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Petition 2026 - PMG JSJ Muskegon (RP).pdf

Pmg Jsj Partners LLC Petitioner Vs. City Of Muskegon Respondent · 26-001004-TT

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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.

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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

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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

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