25-001957 DOC-560 W MITCHELL ST MOB LLC V Petoksy ALT.pdf
Doc-560 W Mitchell St Mob LLC, Petitioner Vs. City Of Petoskey, Respondent · 25-001957-TT
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June 27, 2025 Re: DOC-560 W MITCHELL ST MOB LLC v City of Petoskey MOAHR Docket No.: 25-001957 Dear Chief Clerk: Petitioner hereby serves all parties provided for in Michigan Tax Tribunal Rule 221 with its petition in this matter. Pursuant to the rule, the petition notes the docket number assigned by the tribunal and is served within 45-days of the issuance of the notice of docket number. If you have any questions regarding the enclosed pleading, please do not hesitate to contact our office directly at (313) 230-0104. Respectfully, Sarah R. Belloli Ryan, LLC cc: State of Michigan Treasurer PUBLIC SCHOOLS OF PETOSKEY Emmet County Equalization Director Emmet County Clerk City of Petoskey Assessor City of Petoskey Clerk Enclosures 101 West Big Beaver Suite 945 Troy, Michigan 48084 Tel. 313.230.0104 Fax 313.230.0114 www.ryan.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFARIS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL DOC-560 W MITCHELL ST MOB LLC Petitioner, v MOAHR Docket No.: 25-001957 City of Petoskey Respondent, Proof of Service Joan Kleiner, being duly sworn, deposes and says that on June 27, 2025 , she served a copy of the Petition relative to the above-captioned matter, via first class mail, upon: State of Michigan Treasurer Department of Treasury Treasury Building 430 West Allegan Lansing, MI 48922 PUBLIC SCHOOLS OF PETOSKEY School Board Secretary 1130 Howard Street Petoskey, MI 49770 Emmet County Equalization Director 200 Division St, Suite 180 Petoskey, MI 49770 Emmet County Clerk 200 Division St. Suite 130 Petoskey, MI 49770 and via certified mail, return receipt requested, upon: City of Petoskey Assessor PO Box 25 Rogers City, MI 49779 City of Petoskey Clerk 101 E. Lake St. Petoskey, MI 49770 With proper postage affixed thereto. __________________________ Joan Kleiner June 27, 2025
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GRETCHEN WHITMER GOVERNOR STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS Lansing MARLON I. BROWN, DPA DIRECTOR DOC-560 W MITCHELL ST MOB LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. City of Petoskey , Respondent. ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 52-19-06-199-001 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) 2. The property identified above is X real personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? __Yes ___No. (If no, separate Petitions are required for each non- contiguous parcel.) 4. Are all of the parcels of personal property located on a parcel of real property under appeal? Yes No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): 6. The property identified above is classified as 210 COMMERCIAL- BUILDING ON LEASED LAND 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s March July December Board of Review. X NA 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 25-001957
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MTT Docket No. Page 2 of 4 8. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): 9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): 10. The property or properties at issue are located in Emmet County. The property or properties’ address is: 560 W MITCHELL ST 11. The assessment or assessments at issue were established by the (applicable local governmental unit): City of Petoskey 12. Petitioner’s legal residence or principal office address is: One Seagate, Suite 1500, Toledo, OH 43604 13. This appeal involves issues relating to the (check all that are applicable): X the property or properties’ true cash and taxable values the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or loss? Yes No uniformity of the property or properties’ assessment the property or the properties’ exemption from ad valorem taxation under MCL 14. The tax year(s) at issue are: 2025 25-001957
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MTT Docket No. Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary):NA 16. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 $46,824,000.00 $23,412,000 $18,403,350 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 $29,665,600 $14,832,800 $14,832,800 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 $17,158,400 $8,579,200.00 $3,570,550.00 19. Petitioner requests the following relief (attach additional page if necessary): 20. List the separate and specific facts upon which Petitioner relies to support the relief Petitioner relies on the following facts to support the relief requested: The subject assessments imposed on the subject property and the taxes to be levied and collected are invalid for the reason that: a. The equalized assessment thus imposed on the subject property is more than 50% of its true cash value in violation of the applicable statutory and constitutional limitations. b. The assessment is unlawful and is based upon the application of wrong principles and thereby operates as a fraud upon the taxpayer. Petitioner respectfully requests the Tax Tribunal hear this case and enter an order reducing the 2025 True Cash, State Equalized and Taxable Values and direct Respondent to refund to Petitioner any excess taxes, fees and penalties paid, plus interest and costs. 25-001957
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MTT Docket No. 25-001957 Page 4 of 4 Signature of Petitioner’s Authorized Representative or, if none, Petitioner: Email Address: Sarah.Belloli@Ryan.com Mailing Address: Sarah R. Belloli 101 West Big Beaver, Suite 945 Troy, Michigan, 48084 Telephone Number: (313)230-0104 Date: 5/30/2025 CC: Joan.Kleiner@ryan.com CC: Rob.Unkle@ryan.com