26-000647 Breif MTT.pdf

Mike Ghani Petitioner V City Of Inkster Respondent · 26-000647-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATION HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

CAPITAL HILL INVESTMENTS, LLC 

MTT Docket No: 26-000647 

Petitioner, 

Vv. 

CITY OF INKSTER 

Respondent 

/ 

JEAHAD KADAF (P82492) 

Marwan Abdullah 

Attorneys for the Petitioner 

26215 Trowbridge 

22174 Michigan Ave 

Inkster MI 48141 

Dearborn MI 48124 

City of Inkster Assessor 

(313) 290-0000 

jkadafi@kadaflaw.com 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

WAYNE COUNTY 

) 

On JULY 24, 2026, 

I served a copy of the Petitioner Brief, by placing the envelope with 

sufficient postage in an official U.S. postal receptable located in the City of Dearborn, Michigan. 

/s/ Jeahad Kadaf 

Jeahad Kadaf

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATION HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

CAPITAL HILL INVESTMENTS, LLC 

MTT Docket No: 26-000647 

Petitioner, 

v. 

CITY OF INKSTER 

Respondent 

/ 

JEAHAD KADAF (P82492) 

Marwan Abdullah 

Attorneys for the Petitioner 

26215 Trowbridge 

22174 Michigan Ave 

Inkster MI 48141 

Dearborn MI 48124 

City of Inkster Assessor 

(313) 290-0000 

jkadafi@kadaflaw.com 

PETITIONER’S RESPONSE TO RESPONDENTS ANSWER & 

PETITIONERS FACTUAL BASIS FOR APPEAL 

PETITIONER’S CHALLENGE TO RESPONDENT’S ANSWER 

PETITIONER’S ARGUMENT 

3254 Moore, Inkster MI 48141 

Tax ID# 

44010060274000 

BACKGROUND 

Petitioner owns the property commonly known as 3254 Moore, Inkster MI 48141. The 

property was purchased under a trust, whereas the beneficiary of the trust is Capital Hill 

Investments, LLC. Thereafter, the trustee settled the trust and deeded the property to the 

beneficiary. The important factor is that the trustee and the beneficiary are 100% owned by the 

same person, Mike Ghani. Here is a history of ownership with a timeline below:

oe 

12/1/2022 

Petitioner purchased the property 3254 Moore Inkster Trust also being 

“Capital Hill Investments” the beneficiary of the trust. 

eo 

7/3/2024 

Petitioner moved the property to Capital Hill Investments LLC, who is the 

beneficiary of the trust and same owners as the trustee and the LLC. 

(EXHIBIT A) 

The City of Inkster treated the transfer as an uncapping under the statute as a sale. The 

Petitioner provided the City Assessor all the relevant information that meets the MCL 

211.27(a), and further sent it by Certified Mail return receipt, USPS # 9589 0710 5270 1257 

273145, in an attempt to assist the assessor in rectifying the issue. (EXHIBIT B). 

Although the Petitioner met the burden of proof, the City Assessor uncapped the property 

taxable value. Additionally, the City Assessor argument is that we are petitioning the wrong 

year, yet if you look at the notice sent by the assessor of their decision, it has the wrong 

address of the Petitioner. (EXHIBIT C). 

LAW AND ARGUMENT 

MCL 

211.27a(7)(m) is a provision in Michigan's General Property Tax Act that 

excludes specific corporate changes from triggering a property tax "uncapping” event. 

Specifically, it states that a direct or indirect transfer of real property or ownership 

interests resulting from a transaction qualifying as a tax-free reorganization under 

section 368 of the Internal Revenue Code does not constitute a "transfer of ownership”. 

In TRJ & E Properties, LLC v. City of Lansing, 323 Mich App 664; 919 NW2d 795 

(2018), the Michigan Court of Appeals interpreting the "commonly controlled" exception to 

Michigan's property tax "uncapping" rules under the General Property Tax Act (GPTA). The 

case is significant because it rejected a rigid administrative definition of common control and 

instead focused on who actually possessed the power to control the entities involved. 

The decision established that common control is a functional concept rather than a 

fixed ownership percentage. The court looked to whether the same persons possessed the 

practical ability to control each entity, recognizing that different organizations may require

different voting thresholds. For example, an entity requiring a supermajority might require a 

higher level of common ownership to establish control than one governed by a simple majority. 

The court held that there is an exemption when the transfer is between “commonly 

controlled” entities. 

Here, it is the same circumstances, the transfer is not only between commonly controlled 

entities and a common denominator of ownership, but the Beneficiary of the trust is the entity. 

The trust is a legal entity as well as the single member LLC, and the same individual is effective 

control and ownership, notwithstanding the it was deeded from the trust to the beneficiary. 

Therefore, pursuant to the MCL 211.27a(7)(m) and case law, this DOES NOT trigger uncapping 

of the taxable value under Michigan Law. 

In Anderson v. Chocolay Township (MTTT Docket No. 433005), the Tribunal treated a 

conveyance from a trust, the Tribunal ruled it was not a transfer and exempt under MCL 

211.27a(7)(m). There is no other person(s) involved in the transfer, still the same commonly 

controlled and ownership. 

Again in Shvartsman (MTT Docket Nos. 449484, 449485, 449532, 449533, 449534), Revenue 

Administrative Bulletin (RAB) 1989-48 recognizes that a sole proprietor can be considered part 

of a commonly controlled group. Evidenced in the trust, the same as the beneficiary. 

COURT POWERS TO ADJUST PRIOR YEARS 

In uncapping cases under MCL 211.27a, argument that correcting the year of 

transfer necessarily requires correcting every subsequent year's taxable value because each 

year's taxable value is derived from the prior year's taxable value. 

