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25-002569 Dismiss (untimely-Valuation).pdf

Toni Zhang, Petitioner V City Of Ann Arbor, Respondent · 25-002569-TT

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STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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 

Toni Zhang, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 25-002569 

 

City Of Ann Arbor, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner’s appeal. Petitioner, appealing the true cash and taxable values for Parcel 

No. 09-09-15-104-105 for the 2024 and 2025 tax years, was held in default on August 

12, 2025, for failing to file a copy of the notice giving rise to the appeal, i.e. Board of 

Review (BOR) results. On August 19, 2025, Petitioner filed a response, however their 

attempt to cure was incomplete because Petitioner filed a copy of the 2024 BOR results 

but failed to include a copy of the 2025 BOR results. 

 

On August 29, 2025, Respondent filed an answer stating Petitioner failed to protest the 

disputed assessment for the subject property at the 2025 March BOR. 

 

Thus, the Tribunal finds it has no authority over the 2024 assessment. In accordance 

with MCL 205.735a(6), “[t]he jurisdiction of the tribunal in an assessment dispute as. . . 

residential property. . . is invoked by a party in interest, as petitioner, filing a written 

petition on or before July 31 of the tax year involved.” Here, Petitioner is appealing 

assessments for the 2024 and 2025 tax years, and the Tribunal has no authority over 

the 2024 assessment as the petition was not filed until June 30, 2025. 

 

Moreover, Petitioner failed to protest the disputed assessments to the 2025 March 

BOR. As specified in Sixarp LLC v Byron Twp,1 “[b]ecause Praxis failed to file a timely 

protest before the Board as required by MCL 205.735a(3), the MTT did not have 

jurisdiction to hear Praxis's claim.” Further, “[t]he MTT correctly explained that ‘because 

the Tribunal has no equitable power to waive or otherwise disregard a statutory 

requirement or filing deadline, it has no authority to grant Praxis's exemption request.’”2 

Additionally, the Tribunal has no authority under MCL 211.53a because the facts 

alleged do not establish that the assessments were the result of a clerical error (i.e., “an 

error of a transpositional, typographical, or mathematical nature”) or a mutual mistake of 

fact (i.e., “an erroneous belief, which is shared and relied on by both parties”). And 

though MCL 211.53b provides July and December boards of review with the authority to 

correct qualified errors, Petitioner did not appear before Respondent’s July or 

 

1 Sixarp LLC v Byron Twp___Mich___;___NW3d___(2025). 

2 Id.

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MTT Docket No. 25-002569 

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December BOR or appeal an action taken by any such board. As such, and inasmuch 

as the Tribunal has no equitable power to waive or otherwise disregard a statutory 

requirement or filing deadline, it has no authority to grant Petitioner the relief 

requested.3 

 

Therefore, 

 

IT IS ORDERED that the case is DISMISSED. 

 

This order resolves all pending claims in this matter and closes this case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal. 

 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

 

 

 

Entered: September 9, 2025 

 

 

By _____________________________ 

kac/jcr 

 

 

 

3 The Tribunal’s powers are limited to those authorized by statute and do not include powers of equity. 

See Federal-Mogul Corp v Dep’t of Treasury, 161 Mich App 346 (1987), Elec Data Sys Corp v Flint Twp, 

253 Mich App 538 (2002), and VanderWerp v Plainfield Twp, 278 Mich App 624 (2008).

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MTT Docket No. 25-002569 

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PROOF OF SERVICE 

 

I 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

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