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26-001405.pdf

Mohamed Mansour Petitioner Vs. Township Of Mt Morris Respondent · 26-001405-TT

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Page 1

RECEIVED 

'AUG 19 2026 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Mohamed Mansour, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

v 

MTT Docket No. 26-001405 

City Of Mt Morris, 

Respondent. 

ORDER OF DEFAULT 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

Petitioner filed an Entire Tribunal case information sheet and paid a filing fee. 

Petitioner 

is required to file a petition and pay the required filing fee to initiate an appeal with the 

Tribunal. See TTR 225 and MCL 205.735a. Because a petition was not filed, the 

appeal is not properly pending. As such, Petitioner must file a petition within 14 days of 

the entry of this order. The petition shall note the docket number assigned by the 

Tribunal and if filed utilizing the Tribunal’s e-filing system, must be filed on the assigned 

docket number as an “amended petition.” 

Therefore, 

IT 1S ORDERED that Petitioner is HELD IN DEFAULT. 

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order." 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee). 

By: /s/ Patricia L. Halm 

Entered: August 11, 2026

Page 2

MTT Docket No. 26-001405 

Page 2 of 2 

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 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

AMENDED PROPERTY TAX PETITION 

Mohamed Mansour, 

Petitioner 

v, 

City of Mt Morris, 

Respondent 

MTT Docket No. 26-001405 

1. Property Parcel 

Property Parcel No.; 14-33-100-011 

Property Address: 3502 N Linden Rd, Flint, Michigan 48504 

County: Genesee County 

Property Type: Real property 

Property Classification shown on the 2026 tax bill: 202 - COMMERCIAL-VACANT 

Legal Description: 

W 198 FT OF N 264 FT OF NW 1/4 OF NW 1/4 SEC 33 TSN R6E 1.20 A 

2, Tax Year and Assessment Information 

Tax Year(s) Appealed: 2026 

The 2026 tax bill identifies a taxable value of $21,000, an SEV of $21,000, and an assessed value of $21,000. 

The assessment or assessments at issue were protested before the Respondents Board of Review on: March 

2026 

3. Statement of Facts 

1. Petitioner, Mohamed Mansour, is the owner and taxpayer identified for Parcel No, 14-33- 100-011. 

2. The property is located at 3502 N Linden Rd, Flint, Michigan 48504, and contains approximately 1.20 

acres. 

3. The 2026 tax record classifies the property as 202 — COMMERCIAL-VACANT. 

4. The 2026 tax record reports an assessed value and SEV of $21,000 and a taxable value of $21,000. 

8, Petitioner disputes the assessment and seeks review by the Michigan Tax Tribunal.

Page 4

4. Grounds for Appeal 

These site-specific limitations materially affect the property's development potential and, consequently, its 

market value. Petitioner requests that the Tribunal consider these limitations and the attached engineering 

correspondence and GIS exhibits when determining the property's true cash value. 

Based on the drain and likely casement, floodplain, floodway, possible wetlands, and applicable setbacks, the 

engineer concludes that the site is a very difficult site to develop and that, after those factors are considered, 

there may be little or no buildable area. 

The correspondence also identifies possible wetlands covering most of the site based on the county GIS 

wetlands information. It notes that the online wetlands viewer is not sufficiently reliable to establish a final 

wetlands boundary and that a formal wetlands assessment would be required to determine whether wetlands 

are present and, if so, their boundaries. 

The engineer further states that the southwest corner of the site appears to be outside the floodplain, but that 

the buildable area would still be reduced by applicable setbacks. 

The site also contains a floodway and a 100-year floodplain. The engineer's correspondence states that the 

100-year floodplain covers over half of the site and that 

a maximum of 300 cubic yards of fill is normally 

allowed before compensating cut is required. 

The correspondence states that a county drain crosses the site diagonally and that the Drain Commissioner will 

typically have an easement centered on such a drain, restricting what can be done within the easement. 

Petitioner retained Daniel W. Bartlett, PE, CEM, Associate / Project Manager with ROWE Professional 

Setvices Company, to evaluate the site in connection with a proposed building project. Mr. Bartlett provided 

written correspondence regarding the site's development constraints. 