If the tribunal determines the uncapping was in error, the MTT has full authority to go 

back and amend prior years. These inherent powers with the MTT are to correct errors, those of

which are impacted by prior years. The MTT in order to correct the current tax years, must go 

back and cure the error that created the issue before this tribunal. 

The Michigan Supreme Court has consistently held that The Tax Tribunal does have 

the authority to reduce an unconstitutional previous increase in taxable value for purposes of 

adjusting a taxable value that was timely challenged in a subsequent year. 

"Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers 

and duties as those assigned to a March board of review..., including the duty to adjust erroneous 

taxable values to bring the current tax rolls into compliance with the GPTA.". 

In, Toll Northville Limited Partnership v. Northville Township. The Supreme Court 

stated: The Tax Tribunal has the same powers as the March Board of Review and may adjust 

previously entered erroneous taxable values for purposes of bringing the current tax roll into 

compliance with the GPTA. The Court emphasized that correcting an earlier year's value 

does not reopen that year's tax liability. Instead, the earlier value is corrected because it is the 

mathematical basis for the current year's taxable value. 

In, Mikelonis v. Township of Alabaster 313 Mich App 679 (2015), earlier years were 

addressed by the court as erroneous uncapping, therefore granting powers to make subsequent 

adjustments. Similarly here, the MTT has authority to address prior year error in order to adjust 

the subsequent years and correct the initial issue. 

Michigan Properties, LLC v. Meridian Township (PDF) Page 20 (491 Mich at 537). The Court 

explains the core issue: "The failure to adjust the taxable value in the year immediately

following the transfer produced an erroneous taxable value because the taxable value was 

not in compliance with the GPTA." 

Pages 24-26 (491 Mich at 541-543), ID. 

Here the Court explains why correcting a prior year's taxable value does not reopen 

prior tax years."..may correct the taxable value in a subsequent year in order to bring 

the current taxable value into compliance with the GPTA. 

The Court states: 

"Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers and 

duties as those assigned to a March board of review..." 

the Court continues: 

"...the Tax Tribunal has the authority to reduce an unconstitutional previous increase in 

taxable value for purposes of adjusting a taxable value that was timely challenged in a 

subsequent year. 

CONCLUSION 

The facts are clear and concise that the “Trust” had Capital Hill Investments LLC as the 

trustee. The Trust settlor who is also the same as the Single Member of Capital Investments 

LLC, deeded the property back to the beneficiary, as the same single person with common 

control. 

This same analysis as can be reviewed in this brief has been upheld by the Michigan 

Court of Appeals and this very Michigan Tax Tribunal. The exemption under MCL 

211.27(a)7(m) and as designed by the Michigan Legislature, therefore the City of Inkster 

assessor made an error in uncapping the taxable value. 

The Tribunal has inherent authority as also substantiated by the Michigan Supreme Court 

for the authority to adjust prior errors that impact the current tax year.

Wherefore, Petitioner respectfully requests this Honorable Tribunal to reverse the 

uncapping of the taxable value in line with the Michigan Legislature intent and case law 

established by Michigan Courts and this Honorable Tribunal. 

Dated: July 23, 2026 

/s/ Jeahad Kada 

Jeahad Kadaf P82492 

Attorney for Petitioner 

22174 Michigan ave 

Dearborn MI 48124

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATION HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

CAPITAL HILL INVESTMENTS, LLC 

MTT Docket No: 26-000650 

Petitioner, 

v. 

CITY OF INKSTER 

Respondent 

/ 

JEAHAD KADAF (P82492) 

Marwan Abdullah 

Attorneys for the Petitioner 

26215 Trowbridge 

22174 Michigan Ave 

Inkster MI 48141 

Dearborn MI 48124 

City of Inkster Assessor 

(313) 290-0000 

jkadafi@kadaflaw.com 

PETITIONER’S RESPONSE TO RESPONDENT'S ANSWER & 

PETITIONERS FACTUAL BASIS FOR APPEAL 

PETITIONER’S CHALLENGE TO RESPONDENT’S ANSWER 

PETITIONER’S ARGUMENT 

3254 Moore, Inkster MI 48141 

Tax ID# 

44010060274000 

BACKGROUND 

Petitioner owns the property commonly known as 3254 Moore, Inkster MI 48141. The 

property was purchased under a trust, whereas the beneficiary of the trust is Capital Hill 

Investments, LLC. Thereafter, the trustee settled the trust and deeded the property to the 

beneficiary. The important factor is that the trustee and the beneficiary are 100% owned by the 

same person, Mike Ghani. 

Here is a history of ownership with a timeline below:

eo 

12/1/2022 

Petitioner purchased the property 3254 Moore Inkster Trust also being 

“Capital Hill Investments” the beneficiary of the trust. 

eo 

7/3/2024 

Petitioner moved the property to Capital Hill Investments LLC, who is the 

beneficiary of the trust and same owners as the trustee and the LLC. 

(EXHIBIT A) 

The City of Inkster treated the transfer as an uncapping under the statute as a sale. The 

Petitioner provided the City Assessor all the relevant information that meets the MCL 

211.27(a), and further sent it by Certified Mail return receipt, USPS # 9589 0710 5270 1257 

2731 45, in an attempt to assist the assessor in rectifying the issue. (EXHIBIT B). 

Although the Petitioner met the burden of proof, the City Assessor uncapped the property 

taxable value. Additionally, the City Assessor argument is that we are petitioning the wrong 

year, yet if you look at the notice sent by the assessor of their decision, it has the wrong 

address of the Petitioner. (EXHIBIT C). 

LAW AND ARGUMENT 

MCL 

211.27a(7)(m) is a provision in Michigan's General Property Tax Act that 

excludes specific corporate changes from triggering a property tax "uncapping" event. 

