Petition 2026 - PMG JSJ Muskegon (RP).pdf
Pmg Jsj Partners LLC Petitioner Vs. City Of Muskegon Respondent · 26-001004-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
26-0014
75539050.1
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
PMG JSJ Partners LLC,
Petitioner,
v
City of Muskegon,
Respondent.
MTT Docket No. ________
Parcel No. 24-230-003-0008-00
Jackie J. Cook (P68781)
Honigman LLP
Attorneys for Petitioner
2290 First National Building
660 Woodward Avenue
Detroit, MI 48226-3506
(313) 465-7270
jcook@honigman.com
Petition
PMG JSJ Partners LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says:
1.
Petitioner's principal office address is 124 Tustin Avenue, Suite 200, Newport
Beach, CA 92663.
2.
The subject real property, parcel number 24-230-003-0008-00, is located at 1823
Commerce St., Muskegon, MI, in Muskegon County ("Petitioner's Property").
3.
Respondent, City of Muskegon, assesses and collects property taxes on Petitioner's
Property.
4.
In 2026, Respondent’s Board of Review set the taxable value of Petitioner's
Property to be $1,530,400 and assessed Petitioner's Property at $1,530,400.Page 2
2 75539050.1 5. Respondent’s board of review assessing Petitioner’s Property will result in a state equalized value in the same amount based upon the tentative equalization factor. 6. Petitioner's Property is misclassified as commercial real as the Property is used for agricultural operations and should be classified agricultural. 7. Petitioner's Property is presently used or available for use for agricultural purposes. 8. Petitioner believes that Petitioner's Property was originally designed to be used for agricultural purposes. 9. This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 10. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 11. No board of review protest was required for Petitioner’s Property. 12. The 2026 assessment – including the state equalized and taxable values – imposed on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, because they (a) Exceed amounts permitted by the Michigan Constitution and applicable statutes; (b) Are calculated at or derived from higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; (c) Are based on the application of wrong principles and an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, if any; and
Page 3
3 75539050.1 (d) 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: (i) reducing the 2026 taxable value, assessed value, and state equalized value of Petitioner's Property from $1,530,400 to $700,000; (ii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is entitled. Dated: May 15, 2026 Respectfully submitted, Honigman LLP Attorneys for Petitioner By: Jackie J. Cook (P68781) 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7270 jcook@honigman.com