Petitioner contends that the assessment of the subject property does not reflect its true cash value because 

substantial physical and environmental conditions materially limit the property's usable area and development 

potential. 

Petitioner respectfully requests that the Tribunal consider the actual acquisition price, the unsuccessful prior 

listing, the property's physical limitations, and the engineering evidence when determining true cash value. 

Petitioner believes that the property's inability to attract a buyer at the prior $14,999 asking price, together with 

the documented development constraints, is evidence that the property's actual market value is substantially 

lower than a valuation that assumes the entire 1.20 acres is usable commercial land. 

The $1,400 acquisition price is also relevant evidence of the property's market value. Petitioner further states 

that the property was listed for $14,999 on Scpiember 12, 2024 and did not sell at that asking price. 

This public listing history provides independent corroboration of the September 12, 2024 $14,999 asking 

price. Petitioner will provide the Zillow property-history page as an exhibit. The listing history does not itself 

establish a sale or the property's true cash value; rather, Petitioner offers it as evidence of the property's prior 

marketing history and unsuccessful exposure at that price. 

Publicly available Zillow listing history for 3502 N Linden Rd confirms a price change to $14,999 on

Page 5

The auction receipt provides documentary evidence that Parcel No. 14-33-100-011 was Lot 8405 and was 

acquired by Petitioner at a winning bid of $1,400.00. The receipt identifies Mohamed Mansour as the buyer 

and Parcel No. 14-33-100-011 as Lot 8405. 

5. Relief Requested 

Petitioner respectfully requests that the Michigan Tax Tribunal: 

A. Exercise jurisdiction over this appeal; 

B. Determine the proper valuation and/or classification of the property for the tax year(s) properly before 

the Tribunal; 

C. Reduce or otherwise correct the assessment and taxable value to the amounts supported by the 

evidence; 

D. Grant any other relief authorized by law that the Tribunal determines to be appropriate. 

E. Expected to pay taxes for the actual cash value of the property $1400 

6. Attachments 

Exhibit E — Genesee County GIS wetlands map for Parcel No, 14-33-100-011. 

Exhibit D ~ Genesee County GIS floodplain/floodway map for Parcel No. 14-33-100-011. 

Exhibit C — Email from Daniel W. Bartlett, PE, CFM, ROWE Professional Services Company, concerning 

development constraints at Parcel No. 14-33-100-011, 

Exhibit B — Order of Default entered August 11, 2026, MTT Docket No. 26-001405. 

Exhibit A — 2026 Summer Property Tax Bill for Parcel No. 14-33-100-011. 

The attached engineering correspondence is submitted as evidence of the property's site and development 

constraints. Petitioner does not represent the GIS wetlands layer as a final wetlands determination; the 

engineer's correspondence states that a formal wetlands assessment would be required for a definitive 

determination. 

Exhibit G — Evidence of the September 12, 2024 listing at $14,999, if available (listing printout, 

advertisement, broker record, or other documentation). 

Exhibit F —~ Documentation of the $1,400 acquisition price, if available (purchase agreement, closing 

statement, deed, or other record). 

Exhibit H — Zillow property-history page for 3502 N Linden Rd showing the September 12, 2024 price change 

to $14,999 and the property's current off-market status. 

Web source for Exhibit H: Zillow property page for 3502 N Linden Rd, Flint, MI 48504 (ZPID 

2102861058), accessed August 12, 2026. 

Exhibit I ~ Auction Receipt documenting Lot 8405 / Parcel No. 14-33-100-011 and the $1,400.00 winning bid.

Page 6

I declare that the information stated in this petition is true to the best of my knowledge, information, and 

belief, 

J 

Mohamed Mansour, Petitioner 

Date 

Clie hore 

EXHIBIT D — FLOODPLAIN / FLOODWAY GIS MAP 

Parcel 14-33-100-011 — 3502 N Linden Rd, Flint, MI 48504

Page 7

Genesee County GIS wetlands map supplied by Petitioner. The orange shading depicts possible wetlands; the 

accompanying engineer's correspondence states that a formal wetlands assessment would be required for a 

definitive determination.