Specifically, it states that a direct or indirect transfer of real property or ownership 

interests resulting from a transaction qualifying as a tax-free reorganization under 

section 368 of the Internal Revenue Code does not constitute a “transfer of ownership’. 

In TR) & E Properties, LLC v. City of Lansing, 323 Mich App 664; 919 NW2d 795 

(2018), the Michigan Court of Appeals interpreting the "commonly controlled" exception to 

Michigan's property tax "uncapping" rules under the General Property Tax Act (GPTA). The 

case is significant because it rejected a rigid administrative definition of common control and 

instead focused on who actually possessed the power to control the entities involved. 

The decision established that common control is a functional concept rather than a 

fixed ownership percentage. The court looked to whether the same persons possessed the 

practical ability to control each entity, recognizing that different organizations may require

different voting thresholds. For example, an entity requiring a supermajority might require a 

higher level of common ownership to establish control than one governed by a simple majority. 

The court held that there is an exemption when the transfer is between “commonly 

controlled” entities. 

Here, it is the same circumstances, the transfer is not only between commonly controlled 

entities and a common denominator of ownership, but the Beneficiary of the trust is the entity. 

The trust is a legal entity as well as the single member LLC, and the same individual is effective 

control and ownership, notwithstanding the it was deeded from the trust to the beneficiary. 

Therefore, pursuant to the MCL 211.27a(7)(m) and case law, this DOES NOT trigger uncapping 

of the taxable value under Michigan Law. 

In Anderson v. Chocolay Township (MTTT Docket No. 433005), the Tribunal treated a 

conveyance from a trust, the Tribunal ruled it was not a transfer and exempt under MCL 

211.27a(7)(m). There is no other person(s) involved in the transfer, still the same commonly 

controlled and ownership. 

Again in Shvartsman (MTT Docket Nos. 449484, 449485, 449532, 449533, 449534), Revenue 

Administrative Bulletin (RAB) 1989-48 recognizes that a sole proprietor can be considered part 

of a commonly controlled group. Evidenced in the trust, the same as the beneficiary. 

COURT POWERS TO ADJUST PRIOR YEARS 

In uncapping cases under MCL 211.27a, argument that correcting the year of 

transfer necessarily requires correcting every subsequent year's taxable value because each 

year's taxable value is derived from the prior year's taxable value. 

If the tribunal determines the uncapping was in error, the MTT has full authority to go 

back and amend prior years. These inherent powers with the MTT are to correct errors, those of

which are impacted by prior years. The MTT in order to correct the current tax years, must go 

back and cure the error that created the issue before this tribunal. 

The Michigan Supreme Court has consistently held that The Tax Tribunal does have 

the authority to reduce an unconstitutional previous increase in taxable value for purposes of 

adjusting a taxable value that was timely challenged in a subsequent year. 

"Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers 

and duties as those assigned to a March board of review..., including the duty to adjust erroneous 

taxable values to bring the current tax rolls into compliance with the GPTA.". 

In._Toll Northville Limited Partnership v. Northville Township, The Supreme Court 

stated: The Tax Tribunal has the same powers as the March Board of Review and may adjust 

previously entered erroneous taxable values for purposes of bringing the current tax roll into 

compliance with the GPTA. The Court emphasized that correcting an earlier year's value 

does not reopen that year's tax liability. Instead, the earlier value is corrected because it is the 

mathematical basis for the current year's taxable value. 

In, Mikelonis v. Township of Alabaster 313 Mich App 679 (2015), earlier years were 

addressed by the court as erroneous uncapping, therefore granting powers to make subsequent 

adjustments. Similarly here, the MTT has authority to address prior year error in order to adjust 

the subsequent years and correct the initial issue. 

Michigan Properties, LLC v. Meridian Township (PDF) Page 20 (491 Mich at 537). The Court 

explains the core issue: "The failure to adjust the taxable value in the year immediately

following the transfer produced an erroneous taxable value because the taxable value was 

not in compliance with the GPTA." 

Pages 24-26 (491 Mich at 541-543) 

, ID. 

Here the Court explains why correcting a prior year's taxable value does not reopen 

prior tax years."..may correct the taxable value in a subsequent year in order to bring 

the current taxable value into compliance with the GPTA. 

The Court states: 

"Once its jurisdiction is properly invoked, the Tax Tribunal possesses the same powers and 

duties as those assigned to a March board of review..." 

the Court continues: 

"...the Tax Tribunal has the authority to reduce an unconstitutional previous increase in 

taxable value for purposes of adjusting a taxable value that was timely challenged in a 

subsequent year. 

CONCLUSION 

The facts are clear and concise that the “Trust” had Capital Hill Investments LLC as the 

trustee. The Trust settlor who is also the same as the Single Member of Capital Investments 

LLC, deeded the property back to the beneficiary, as the same single person with common 

control. 

This same analysis as can be reviewed in this brief has been upheld by the Michigan 

Court of Appeals and this very Michigan Tax Tribunal. The exemption under MCL 

211.27(a)7(m) and as designed by the Michigan Legislature, therefore the City of Inkster 

assessor made an error in uncapping the taxable value. 

The Tribunal has inherent authority as also substantiated by the Michigan Supreme Court 

for the authority to adjust prior errors that impact the current tax year.

Wherefore, Petitioner respectfully requests this Honorable Tribunal to reverse the 

uncapping of the taxable value in line with the Michigan Legislature intent and case law 

established by Michigan Courts and this Honorable Tribunal. 

