MTA - 25-001896 - FSB - IM.pdf
Flagstar Bank Na, Petitioner Vs. City Of Iron Mountain, Respondent · 25-001896-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL FLAGSTAR BANK, N.A., Petitioner, v. MTT Docket No. 25-001896 CITY OF IRON MOUNTAIN, Respondent. Parcel: 051-104-811-00 / Law Office of Aaron M. Fales, Attorneys for Petitioner Aaron Fales (P72864) 330 Hamilton Row, Suite 350 Birmingham, MI 48009 (248) 767-9840 aaron@afaleslaw.com City of Iron Mountain Abbey Simondsen - Assessor 501 South Stevenson Hwy. Iron Mountain, MI 49801 906-774-8530 assessor@ironmountainmi.gov / MOTION TO AMEND PETITION TO CONTEST 2026 ASSESSED AND TAXABLE VALUES PETITIONER, by and through its attorney, Law Office of Aaron M. Fales, P.C., moves to amend the Petition in this matter to include the following: 1. In 2026, Respondent determined the following values: True Cash Value Assessed and State Equalized Value Taxable Value $2,072,800 $1,036,400 $750,450 2. The 2026 assessment, including state equalized value and taxable value, imposed on Petitioner’s Property, and the taxes to be levied and collected
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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, exceed the amounts 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 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 adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Petitioner moves that this Motion to Amend be granted, and Petitioner requests that the Tribunal enter an Order reducing the values to the following: True Cash Value Assessed and State Equalized Value Taxable Value $800,000 $400,000 $400,000 and requiring that Respondent pay to Petitioner the refunds attributable to such reductions, plus interest and costs.
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_________________ Respectfully submitted, LAW OFFICE OF AARON M. FALES, P.C. Attorney for Petitioner By: _ Aaron Fales 330 Hamilton Row, Suite 350 Birmingham, MI 48009 (248) 767-9840 Dated: 5/24/26 PROOF OF SERVICE STATE OF MICHIGAN ) ) ss. COUNTY OF OAKLAND ) Aaron M. Fales, being duly sworn, deposes and says that on May 24, 2026 he served a copy of Petitioner’s Motion to Amend on the Respondent. Aaron M. Fales