Page 8

14 

wl FT ED 

14-33-100-011 Floo... 

+ 

X 

Genesee County GIS 

® 

Map Publicetion. 

1AVI0251 03 PU

Page 9

EXHIBIT E — WETLANDS GIS MAP 

Parcel 14-33-100-011 — 3502 N Linden Rd, Flint, MI 48504

Page 10

Genesee County GIS map supplied by Petitioner. The map depicts the parcel and the mapped 

Moodplain/floodway areas.

Page 11

8:14 

all > ED 

14-33-100-011 Wetl... 

+ 

X 

10f1 

Genesee County GIS 

Map Publication: 

NZIS 12M

Page 12

EXHIBIT D — FLOODPLAIN / FLOODWAY GIS MAP 

Parcel 14-33-100-011 — 3502 N Linden Rd, Flint, MI 48504

Page 13

Sent: Tuesday, December 2, 

2025 1:27 PM 

To: Ken Perry 

<KPerry@rowepsc.com>; 

Doug Scott 

<DScott@rowepsc.com> 

Subject: RE: Site 

Development - 3502 N Linden 

Rd Flint 

Ken, 

See attached floodplain 

drawing from the county GIS 

site. There is a county drain 

crossing diagonally through the 

site. The Drain Commissioner 

will typically have an easement 

centered on those which 

restricts what can be done 

within it. There is also a 

floodway (red crosshatch), and 

100 year floodplain (blue 

shading) which is over half of 

the site. A maximum of 300 cyd 

of fill, which isn’t much, is 

normally allowed before 

compensating cut is required.

Page 14

§ GIR I TERRY: WG, TROTTING i 

site. See attached wetlands 

PDF 

I made of the site from the 

county GIS. The orange 

shading is possible wetlands, 

which is most of the site. The 

accuracy of the online wetlands 

viewer is very hit or miss, they 

would need a formal wetlands 

assessment to get a wetlands 

determination to determine 

whether wetlands are present, 

and if they are, what the 

boundary is. 

The presence of the drain with 

a likely easement, a floodplain, 

floodway, and possible 

wetlands makes this a very 

difficult site to develop. By the 

time those factors are 

considered, and the setbacks, 

there may not much if any 

buildable area. 

A 

Daniel W. Bartlett,

Page 15

Auction Receipt 

Amount Due 

Payments 

Lot(s) Won 

Winning Bid 

Grand Total 

$26,022.69 

CreditCard 

31020500 

Base Charge 

$10,000.00 

a BISRCOTEE 

| 

reernnenn RISO eee 

Wire Transfer 

$14,747.69 

Subtotal 

$16,700.00 

Balance 

$0.00 

Other Fees 

Amount 

Lot 8405 Deed Fee 

Received of (Buyer): 

a 

Bidder Number - driovethefirst 

Mohamed Mansour 

{407)620-3003 (tel(407)820-3003) 

driovethefirst@yahoo.com 

3507 sunset 

dr 

flint, mi, 48503 

2.75% CC Fee 

$275.00 

Grand Total 

$25,022.69 

Lots Won 

Lot Number 

Parcel IDs 

8405 

14-33-100-011 (tel: 14-33-100-011) 

8515 

41-08-131-022 (tel:41-08-131-022) 

8621 

46-36-279-036 (tel:46-36-279-036) 

8648 

47-31-180-007 (tel:47-31-180-007) 

REMEMBER: 

If you have not yet executed and returned the Buyer's Affidavit and Affidavit of Entity 

Ownership (if applicable) that were emailad to you after the auction, you must do so IMMEDIATELY! 

If you fail to return these documents to us, your sale will be cancelled!

Page 16

FAMILY MEDICINE 

9589 0710 5270 u230 4979

woe wed 

MAANLD 

wi 

G-3230 Beecher Road, Suite 1 

Flint, Michigan 48532 

Micegn 

©. 9 

Rox 

lewsiwy

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