Dated: July 23, 2026 

/s/ Jeahad Kadaf 

Jeahad Kadaf P82492 

Attorney for Petitioner 

22174 Michigan ave 

Dearborn MI 48124

EXHIBIT A

$i 

IRS DEPARTVENT OF THE TREASURY 

INTERNAL REVENUE SERVICE 

CINCINNATI 

OH 

45999-0023 

Date of this notice: 

01-13-2017 

Employer Identification Number: 

81-4975575 

Form: 

SS-4 

Number of this notice: 

CP 575 

B 

CAPITAL HILL INVESTMENTS LLC 

MIKE ABDUL GHANI MBR 

109 

E 17TH ST STE 430 

For assistance you may call us at: 

CHEYENNE, 

WY 

82001 

1-800-829-4933 

IF YOU WRITE, ATTACH THE 

STUB AT THE END OF THIS NOTICE. 

WE ASSIGNED YOU AN EMPLOYER IDENTIFICATION NUMBER 

Thank you for applying for an Employer Identification Number 

(EIN). 

We assigned you 

EIN 81-4975575. 

This EIN will identify you, 

your business accounts, 

tax returns, 

and 

documents, 

even if you have no employees. 

Please keep this notice in your permanent 

records. 

’ 

When filing tax documents, payments, 

and related correspondence, 

it is very important 

that you use your EIN and complete name and address exactly as shown above. 

Any variation 

may cause a delay in processing, 

result in incorrect information in your account, 

or even 

cause you to be assigned more than one EIN. 

If the information is not correct as shown 

above, please make the correction using the attached tear off stub and return 

it to us. 

Based on the information received from you or your representative, 

you must file’ 

the following form(s) 

by the date(s) 

shown. 

Form 1065 

03/15/2018 

If you have questions about the form(s) 

or the due date(s) 

shown, 

you can call us 

at 

the phone number or write to us at the address shown at the top of this notice. 

If you 

need help in determining your annual accounting period 

(tax year), 

see Publication 538, 

Accounting Periods and Methods. 

We assigned you 

a tax classification based on information obtained from you or your 

representative. 

It 

is not 

a legal determination of your tax classification, 

and is not 

binding on the IRS. 

If you want a legal determination of your tax classification, 

you may 

request 

a private letter ruling from the IRS under the guidelines in Revenue Procedure 

2004-1, 

2004-1 I.R.B. 

1 

(or superseding Revenue Procedure for the year at issue). 

Note: 

Certain tax classification elections can be requested by filing Form 8832, Entity 

Classification Election. 

See Form 8832 and its instructions for additional information. 

A limited liability company 

(LLC) 

may file Form 8832, 

Entity Classification 

Election, 

and elect 

to be classified as an association taxable as 

a corporation. 

If 

the LIC 

is eligible to be treated as 

a corporation that meets certain tests and it 

will be electing 

S corporation status, 

it must timely file Form 2553, Election by a 

Small Business Corporation. 

The LIC will be treated as 

a corporation as of the 

effective date of the 

S corporation election and does not need to file Form 8832. 

To obtain tax forms and publications, 

including those referenced in this notice, 

visit our Web site at www.irs.gov. 

If you do not have access to the Internet, 

call 

1-800-829-3676 

(TTY/TDD 1-800-829-4059) 

or visit your local IRS office.

REVOCABLE TITLE HOLDING TRUST AGREEMENT 

Trust Agreement made this 5TH day of April 2019. 

Capital Hill Investments LLC Settlor(s) whose address is 109 E 17t" Street Suite 430, 

Cheyenne, WY 82001 hereinafter collectively referred to as the "Beneficiaries". 

Anwar Haidar, as Trustee and Mike Abdul-Ghanli, as Co-Trustee, of the trust created hereby, 

(herein after referred to as the “Trustee”, which designation shall include all successor trustees), 

whose address is 99 Wall Street #772, New York, NY 10005. 

Whereas, the Beneficiaries are about to conveyor cause to be conveyed In the near future 

certain real property to the Trustee, and the Trustee has agreed to accept such conveyance and 

hold the real property as a fiduciary in trust for the Beneficiaries under the terms and conditions 

set forth below. 

Now, therefore, the parties hereby agree as follows: 

1. 

Declaration of Trust. The trust created by the trustors/settlors herein shall be known 505 

Arlington Inkster Trust (hereinafter referred to as the Trust"). 

2. 

Trust Property. The corpus of the trust will be real property (hereinafter referred to as the 

“Trust Property”) that the Beneficiary will conveyor cause to be conveyed fee simple 

absolute by deed. Said property is described in the attached Exhibit IA.” The Trustee shall 

hold full legal and equitable title to said property, in trust, only for the use and purpose 

stated under the terms of this Agreement and any valid addendum hereto duly executed by 

the parties. If permissible in the state in which the real property sits, title shall be held in the 

name of the Trust itself, to wit: "505 Arlington Inkster Trust” otherwise, the Trustee shall 

hold title in his or her name "an Individual, as Trustee, and not personally, of the "605 

Arlington Inkster Trust". 

3. 

Trust Purpose. The objects and purposes of this Trust shall be to hold full legal and 

equitable title to the Trust Property until its sale, disposition or liquidation, or until the trust is 

terminated or expires by its own terms and/or as a matter of law. The Trustee shall not 

undertake any activity that is not strictly necessary to the achievement of the foregoing 

objects and purposes, nor shall the Trustee transact business within the meaning of 

applicable state law, or any other law, nor shall this Agreement be deemed to be, or create 

or evidence the existence of a corporation, de facto or de jure, or a Massachusetts Trust, or 

any other type of business trust, or an assoclation in the nature of a corporation, or a co- 

partnership or joint venture, limited liability company, or similar limited liability association 

by or between the Trustee and the Beneficiarles, or by or between the Beneficiaries. 

4. 

