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26 - Shelby POS.pdf

Jbt Shelby LLC Petitioner Vs. Township Of Shelby Respondent · 26-001528-TT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

v. 

MTT Docket # 26-001528 

TOWNSHIP OF SHELBY, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

} 

} ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on September IS 

, 2026 he served a 

copy of Petitioner's Petition on the parties named on the attached list. 

el 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

SHELBY TWP. - MACOMB 

52700 VAN DYKE 

SHELBY TWP., MI 48316 

ASSESSOR 

SHELBY TWP. - MACOMB 

52700 VAN DYKE 

SHELBY TWP., MI 48316 

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., 8TH FLOOR 

- 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

UTICA COMMUNITY SCHOOLS 

11303 GREENDALE DRIVE 

STERLING HEIGHTS, MI 48312-2925 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, Mi 48922

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STATE OF MICHIGAN 

GRETGHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

JBT Shelby LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001528 

Township Of Shelby, 

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 205.7354, 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), “[{lhe 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 14, 2026 

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

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

MTT Docket #26- 001528 

vs. 

Parcel No. 23-07-36-302-006 

SHELBY TOWNSHIP, 

Respondent. 

/ 

PETITION 

JBT SHELBY LLC ("Petitioner"}, through its attorneys, Law Office of Aaron M. 

Fales, P.C., says: 

I. 

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 

faxes on real property tax parcel no. 23-07-36-302-006 ("Petitioner's Property"), at 

45660 Schoenherr, Shelby Twp., Ml. 

2. 

Respondent, Shelby Township assesses and collects property taxes 

on Petitioner's Property. 

3. 

In 2026, Respondent determined the taxable value of Petitioner's 

Property fo be $374,300 and assessed Petitioner's Property at $374,300 resulting in 

a state equalized value of the same amount based on the tenative equalization

Page 5

Petitioner's 

Property 

was 

originally 

designed 

to 

be 

used 

for 

commercial 

purposes. 

5. 

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

(c) taxable value, and {d} uniformity. 

6. 

At this time, Petitioner believes, as 

it relates to taxable value, that 

there is a dispute relative fo the value of a loss. 

7. 

The 2026 assessment, including state equalized value and taxable 

value, 

imposed 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

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

taxpayer for the reasons that: 

(a) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

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

applicable statutes; 

(lb) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable 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 

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

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

Page 6

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 

2026 

taxable 

value 

of 

Petitioner's 

Property 

from 

$374,300 

to 

$125,000, 

and 

reducing 

the 

2026 

assessed 

and 

state 

equdlized 

values 

of 

Petitioner's Property from $374,300 to $125,000, 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 

Pd 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, Mi 48009 

(248) 767-9840 

By: 

Dated: May 27, 2026

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