Trillium POS.pdf

Cmg Trillium, LLC, Petitioner Vs. Township Of Clinton, Respondent · 25-002167-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

oO 

MG TRILLIUM LLC, 

Petitioner, 

v. 

MTT Docket # 25-002167 

CLINTON TOWNSHIP, 

Respondent. 

PROOF 

OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

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

>f Petitioner’s Petition on the parties named on the attached list. 

Aaron M. Fales

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

CLINTON TWP. - MACOMB 

40700 ROMEO PLANK ROAD 

CLINTON TWP., MI 48038-2617 

ASSESSOR 

CLINTON TWP 

- MACOMB 

40700 ROMEO PLANK ROAD 

CLINTON TWP., MI 48038-2917 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., STH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

CLINTONDALE COMMUNITY SCHOOLS 

35100 LITTLE MACK AVENUE 

CLINTON TWP., MI 48035-2633 

STATE TREASURER 

MICHIGAN DEPARTVIENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING MT 48927.

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG TRILLIUM, LLC, 

Petitioner, 

MTT Docket #25. 

00 2167( 

Parcel No. 16-11-19-477-005 

CLINTON CHARTER TOWNSHIP, 

Respondent. 

vl 

PETITION 

CMG 

TRILLIUM, 

LLC 

(“Petitioner”), through 

its attorneys, Law Office 

of 

Acron M. Fales, 

P.C., says: 

1. 

Petitioner's principal office address 

is 43900 Garfield 

Rd., Ste. 203, 

Zinfon Twp., MI 48038. 

Petitioner is a party in interest with respect to property 

foxes on real property tax parcel no. 16-11-19-477-005 ("Petitioner's Property"), at 

37399 Garfield, Clinton Twp., Ml 48036. 

2. 

Respondent, Clinfon Township assesses and collects property taxes 

on Petitioner's Property. 

3. 

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

Froperty 

to 

be 

$1,792,055 

and 

assessed 

Petitioner's 

Property 

at 

$2,592,500 

‘sulting 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. 

ier's Property 

is an office 

Building. 

Petitioner believes that 

Petitioner's 

operiy was originally designed to be used for commercial purposes. 

5. 

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

taxable value, and (d) uniformity. 

At this time, Petitioner believes, as 

it relates to taxable value, that 

sre is a dispute relative to the value of a loss. 

he 2025 assessment, including state equalized value and taxable 

lve, 

Imposed 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

llected thereon, 

are invalid and unlawful and operate as a fraud upon the 

(payer for 

the reasons that: 

(a) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

a 

ble value, exceeds the amount permitted by the Michigan Constitution and 

fatutes; 

[®] 

lb) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

«ble 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 

ecualized value, are based upon an erroneous determination of the true cash

(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 

2025 taxable value 

of 

Petitioner's 

Property from 

$1,792,055 

to 

$1,000,000, and reducing 

the 

2025 assessed 

and 

state equalized values 

of 

Petitioner's Property from $2,592,500 to $1,000,000, 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 

NY Ad 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

By: 

Dated: May 29, 2025

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