Consideration. The Trustee has paid no consideration for the conveyance of real property 

described herein. The conveyance will be accepted and held by the Trustee subject to all 

existing liens, encumbrances, easements, restrictions or other clouds or claims against the 

title thereto, whether the same are of record or otherwise. The property will be held on the 

trusts, terms and conditions and for the purposes hereinafter set forth, until the whole of 

the trust estate is conveyed, free of this trust, as hereinafter provided.

5. 

Rights and Duties of the Beneficlaries. The persons and/or entities named in the attached 

Exhibit "B® (including their heirs, assigns or successors) hereof are the Beneficiaries of this 

Trust, and as such, shall be entitled to all of the eamings, avalls and proceeds of the Trust 

Property according to their interests set opposite their respective names. No Beneficiary 

shall have any legal or equitable right, title or interest, as realty, in or to any real estate held 

in trust under this Agreement, or the right to require partition of that real estate, but shall 

have enly the rights, as personally, set out below, and the death of a Beneficiary shall not 

terminate this Trust or in any manner affect the powers of the Trustee. 

The interests of the Beneficiaries shall consist solely of the following rights respecting the 

Trust Property: 

a. The right to direct the Trustee to conveyor otherwise deal with the title to the 

Trust Property as hereinafter set out. 

b. The right to participate in the management and control the Trust Property. 

c. The right to receive the proceeds and avails from the rental, sale, mortgage, or 

other disposition of the Trust Property. 

d. The right to create, manage and participate In the handling of bank accounts 

and funds for the trust. 

6. 

Powers and Duties of Trustee. The Trustee shall not copy or show this agreement to any 

Individual or entity other than the beneficiaries or successor trustees, nor shall the Trustee 

reveal the identity of the beneficiaries or the trust property to any individual or entity except 

by way of a Court Order duly exscuted by a Justice or Magistrate of a Court of competent 

Jurisdiction. The trustee shall not record this agreement or the name of any of the 

beneficiaries in any place of public record. 

The Trustee, as owner of record under the Trust, is merely holding title to the Trust 

Property and does not have the right to mortgage, lease, convey, exchange, option, 

barter or otherwise encumber said property without express written direction from the 

beneficiary or power of direction holder. The Trustee, as the sole owner of record of the 

Trust Property, has only the following powers with respect the Trust Property, and only 

at the written direction of the Beneficiary: 

a. 

To issue notes or bonds and to secure the payment of the same by executing a 

deed of trust, mortgage or other security instrument conveying a lien on the 

whole or any part of the Trust Property; 

b. 

To borrow money, giving notes therefore, or to assume existing debts related to 

the property signed by him or her in the capacity as Trustee; 

c. 

To invest such part of the capital and profits there from and the proceeds of the 

sale of bonds and notes in such real estate, equities in real estate, and 

mortgages in real estate in the United States of America; 

d. 

To have, together with, and at the direction of the beneficiaries, the exclusive 

management and control of the property as if he were the absolute owner 

thereof, and the full power to do all things and perform all acts which in his or her 

2

judgment are necessary and proper for the protection and preservation of the 

Trust Property and for the interest of the Beneficiaries in the property of the 

Trust, subject 

to the restrictions, terms, and conditions set forth herein; 

e. 

To take possession of the trust property in the event it becomes vacant; 

f. 

To purchase any additional real property for the Trust at such times and on such 

terms as may be beneficial to the beneficiary; 

g. 

To rent or lease the whole or any part of the Trust Property for long or short 

terms, but not for terms exceeding the term of the Trust then remaining; 

h. 

To repair, alter, tear down, add to, or erect any building or buildings upon land 

belonging to the Trust; to fill, grads, drain, improve, and otherwise develop any 

land belonging to the Trust; to carry on, operate, or manage any building, 

apartment house, mabile home lot or hotel belonging to the Trust; 

I. 

To make, execute, acknowledge, and deliver all deeds, releases, mortgages, 

leases, contracts, options, agreements, instruments, and other obligations of 

whatsoever nature relating to the Trust Property, and generally to have full power 

to do all things and perform all acts necessary to make the instruments proper 

and legal (and to do so by a duly appointed attomey-in-fact); 

J- 

To collect notes, rents, obligations, dividends, and all other payments that may 

be due and payable to the Trust; to deposit the net proceeds thereof, as wall as 

any other moneys from whatsoever source they may be derived, in any suitable 

bank or depository, and to draw the same from time to time for the purposes 

herein provided, paying the net proceeds there from to the beneficiaries; 

k. 

To pay all lawful taxes and assessments and the necessary expenses of the 

Trust; to employ such officers, brokers, property managers, engineers, architects, 

carpenters, contractors, agents, counsel, and such other persons as may seem 

expedient, to designate their duties and fix their compensation; to fix a 

reasonable compensation for their own services to the Trust, as organizers 

thereof. 

I. 

To represent the Trust and the Beneficiaries In all suits and legal proceedings 

relating to the Trust Property in any court of law of equity, or before any other 

bodies or tribunals; to begin suits and to prosecute them to final Judgment or 

decree; to compromise claims or suits, and to submit the same to arbitration 

when, in their judgment, such course is necessary or proper. 

Trustee in addition to the other duties herein imposed upon him or her, shall have the 

obligation to: 

m. To keep a careful and complete record of all the beneficial interests in the Trust 

Property with the name and residence of the person or persons owning such 

beneficial interest, and such other items as they may deem of Importance or as 

may be required by the Beneficiaries.

7. 

8. 

n. 

To keep careful and accurate books showing the receipts and disbursements he 

or she has made on behalf of the Trust and also of the Trust Property and to 

keep books of the Trust open to the inspection of the Beneficiaries. 

