Eagle Pickard MTT appeal docket # 26-000987.pdf

Eagle Pickard LLC Petitioner Vs. Township Of Union Respondent · 26-000987-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

MOAHR DOCKET NO. 26-000987 

Charter Township of Union 

Jill Peters 

Union Township Assessor 

2010 S Lincoln Rd. 

Mount Pleasant, MI. 48858 

MOAHR Docket No. # 26-000987 

Eagle Pickard LLC v Township of Union 

VIA ELECTRONIC FILING 

Samantha M Welton, Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI. 48909 

August 4, 2026 

Dear Ms. Welton: 

Enclosed for filing, please find the Respondent's Answer to Petition and Proof of Service in the 

above referenced matter. 

Sincerely, 

Oil 

Jill 

Peters, Michigan Advanced Assessment Officer 

Union Charter Township Assessor-Isabella County

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRAIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

Eagle Pickard LLC 

Petitioner 

MOAHR DOCKET NO. 26-000987 

Vs. 

PARCEL NO. 14-011-40-013-01 

Union Township- Isabella 

Respondent 

RESPONSE TO PETITION 

The Union Township ("Respondent") states in response to Eagle Pickard LLC, 

(“Petitioner”) filed petition dated May 14, 2026, the following: 

1. 

In response to statement #1, Respondent agrees to the identification of Petitioner and 

situs of subject property. The Petitioner did not identify the type of interest held in 

subject property. 

2. 

Inresponse to statement #2, Respondent agrees. 

3. 

Inresponse to statement #3, Respondent confirms taxes are collected by Union 

Township. 

4. 

In response to statement #4, Respondent agrees. The property is used for commercial 

purposes. The property under appeal is classified as Commercial Real on the 2026 

assessment roll.

8. 

9. 

In response to statement #5. True- Petitioner is not required to attend Board of Review 

In response to statement #6. Respondent agrees with address of subject property. 

Respondent denies statement #7. 

Petitioners have not provided proof of market 

value or uniformity. 

In response to statement #8, Respondent agrees with year of appeal. 

Agrees with valuation summary 

10. Respondent neither agrees nor denies. Petitioners have not proven the market value of the 

property; therefore, the statement of discrimination or uniformity is unsubstantiated. 

11. Petitioners are required to provide data to support their determination of Market value. 

12. Respondent agrees with the amount of contention. 

13. Respondent disagrees with statements made. 

In further response, the assessed, state equalized, and taxable values do not exceed 

permitted amounts, does not exceed the percentage for true cash value permitted by 

law, were correctly determined and are based upon the correct application of property 

principals, and do not discriminate against Petitioner. 

The Petitioner is not entitled to the relief requested since the Petitioner's amounts do 

not reflect an accurate valuation of the property. The Petitioner's opinion of value as 

stated in the filed petition is drastically underestimated. The assessed, state equalized, 

and taxable values do not exceed permitted amounts, do not exceed the percentage 

for true cash value permitted by law, were correctly determined and are based upon 

the correct application of proper principles. The Respondent's certified assessment is 

non-discriminatory and constitutional.

AFFIRMATIVE DENFENSES 

Respondent states that it may rely on one or all the following Affirmative Defenses: 

1. 

The subject property was assessed using appropriate methods which align with 

the valuation methods applied to similarly situated property in the Union Township, 

Isabella County. The current method used to value subject is based on a modified 

cost approach minus depreciation plus land value and land improvements. The 

Petitioner has not provided the Assessor with income or lease information to utilize the 

income approach. The sales approach may not be suitable because of the absence of 

going - concern sales. 

2. 

Petitioner has failed to state a claim upon which relief can be granted (MCR 

2.116(C)(4) and (8)), including on, but not necessarily limited to, the following grounds: 

a. 

The Petitioner does not comply with the Tax Tribunal Rules TTR 

227(1) and (2)(f). 

b. 

The Petitioner provides no factual basis to determine the Tribunal's 

Tah 

subject matter jurisdiction or "petitioner's" standing. 

c. 

The Petitioner provides no factual basis to determine that 

the assessment is incorrect. 

d. 

The Petitioner provides no factual basis to support the claim for 

reducing the assessed value. 

e. 

The Petitioner fails to provide any factual grounds for seeking relief. 

3. 

Petitioner may not be proper party-in-interest. MCR 2.116(C)(4), (5) and (8). The 

verification of Fee simple ownership is pending. 

4. 

Petitioners may not have the standing to appeal. MCR 2.116(C)(4), (5) and (8).

5. 

Regarding this appeal, the tribunal's subject matter jurisdiction may be in question. 

MCR 2.116(C)(4) and (8). 

6. 

Regarding the Petitioner, there may have been a failure to comply with state property 

tax law. This includes not fully reporting assessable property, both real and personal, 

resulting in delinquent or underpaid property taxes. Consequently, the Petitioner is 

barred from appealing its property values; and the Respondent should be entitled to 

damages. 

7. 

Respondent reserves the right to add additional affirmative defenses as they become 

known to it through discovery in this matter. 

WHEREFORE, Respondent requests that the Tribunal affirm the assessed and taxable 

values as determined by Respondent, dismiss the Petition, and award Respondent its 

costs and attorney fees and any other relief that the Tribunal determines is fair, just, and 

equitable. 

Respectfully sub 

By: De: re 

Jill Peters, Michigan Advanced Assessment Officer 

Union Charter Township Assessor-Isabella County 

Date: 

August 4, 2026

ADDITIONAL NOTES 

MTT DOCKET; 26-000987 

August 4, 2026 

Proof Of Service 

On the date below 

| sent a copy of the foregoing answer to Eagle Pickard LLC Entire Tax Tribunal 

appeal. 

Township Clerk 

County Clerk 

Charter Township of Union 

Isabella County 

2010 S Lincoln rd. 

510 W Pickard 

Mount Pleasant, MI 48858 

Mount Pleasant, Ml. 48858 

Director of Equalization 

Secretary of the School Board 

Isabella County 

Mount Pleasant Public Schools 

510 W Pickard St. 

720 N Kinney 

Mount Pleasant, Ml. 48858 

Mt. Pleasant, MI 48858 

State of Michigan 

COLLIERS INTERNATIONAL 

State Treasurer 

Joshua T Shillair 

430 W Allegan 

Representative for Petitioner 

Lansing, MI 48922 

| declare that the Statement above is true to the best of my Information, knowledge and belief. 

a 

NA 

TD 

Dated: FF Frid 

CL Jodo hy 

Jill Peters: MAA, Assessor

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN 

OFFICE OF ADMINISTRAIVE HEARINGS AND RULES MICHIGAN TAX 

TRIBUNAL 

MOAHR DOCKET NO. 26-000987 PARCEL NO. 14-011-40-013-01 

PROOF OF SERVICE 

Jill Peters, Union Township Assessor states that on August 4, 2026, she served a copy of 

RESPONSE TO PETITION relative to the above-captioned matter upon: 

Colliers International 

Representative for Petitioner 

Joshua T Shillair, ESQ 

400 E 4 ST. Suite 350 

Royal Oak, MI. 48067 

Joshua Shillair@Colliers.com 

No submitted 

. 

HF 

Jill 

Péters, Michigan Advanced Assessment Officer Union 

Charter Township Assessor-Isabella County 

Date: August 4, 2026

← View full record