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REO Fundit 3 Asset, LLC - Delta Charter Township 25-002075.pdf

Reo Fundit 3 Asset LLC, Petitioner Vs. Township Of Delta, Respondent · 25-002075-TT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

REO FUNDIT 3 ASSET, LLC, 

Petitioner, 

MTT DOCKET NO.25-002075-TT 

Delta Charter Township, 

Respondent. 

PROOF OF SERVICE 

Michelle (Mikki) M. Silvey, being first duly sworn, deposes and says that on the 16%" day of 

September 2025 she served a copy of the Petition upon the following persons by placing 

same in an envelope properly addressed to each via USPS first class thereon: 

Diana Bosworth 

Waverly Community Schools 

Eaton County Clerk 

Vince Perkins, School Board Secretary 

1045 Independence Boulevard 

515 Snow Rd 

Charlotte, MI 48813 

Lansing, MI 48917 

Tim Vandermark 

Michigan State Treasurer 

Eaton County Equalization Director 

Department of Treasury 

1045 Independence Boulevard Room 150 

Treasury Building 

Charlotte, MI 48813 

430 West Allegan 

Lansing, MI 48922 

Mice (0 re) 

Michelle (Mikki) M. Silvey (P69494) 

Authorized Agent

Page 2

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

REO FUNDIT 3 ASSET, LLC, 

Petitioner, 

MTT DOCKET NO.25-002075-TT 

Delta Charter Township, 

Respondent. 

PROOF OF SERVICE 

Michelle (Mikki) M. Silvey, being first duly sworn, deposes and says that on the 16% day of 

September 2025 she served a copy of the Petition upon the following persons by placing 

same in an envelope properly addressed to each via certified mail thereon: 

Ted Droste 

Fonda J. Brewer 

Delta Charter Township Assessor 

Delta Charter Township Supervisor 

7710 West Saginaw Hwy. 

7710 West Saginaw Hwy. 

Lansing, MI 48917 

Lansing, MI 48917 

Mary R. Clark 

Delta Charter Township Clerk 

7710 West Saginaw Hwy. 

Lansing, MI 48917 

Mics (0 Sg 

Michelle (Mikki) M. Silvey (P69494) 

Authorized Agent

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

REO FUNDIT 3 ASSET, LLC 

5 

MTT Docket No. 25-002075 

 -TT 

Petitioner, 

v 

Delta Charter Township 

Respondent. 

Michelle (Mikki) M. Silvey (P69494) 

Alex Morse 

DuCharme, McMillen & Associates, Inc. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 689-6467-ofc 

(917) 488-7825-mobile 

msilvey@dmainc.com 

amorse@dmainc.com 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No.: 040-014-200-015-01 

2. 

The property identified above is real 

. 

3. 

Only one parcel of property is the subject of this appeal. 

4. 

Petitioner owns and/or otherwise holds an interest in the parcel of property that is the 

subject of this appeal.

Page 4

MTT Docket No. 25-002075 

TT 

Page 2 of 3 

5. 

The property identified above is classified as 201 Commercial Improved 

6. 

The assessment(s) at issue were not protested to Respondents March, July, or December 

Board of Review as a protest was not required. 

7. 

The property or properties at issue are in Eaton 

County. 

8. 

The property or properties” address is: 

5625 W Saginaw Hwy, Lansing, MI 48917 

. 

9. 

The assessment(s) at issue were established by the: Delta Charter Township 

10. Petitioner’s legal residence or principal office address is: 

19790 W Dixie Hwy, Ste 902, Miami, FL 33180 

11. This appeal involves issues relating to the property or properties’ true cash and taxable 

values and uniformity. 

12. The tax year at issue is: 2025. 

13. The values for the property identified above as established by Respondent’s 2025 Board 

of Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$7,471,200 

$3,735,600 

$3,735,600 

14. Petitioner contends the values for tax year 2025 are no more than the following: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2025 

$4,480,000 

$2,240,000 

$2,240,000 

15. The values in contention for tax year 2025 are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2025 

$2,991,200 

$1,495,600 

$1,495,600

Page 5

MTT Docket No. 25-002075 

TT 

Page 3 of 3 

16. The 2025 assessments imposed on the subject property and the taxes to be levied and 

collected are invalid because: 

(a) The assessment, including state equalized and/or taxable value, exceeds the amount 

permitted by the Michigan Constitution and applicable statutes; 

(b) The assessment, including state equalized and/or taxable value, is at a higher 

percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) The assessment is based on the misapplication of valuation principles, and 

(d) The assessment otherwise violates Petitioner’s rights. 

WHEREFORE, Petitioner respectfully requests this honorable Tribunal hear this case 

and enter an order reducing the 2025 true cash, state equalized and taxable values and direct 

Respondent to refund to Petitioner any excess taxes, fees, and penalties paid, plus interest and 

costs, and all other relief to which it is entitled under Michigan law and as is appropriate under 

the circumstances. 

Respectfully submitted, 

DuCharme, McMillen & Associates, Inc. 

Mic (0 ve) 

Dated: May 31 , 2025 

By: 

Michelle (Mikki) M. Silvey (P69494) 

Petitioner's Representative

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