Nothing in this agreement shall preclude the powers and authorities of a trustee 

as defined by state law, code or statute, unless such additional powers shall 

cause this agreement to be construed as a "trust" as defined in Section 

301.7701-4(a) of the Procedure and Administration Regulations of the Internal 

Revenue Code. 

Compensation of Trustee. The Beneficiaries jointly and severally agree that the Trustee 

shall receive the sum N/A per year for his or her services as Trustee. 

Liability of Trustee. The Trustee and his or her successor as Trustee shall not be required to 

give a bond, and each Trustee shall be liable only for his own acts and then only as a result 

of his own gross negligence or bad faith. 

Removal of Trustee. The Beneficiaries shall have the power to remove a Trustee from his 

office or appoint a successor to succeed him or her. This removal must be in writing, signed 

by all of the beneficiaries. Upon Seven (7) days written notice, the Trustee shall deliver all 

books, records, bank account information, keys, security deposits, leases and funds in his or 

her possession, and execute any documents necessary to convey title and / or authority 

over the Trust and the Trust Property to the Successor Trustee. 

10. Resignation of Trustee. Any Trustee may resign his or her office with thirty (30) days written 

notice to Beneficiaries. The Beneficiaries shall appoint the Trustee named as successor 

Trustee herein (or proceed to elect a new Trustee) to take the place of the Trustee who had 

resigned, but the resignation shall not take effect until an affidavit signed and acknowledged 

before a notary public by both the resigning Trustee and the new Trustee shall have been 

procured in a form which is acceptable for recording in the registries of deeds of all the 

counties in which properties held under this instrument are situated. If the Trust property is 

recorded in the name of the trustee himself, the resigning trustse shall also execute a 

general warranty deed in the proper form and manner for recording the registry of deeds in 

the county in which the property is situate. Said deed and/or affidavit need not be recorded 

unless so requested of the new Trustee at the written direction of the Beneficiaries. 

In the event a new trustee Is not appointed within Sixty (60) days after notice the resignation 

of the existing Trustee is received by the beneficiaries, this agreement shall terminate, and 

the resigning Trustee shall deliver all books, records, bank account information, keys, 

security deposits, leases and funds in his or her possession, and execute any documents 

necessary to convey title to the trust property to the beneficiaries as their interests may 

appear. 

Whenever a new Trustee shall have been elected or appointed to the office of Trustee and 

shall have assumed the duties of office, he or she shall succeed to the title of all the 

properties of the Trust and shall have all the powers and be subject to all the restrictions 

granted to or imposed upon the Trustee by this agreement, and every Trustee shall have the 

same powers, rights, and interests regarding the Trust Property, and shall be subject to the 

same restrictions and duties as the original Trustee, except as the same shall have been 

modified by amendment, as herein provided for.

11. Death or Incapacity of Trustee. Upon the death, termination, resignation or physical or 

mental incapacity of the Trustee, the following individual(s) shall immediately be appointed 

as successor Trustee, with the full powers and duties of the former Trustee: 

Jihad Haldar 

Ames Ghani 

In the event none of said Individuals are then living or are unable or unwilling to act as 

Trustes, then a new Trustee will be elected and appointed as per paragraph®10” herein. 

In the event of the death of any beneficiary, his or her right and interest hereunder, except 

as otherwise provided, shall pass to his or her executor or administrator and to his heirs at 

law. 

12. Death or Incapacity of Beneficiary. In the event of the death of the beneficiary hereunder, 

100% of the beneficial interest shall pass to the successor beneficiary: 

N/A 

13. Beneficiary not bound by Trustee. The Trustee is not an agent or partner of, and shall have 

no power to bind the Beneficiaries personally and, in every written contract he may enter 

into, reference shall be made to this declaration; and any person or corporation contracting 

with the Trustee, as well as any beneficiary, shall look to the funds and the Trust Property 

for payment under such contract, or for the payment of any debt, mortgage, judgment, or 

decree, or for any money that may otherwise become due or payable, whether by reason or 

failure of the Trustee to perform the contract, or for any other reason, and neither the 

Trustee nor the Beneficiaries shall be liable personally therefore. 

14. Dealings 

with Trustee. No party dealing with the Trustee in relation to the Trust Property in 

any manner whatsoever, and, without limiting the foregoing, no party to whom the property 

or any part of it or any Interest in it shall be conveyed, contracted to be sold, leased or 

mortgaged by the Trustee, shall be obliged to see to the application of any purchase money, 

rent or money borrowed or otherwise advanced on the property; to see that the terms of this 

Trust Agreement have been complied with; to inquire into the authority, necessity or 

expediency of any act of the Trustee; or be privileged to inquire into any of the terms of this 

Trust Agreement. 

15. Recording of Agreement. Neither this Agreement nor any summary of the contents hereof 

shall be placed on record in the county in which the Trust Property is situated, or elsewhere, 

but if it is so recorded, that recording shall not be considered as notice of the rights of any 

person under this Agreement derogatory to the title or powers of the Trustee. 

16. Term of Agreement. This agreement shall continue for a period of twenty years from the 

date of its execution. The Trustee shall contact all Beneficiaries In writing at least twelve 

months prior to that time. The trustee shall place the Trust Property for public sale, pay all 

debts due and owing with regard to the Trust Property, and remit the proceeds to the 

Beneficiaries according to their respective interests in the Trust. The Beneficiaries may 

choose to renew this agreement for a tem of twenty additional years by submitting their 

intention in writing to the Trustee.

