Statewide Macomb POS.pdf

Statewide Macomb LLC, Petitioner Vs. Township Of Macomb, Respondent · 25-001815-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

V. 

MTT Docket # 25-001815 

TOWNSHIP OF MACOMB, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

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

| 

2025 he served a copy 

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

Bee 

ee 

Aaron M. Fales

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

MACOMB TWP. 

54111 BROUGHTON ROAD 

MACOMB, MI 48042 

ASSESSOR 

MACOMB TWP, 

54111 BROUGHTON ROAD 

MACOMB, MI 48042 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

NEW HAVEN COMMUNITY SCHOOLS 

30375 CLARK STREET, P.O. BOX 482000 

NEW HAVEN, Mi 48048-2000 

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 

Statewide Macomb LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-001815 

Township Of Macomb, 

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), “[t]he 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: July 24, 2025 

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 

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

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

MTT Docket #25- 

001815 

he 

Parcel No. 

20-08-36-227-021 

MACOMB TOWNSHIP, 

Respondent. 

/ 

PETITION 

STATEWIDE MACOMB LLC (“Petitioner”), through 

its attorneys, Law Office 

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

1. 

Petitioner's 

principal 

office 

address 

is 

48991 

Jefferson 

Ave, 

Chesterfield, MI 48047. 

Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 20-08-36-227-021 

("Petitioner's Property”), at 

46705 Erb Dr., Macomb MI. 

2. 

Respondent, Macomb Township 

assesses 

and 

collects 

property 

taxes on Petitioner's Property. 

3: 

In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $612,300 and assessed Petitioner's Property at $612,300 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 to be used for commercial purposes. 

5. 

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

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

6. 

Af this time, Petitioner believes, as 

it relates to taxable value, that 

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

7. 

The 2025 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; 

(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 frue 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 

adopted 

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 

2025 

taxable 

value 

of 

Petitioner's 

Property from 

$612,300 

to 

$300,000, 

and 

reducing 

the 

2025 

assessed 

and 

state 

equalized 

values 

of 

Petitioner's Property from $612,300 to $300,000 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 

pr 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

By: 

Dated: May 28, 2025

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