxable 

Jue of Petitioner's Property to be $393,590 and assessed Petitioner's Property at

itioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

Property 

is an office 

Building. 

Petitioner believes that Petitioner's 

perry was originally designed to be used for commercial purposes. 

his matter involves issues relating to: (a) valuation, (b) assessment, 

[3] 

e 

value, and (d) uniformity. 

Al this time, Petitioner believes, as 

it relates to taxable value, that 

> 

is a dispute relative to the value of a loss. 

‘he 2025 assessments, including state equalized value and taxable 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

ected 

thereon, are invalid and unlawful and operate as a fraud upon the 

r the reasons that: 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

oxpayer fo 

(a) 

exceeds the amount permitted by the Michigan Constitution and 

raxable value, 

plicable statutes; 

(b) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

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 

ed valve, are based upon an erroneous determination of the true cash 

(~)

clue of that portion of Petitioner's Property that is taxable under Michigan law, 

cl are based upon the application of wrong principles; and, 

'd) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

) 

y 

[0] 

volue, 

and 

the 

mode 

of 

assessment 

adopted 

by 

Respondent, 

Sscriminate 

against Petitioner and deny Petitioner 

its constitutional 

rights 

to 

Vformity, 

equal protection and due process of law. 

WHEREFORE, 

Petitioner requests 

that 

the 

Tax 

Tribunal 

enter 

an 

Order 

ducing the 2025 taxable value of Petitioner's Property identified as Parcel 12- 

54 

from $1,315,590 to $1,000,000, and reducing the 2025 assessed 

qualized values of Petitioner's Property from $1,315,590 to $1,000,000 

=dlucing The 2025 taxable value of Petitioner's Property identified as Parcel 

-15-13-351-035 from $393,590 to $200,000, and reducing the 2025 assessed and 

= 

equalized values of Petitioner's Property from $393,590 to $200,000, and 

‘equring 

Respondent 

to 

pay 

Petitioner 

the 

refunds 

attributable 

to 

such 

uctions, plus interest and costs.

Respectfully submitted, 

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

Attorney for Petitioner 

Ss 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

By: 

Dated: May 29, 2025

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