If any portion of the Trust Property is in any manner or time period capable of being held in 

this Land Trust for longer period of time than Is permitted under the laws of the state law 

governing this Agreement, or the vesting of any interest under this Land Trust could possibly 

occur after the end of such permitted time pericd, then, upon the occurrence of the 

foregoing, the Trustee is directed to immediately terminate the Trust and to distribute the 

Trust Property to the Beneficiaries as thelr respective interests may appear at the time of the 

termination of the Trust. As much as possible, the Trustee will maintain the Trust Property 

intact and not liquidate it, but, rather, distribute the Trust Property in kind. 

17. Income Tax Retums. The Trustee shall not be obligated to file any income tax returns with 

respect to the Trust, except as required by law, and the Beneficiaries individually shall report 

and pay their share of income taxes on the earings and avails of the Trust Property or 

growing out of their interest under this Trust. in the event an informational return is required 

by law, the Trustee agrees to execute the same after contacting all the Beneficiarles. It Is 

the intention of the parties that this agreement does not create a "trust” under the definition 

as set forth in Section 301.7701-4(a) of the Procedure and Administration Regulations of the 

Internal Revenue Code. 

18. Assignment of Beneficial Interest. The interest of a Beneficiary, or any part of that interest, 

may be transferred only by a written assignment, executed in duplicate and delivered to the 

Trustee. If there is more than one beneficiary, the remaining beneficiaries must first approve 

of said transfer in writing. The remaining beneficiaries shall have a sixty (60) day right of first 

refusal to purchase said interest. Unless stated otherwise, any assignment of beneficial 

interest hereunder shall also include the power of direction and revocation of this trust 

agreement. Any beneficiary who assigns his interest in full shall forever waive his right to 

revoke this trust agreement. 

19. Individual Liability of Trustee. The Trustee shall not be required, in dealing with the Trust 

Property or in otherwise acting under this Agreement, to enter into any individual contract or 

other individual obligation whatsoever; nor 

to make itself individually liable to pay or incur 

the payment of any damages, attomeys' fees, fines, penalties, forfeitures, costs, charges or 

other sums of money whatsoever. The Trustee shall have no individual liability or obligation 

whatscever arising from its ownership, as Trustee, of the legal title to the Trust Property, or 

with respect to any act done or contract entered into or indebtedness incurred byit in 

dealing with the Trust Property or in otherwise acting under this Agreement, except only as 

far as the Trust Property and any rust funds in the actual possession of the Trustee shall be 

applicable to the payment and discharge of that liability or obligation. 

20. Reimbursement and Indemnification of Trustee. If the Trustee shall pay or incur any liability 

to pay any money on account of this Trust, or incur any liability to pay any money on 

account of being made a party to any litigation as a result of holding title to the Trust 

Property or otherwise in connection with this Trust the Beneficiaries, Jointly and severally, 

agree that on demand they will pay to the Trustee all such payments made or liabilities 

incurred by the Trustes, together with its expenses, including reasonable attorneys’ fees, 

and that they will indemnify and hold the Trustee harmless of and from any and all payments 

made or liabilities incurred by it for any reason whatsoever as a result of this Agreement. 

21. Unanimous Direction of Beneficiaries. Wherever an act, decision or direction is required by 

the “Beneficiary” or “Beneficiaries” herein, said designation shall be deemed to mean all of 

the Beneficlaries acting in a unanimous agreement, unless a lesser percentage is so 

specified.

22. Governing Law. This agreement, and all transactions contemplated hereby, shall be 

23. 

24. 

25. 

26. 

IN 

govemed by, construed and enforced in accordance with the laws of the State of Michigan. 

The parties herein waive trial by jury and agree to submit to the personal jurisdiction and 

venue of a court of subject matter jurisdiction located in the County in which the property 

sits. In the event that litigation results from or arises out of this Agreement or the 

performance thereof, the parties agree to reimburse the prevailing party's reasonable 

attorney's fees, court costs, and all other expenses, whether or not taxable by the court as 

costs, in addition to any other relief to which the prevailing party may be entitled. In such 

event, no action shall be entertained by said court or any court of competent jurisdiction 

if 

filed more than one year subsequent to the date the cause( s) of action actually accrued 

regardless of whether damages were otherwise as of said time calculable. 

Binding Effect. The terms and conditions of this Agreement shall inure to the benefit of and 

be binding upon any successor trustee under it, as well as upon the executors, 

administrators, heirs, assigns and all other successors in interest of the Beneficiaries. 

Annual Statements. There shall be no annual meeting of the Beneficiaries, but the Trustee 

shall prepare an annual report of their receipts and disbursements for the fiscal year 

preceding, which fiscal year shall coincide with the calendar year, and a copy of the report 

shall be sent by mail to the Beneficiaries not later than February 28 of each year. 

Termination of this Agreement. This Trust may be terminated on thirty (30) days written 

notice signed by all of beneficiaries and delivered to the Trustee. Upon the termination of 

this Agreement, the Trustee shall deliver all books, records, bank account information, keys, 

security deposits, leases and funds in his or her possession, and execute any documents 

necessary to convey title to the trust property to the beneficiaries as their interests may 

appear. 

Entire Agreement. This Agreement contains the entire understanding between the parties 

and may be amended, revoked or terminated only by written agreement signed by the 

Trustee and all of the Beneficiaries. 

WITNESS WHEREOF, the parties hereto have executed this agreement as of the day and 

year first above written. 

The beneficiaries: 

FA 

Capital Hill Investments LLC

The Trustee: 

NE; Ny 

Anwar Haidar’ 

The Co-Trustee: 

Mike Abdu 

i 

STATE OF MICHIGAN, 

) 

COUNTY OF WAYNE 

) 

On Fit 

esl 

before me, Janne M. Salerng 

Notary Public 

personally appeared Anwar Haidar and Mike Abdul-Ghani, who proved to me on the basis of 

satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within 

instrument and acknowledged to me that he/she/they executed the same in his/her/their 

authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), 

or the entity upon behalf of which the person(s) acted, executed the instrument. 

