261001 statement prehearing Fossores.pdf
Fossores, Petitioner Vs. City Of Jackson, Respondent · 24-004252-TT
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR FOSSORES , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. 24-004252 CITY OF JACKSON , Respondent(s) X__ PETITIONER'S PROPERTY PREHEARING STATEMENT RESPONDENT'S PROPERTY PREHEARING STATEMENT Petitioner's representative: Ryan L. Phillips PC, Ryan L. Phillips P73731 Respondent's representative: Jackson City Attorney's Office, Matthew M. Hagerty P66015 Il. VALUATION INFORMATION: A. The true cash value (TCV), assessed value (AV), and taxable value (TV) for each parcel and tax year at issue as established by the Board of Review: Parcel Number: 2-005700000 Year TCV AV TV 2024 374400 187200 186270 2025 530200 265100 192044 2026 478600 239300 197229 B. Your contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue: Parcel Number: 2-005700000 Year TCV SEV TV 2024 374400 187200 0 2025 530200 265100 0 2026 478600 239300 0 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
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MTT Docket No. 24-004252 Page 2 of 4 C. Amounts in dispute for the tax year(s) at issue: Parcel Number: 2-005700000 Year TCV SEV TV 2024 186270 2025 192044 2026 197229 TAX INFORMATION: A. Have taxes been paid for each property for each tax year at issue? __Yes _x No FACTUAL STATEMENT OF CLAIMS: A. Describe any additions or losses for each property for each tax year at issue (by parcel number and tax year): not applicable Classification of each property for each tax year at issue (by parcel number): 201-Commercial Current use of each property for each tax year at issue, if different than above (by parcel number): House of public worship owned by a religious society and used predominantly for religious services and for teaching the religious truths and beliefs of the SOCIEty. . Contention of highest and best use for each property for each tax year at issue, if different than property's current use for each tax year at issue (by parcel number): not applicable Your factual statement of claims in support of your contentions, including additions and losses, if any (i.e., what facts are you relying on in support of your claim or defense?): The property at issue is a house of public worship, owned by a religious society and used predominantly
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Iv. VI. MTT Docket No. Page 3 of 4 for religious services and for teaching the religious truths and beliefs of the society. F. If non-uniformity of assessment is alleged, what evidence will you rely upon in support of your contentions? not applicable. ISSUES TO BE LITIGATED: A. Factual Issues: Is the property owned by a religious society and used predominantly for religious services and for teaching the religious truths and beliefs of the society? B. Legal Issues: Does the property qualify for exemption pursuant to MCL 211.7s? DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE EVIDENCE? ___Yes X_No A. If yes, state all necessary amendments (a motion may be required to amend the pleadings): ARE THERE CONSOLIDATION ISSUES? __ Yes _X No A. If yes, state the cases, by docket number, that should be consolidated with this case (a motion may be required to consolidate the cases):
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MTT Docket No. 24-004252 Page 4 of 4 VII. PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY ISSUES, IF ANY: A. Motions: none B. Discovery: none VIII. WITNESSES - IDENTIFY THE NAME AND ADDRESS OF ANY PERSON WHO MAY TESTIFY AND PROVIDE A GENERAL SUMMARY OF THE SUBJECT AREA OF THE TESTIMONY OF EACH PERSON IDENTIFIED: A. B. ] D m David McDonald, Lead Past of Fossores, 1331 Cadillac Blvd., Detroit, MI 48214 (see attachment) Ryan Parschall, CPA, 4100 Spring Arbor Rd., Jackson, MI 49201 (see attachment) . Kelly Heath, 722 Glenwood Ave., Jackson, MI 49203 . Jamin Bradley, 1208 Greenwood Ave., Jackson, MI 49203 Donald Bumgardner, Jr. 207 Star Rd., Spring Arbor, MI 49283 As provided by TTR 241, a person, other than a rebuttal witness, who is NOT identified as a witness in the prehearing statement, shall NOT be permitted to give testimony, unless, for good cause shown, the Tribunal permits the testimony to be taken. IX. NUMBER OF DAYS REQUIRED FOR HEARING: 1-2 X. DISCLOSURE AND TAXATION OF COSTS: By Petitioner does not seek costs at this time. Petitioner reserves the right to seek costs, including naple y fees, unde : = if vails an ents defense-is friviok os gil Date _ /O i OZ J / Failure to file and exchange this prehearing statement, as required by the Tribunal, shall result in the commencement of the prehearing conference as a show cause hearing. See TTR 237 and 241. See also MCL 205.732.
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VIII. ATTACHMENT TO PETITIONER’S PROPERTY PREHEARING STATEMENT . David McDonald is the Lead Pastor of the Fossores Chapters and is knowledgeable of most, if not all, events occurring at the subject property. . Ryan Parschall is a Certified Public Account and is knowledgeable of the books, accounting, and tax reporting of Fossores . Kelly Heath is, as worship leader, and has participated in leading worship and participating in other worship services at the subject property. . Jamin Bradley is a pastor and has participated in leading worship and participating in other worship services at the subject property. . Donald Bumgardner, Jr. is a pastor and has participated in leading worship and participating in other worship services at the subject property. . Joshua Kirchmeier, 750 Beverly Park Place, Jackson, Ml 49203, was a board member of Fossores and knowledgeable of reports to and actions of the board of directors.