311 POS.pdf

311 Grand River LLC Petitioner Vs. City Of Detroit Respondent · 26-001228-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

311 GRAND RIVER LLC, 

Petitioner, 

2 

MTT Docket # 26-001228 

CITY OF DETROIT, 

Respondent. 

/ 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on August b, 2026 he served a copy 

of Petitioner’s Petition on the parties named on the attached list. oe 

Aaron M, Fales

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

ASSESSOR 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

. 

WAYNE COUNTY 

CAYMC, 2 WOODWARD AVENUE #211 

DETROIT, MI 48226 

DIRECTOR OF EQUALIZATION 

WAYNE COUNTY 

500 GRISWOLD ST. 21ST FLOOR 

DETROIT, MI 48226 

SECRETARY OF SCHOOL BOARD 

DETROIT PUBLIC SCHOOLS 

732) 2ND AVENUE, 14TH FLOOR 

DETROIT, MI 48202-4050 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, mi -48922

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

311 Grand River LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001228 

City of Detroit, 

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 205.735a, 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), “[tlhe 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 Tribunal's rules. 

By: Tribunal Clerk 

Entered: July 29, 2026 

PROOF OF SERVICE 

| certify that a copy of the foregoing was sent on the eniry date indicated above to the

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

311 GRAND RIVER LLC, 

Petitioner, 

MTT Docket #26- 001228 

vs. 

Parcel No. 01004041-2, 23032100.36F, 

CITY OF DETROIT, 

8 23032100.36N 

Respondent. 

/ 

PETITION 

311 Grand River LLC ("Petitioner"), through 

its attorneys, Law Office of 

Aaron M. Fales, P.C., says: 

1. 

Petitioner's principal office address is 1300 Broadway, 

Suite 600, Detroit, Ml 48226. Petitioner is a party in interest with respect to 

property taxes on contiguous real property tax parcel nos. 01004041-2, 

23032100.36F, 

& 23032100.36N ("Petitioner's Property"), at 311 Grand River, 

Detroit, MI, 48226. 

2. 

Respondent, City of Detroit assesses and collects property taxes on 

Petitioner's Property. 

3. 

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

23032100.36F. 

to 

be $757,642 and assessed 

Petitioner's Property 

at $757,700 

resulting in a state equalized value of the same amount based on the tenative 

equalization factor and determined the faxable value of Pefitioner's Parcel # 

23032100.36N. to be $1,097,700 and assessed Petitioner's Property at $1,183,900 

resulting in a state equalized value of the same amount based on the tenative 

equalization factor. 

4. 

Petitioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

Petitioner's Property 

is commercial property. 

Petitioner believes that Petitioner's 

Property was designed fo be used as a 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

{b) 

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, 

and are based upon the application of wrong principles; and, 

(d} 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable 

value, 

and 

the 

mode 

of 

assessment 

adopied 

by 

Respondent, 

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 Parcel # 01004041-2. 

from $492,200 to $100,000, and reducing the 2026 assessed and state equalized 

values of Petitioner's Property from $492,200 to $100,000 and reducing the 2024 

taxable value of Petitioner's Parcel # 23032100.36F from $757,642 to $300,000, 

and reducing the 2026 assessed and state equalized values of Petitioner's 

Property from $757,700 to $300,000 and reducing the 2026 taxable value of 

Petitioner's Parcel # 23032100.36N from $1,097,700 to $700,000, and reducing the

Respectfully submitted, 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

a 

= 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste 350 

Birmingham, MI 48009 

(248) 767-9840 

Dated: May 21, 2026

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