I certify under PENALTY OF PERJURY under the laws of the State of Michigan that the 

foregoing paragraph is true and correct. 

WITNESS my hand and official seal. 

Qassim 

NOTARY PUBLIC 

COUNTY 

OF WAYNE 

MY COMMISSION 

EXPIRES JANUARY 9, 202 

ACTING IN THE COUNTY 

OF 

ragcnEenERed 

JSEEmERRREaguY, 

STATE OF | 

< 

ANENEESHENESAESUSNINENENEARNEELS A!

EXHIBIT B 

BENEFICIARIES AND THEIR INTERESTS 

Name and Address 

% Interest 

Capital Hill Investments LLC 

100% 

109 E 17" Street Suite 430 

Cheyenne, WY 82001 

10

EXHIBIT B

SENDER: COMPLETE THIS SE 

TION. 

B Complete items 1, 2, and 3. 

B® Print your name and address on the’ 

. i that we can return the card to Cot 

ttach this card to the back of th 

Jip 

e 

or on the front if space permits. 

ioe 

1, 

COMPLETE, THIS SECTION/ON. DELIVERY: 

A. Signature 

~ 

1 

5 

u(x, n 

{ Vo 

OO Agent 

bi 

[1 Addressee 

3 

Received 

by (Printe: 

TL 

EE Py 17257 

Mayors Office 

26215 Trowbridge 

Inkster M1 48141 

D. 

Is delivery address different fro m iter 

If YES, enter delivery address Hoi 

= 5 

3. Service Type 

Amman 

se 

0 Adult Signature Restricted Delivery 

o 

je 

il 

9590 9402 8397 3156 0755 30 

0 Gorled Mah Restcted Delivery 

POR 

Vr ——— 

0 Collect on Delivery 

9589 0710 5270 1257 2731 

38 

 goorewetde 

fer oo Restricted Delivery 

O Priority Mail Express® 

a Registered Mail™ 

istered 

Dalvery 

Mail Restricted 

0 Signature Confirmation™ 

O Signature Confirmation 

Restricted Delivery 

PS Form 3811, July 2020 PSN 7530-02-000-0053 

Domestic Return Receipt 

SENDER: COMPLETE THISISECTION 

m Complete items 1, 2, and 3. 

B Print your name and address on the veverse 

so that we can return the card to you. 

® Attach this card to the back of the mailpiece, 

or on the front if space permits. 

COMPLETE THIS SECTION ON! DELIVERY: 

Address 

C. Date of 

Deliv 

o> & 

g 

2 

52-bEv Log 

1. Article Addressed to: 

— 

Assessors Office 

26215 Trowbridge 

Inkster MI 48141 

HHH 

9590 9402 8397 3156 075523 

D. Is delivery address different from tem 17 

“3 Yes 

If YES, enter delivery address below: 

CI No 

3. Service Type 

0 Adult Signature 

O Adult Signature Restricted Delivery 

0 Certified Mall® 

0 Certified Mail Restricted Delivery 

D Artinla Misia 

7 

O Collecton Delivery 

589 0710 

5270 

1.257 

2731 

45 

1 

Resticted Deivery 

(over $500) 

0 Priority Mail Express® 

O Registered Mail™ 

0 Registered Mall Restricted 

Delivery 

0 Signature Confirmation™ 

0 Signature Confirmation 

2 Delivery Restricted Delivery 

Restricted Delivery 

PS Form 3811, July 2020 PSN 7530-02-000-9053 

Domestic Return Receipt

EXHIBIT C

04/15/2026 

09:54 

AM 

2026 BOARD OF REVIEW DECISION 

FROM 

CITY OF INKSTER 

ASSESSOR'S OFFICE 

26215 TROWBRIGE 

INKSTER, MI 48141 

NAME AND ADDRESS OF OWNER OR PERSON NAMED ON ASSESSMENT ROLL: 

PROPERTY IDENTIFICATION: (Parcel Code required. Property address 

and legal description optional.): 

44 010 06 0274 000 

3254 MOORE 

CAPITAL HILL INVESTMENTS LLC 

3254 MOORE 

INKSTER, MI 48141 

25U274 LOT 274 WOLVERNINE TRACTOR SUB T2S ROE L38 

P34 WCR 

THIS PROPERTY IS CLASSIFIED 

401 (RESIDENTIAL-IMPROVED) 

Thank you for attending this years March Board of Review. The Board has reviewed the information you supplied and the data necessary 

to compute your assessment and taxable value. 

The Board has completed their review of parcel number 44 010 06 0274 000 

They have made the following determination based on the information you supplied. 

Board of Review Comments 

DENIED, INSUFFICIENT INFORMATION TO WARRANT A RECAPPING FROM 2025. 

[2026 ORIGINAL ASSESSED VALUE 

43,700 

| 

[2026 "BOARD OF REVIEW" ASSESSED VALUE 

43,700 

] 

(If the above amounts are the same, no revisions have occured) 

2026 ORIGINAL TAXABLE VALUE 

38,512 

| 

[2026 "BOARD OF REVIEW" TAXABLE VALUE 

38,512 

| 

[2026 PRINCIPAL RESIDENCE EXEMPTION/QUALIFIED AG 

0.0000 

| 

Please feel free to contact the assessor at the address listed above or call if you have any questions. 

"Effective March 1, 2013, the Tribunal is no longer able to accept Small Claims letter appeals. Rather, you are required to file a petition to 

initiate a new Small Claims appeal. Petition forms are available on this website." 

http://www.michigan.gov/taxtrib/0,4677,7-187-38254---,00.html

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