MTT_Docket_26-001405_Amended_Petition copy.pdf
Mohamed Mansour Petitioner Vs. Township Of Mt Morris Respondent · 26-001405-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL AMENDED PROPERTY TAX PETITION Mohamed Mansour, Petitioner MTT Docket No. 26-001405 v. City of Mt Morris, Respondent 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 T8N R6E 1.20 A 2. Tax Year and Assessment Information Tax Year(s) Appealed: 2026 [CONFIRM IF OTHER YEARS ARE ALSO AT ISSUE] 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 Respondent’s 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. 5. Petitioner disputes the assessment and seeks review by the Michigan Tax Tribunal. 6. Petitioner relies on the evidence and documentation submitted with this petition and reserves the right to supplement the factual and legal basis of the appeal as permitted by the Tribunal’s rules and orders. Petitioner believes that, given the property's current physical and development limitations, including the drain, likely easement, floodway, floodplain, possible wetlands, and setbacks, the property would be extremely difficult to sell even at a price of $1,400 in its present condition. Petitioner states that the property was offered for sale for $14,999 on September 12, 2024, but did not sell at that asking price. Petitioner acquired the property for $1,400.
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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 easement, 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, CFM, Associate / Project Manager with ROWE Professional Services 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 September 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 September 12, 2024, under MLS/Realcomp II listing number 20240018943. Zillow currently identifies the property as off market and reports the lot size as 1.20 acres. Petitioner submits the auction receipt as direct documentary evidence of the property's acquisition price and requests that the Tribunal consider the $1,400.00 winning bid, together with the property's subsequent unsuccessful marketing at $14,999 and the documented physical development constraints, in evaluating the property's true cash value. The same receipt separately lists a $30.00 deed fee, a $140.00 buyer's premium, and $464.98 in summer tax for Lot 8405. Accordingly, the $1,400.00 figure is the winning bid amount, not necessarily the total amount paid for all costs associated with acquiring the parcel.
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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. 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. 7. Petitioner Information Name: Mohamed Mansour Legal Residence / Mailing Address: 3507 Sunset Dr, Flint, MI 48503 Telephone: 4076203003 Email: DRLOVETHEFIRST@yahoo.com 8. Signature I declare that the information stated in this petition is true to the best of my knowledge, information, and belief.
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____________________________________ ____________________________________ Mohamed Mansour, Petitioner Date IMPORTANT FILING NOTE The Tribunal’s Order of Default entered August 11, 2026 states that Petitioner must file a petition within 14 days of entry of the order and must note MTT Docket No. 26-001405. If submitted through the Tribunal’s e- filing system, the Tribunal’s order states that it should be filed on the assigned docket number as an “amended petition.” Supporting evidence should be attached as available.
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EXHIBIT D — FLOODPLAIN / FLOODWAY GIS MAP Parcel 14-33-100-011 — 3502 N Linden Rd, Flint, MI 48504
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8:14 all = € 14-33-100-011 Wetl... + X 0D) 10f1 Genesee County GIS
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Genesee County GIS map supplied by Petitioner. The map depicts the parcel and the mapped floodplain/floodway areas.
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EXHIBIT E — WETLANDS GIS MAP Parcel 14-33-100-011 — 3502 N Linden Rd, Flint, MI 48504
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8:14 ol = € 34 J 14-33-100-011Floo... + X Genesee County GIS powered by FetchGIS
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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.