3459 Miller, LLC Petitioner Vs. Township Of Flint Respondent

Page 1

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 

3459 Miller LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000694 

 

Flint Township, 

 

Presiding Judge 

Respondent. 

 

Joshua M. Wease 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has considered the file in this case and the submitted Stipulation for Entry 

of Consent Judgment (Stipulation) and finds that the Stipulation meets all filing and 

statutory requirements.1 As such, the Tribunal shall enter the Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 26-000694 

Page 2 of 2 

 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

(xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%, and (xx) after 

July 1, 2026, through December 31, 2026, at a rate of 7.85%. 

 

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

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

Entered: August 20, 2026 

 

 

 

By: /s/ Joshua M. Wease 

jc 

 

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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

3459 Miller, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26-000694 

 

Petitioner, 

 

 

 

 

 

Parcel No. 07-27-100-021 

 

v. 

 

Charter Township of Flint, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Paula Dotson, Assessor 

CHARTER TOWNSHIP OF FLINT 

1490 S. Dye Road 

Flint, MI 48532 

(810) 600-3227 

Authorized Representative for 

Respondent 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Stipulation for Entry of Consent Judgment 

 

1. 

This appeal is pending in the Entire Tribunal Division. 

 

2. 

The subject property in this appeal is identified as Parcel No. 07-27-

100-021 and is commonly known as 3459 Miller Road, Flint Township, Michigan 

48532 (the “Subject Property”). 

3. 

The values for the Subject Property established by Respondent’s March 

Board of Review are as follows: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

 $1,310,000 

 $655,000 

 $646,207 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner

Page 2

Page 2 

4. 

The values for the Subject Property stipulated by the parties for 

settlement purposes are as follows: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

 $900,000 

 $450,000 

 $450,000 

 

5. 

Special terms and conditions: All refunds shall be issued payable 

jointly to Petitioner and WWRP, P.C., and shall be delivered to Petitioner’s 

attorneys as follows: Williams, Williams, Rattner & Plunkett, P.C., Attn: Jerome P. 

Pesick, 380 N. Old Woodward Avenue, Suite 300, Birmingham, MI 48009. 

Wherefore, the parties respectfully request that this honorable Tribunal 

enter a Consent Judgment revising the Subject Property’s 2025 property tax 

assessment consistent with the values set forth in this Stipulation. 

 

 

 /s/ Jerome P. Pesick 

 

 

Jerome P. Pesick (P29039) 

Attorney for Petitioner 

 

 

 /s/ Paula Dotson 

 

 

 

 

 

Paula Dotson 

Assessor for Respondent 

 

 

Dated: August 12, 2026

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Page 1

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000694

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Joint

Files

Document Type: Stip for Consent Judgment

Attachment File Name: Stipulation for Entry of Consent Judgment

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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Page 1

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

NOTICE OF JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

3459 Miller, LLC,

Petitioner,

v

 

 

Township of Flint,

Respondent.

 MTT Docket No. 26-000694

Please be advised that 26-000694 has been placed on a two-week Prehearing General 

Call commencing July 01, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 26-000694

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by March 4, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by March 4, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 4, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

July 1, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 3, 2026

Page 3

MTT Docket No. 26-000694

Page 3 of 3

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,

Page 4

S

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Page 1

RECEIVED 

JUL 07 2005 

CHARTER TOWNSHIP OF FLINT 

Assessment Division 

MICHIGAN TAX TRIBUNAL 

Willan Foer, 

14508. Dye Road 

Po (410) 732.0386 

— Cy 

Flint, Michigan 48532 

assessingdept@flinttownship.org 

July 1, 2026 

Office of the Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

MTT Docket No.: 26-000694 

3459 Miller LLC v Township of Flint 

Parcel: 07-27-100-021 

Dear Honorable Michigan Tax Tribunal: 

Enclosed for filing, please find Respondent’s Reply to Petitioner’s Petition (in the Entire 

Tribunal) and Respondent’s Proof of Service. 

espectfully submitted, 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

3459 Miller LLC 

MTT Docket No.: 26-000694 

Parcel 07-27-100-021 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

Jason Long & Jerome Pesick 

Paula Dotson 

Williams, Williams, Rattner & Plunkett 

Deputy Assessor, Charter Township of Flint 

380 N. Old Woodward Ave., Ste. 300 

1490 S. Dye Road 

Birmingham, MI 48009 

Flint, M1 48532 

248.642.0333 

810.600.3227 

RESPONDENT’S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2026 

ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) 

Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy 

Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 

1. 

Respondent neither admits nor denies the statements and 

or allegations 

set forth 

in 

paragraph 

1 of Petitioner’s Petition as it does not have sufficient information to form a 

belief as to the truth of the allegations. 

2. 

Respondent admits the statements and or allegations set forth in paragraph 2 of Petitioner’s 

Petition. 

3. 

Respondent admits the statements and or allegations set forth in paragraph 3 of Petitioner’s 

Petition.

Page 3

10. 

11. 

12. 

MTT Docket No. 26-000694 

Respondent admits the statements and or allegations set forth in paragraph 6 of Petitioner’s 

Petition. 

Respondent admits the statements and or allegations set forth in paragraph 7 of Petitioner’s 

Petition. 

Respondent neither admits nor denies the statements and or allegations set forth in paragraph 

8 of Petitioner’s Petition as said paragraph is merely the opportunity for Petitioner to set 

forth its opinion of value. 

Respondent neither admits nor denies the statements and or allegations set forth in paragraph 

9 of Petitioner’s Petition said paragraph is merely the mathematical calculation of the 

difference between Respondent’s valuations and Petitioner’s contention of value. 

Respondent neither admits nor denies the statements and or allegations set forth in paragraph 

10 of Petitioner’s as said paragraph does not have sufficient information to form a belief as 

to the truth of the allegations. 

Respondent denies the statements or allegations set forth in paragraph 11 of Petitioner’s 

Petition for the reason they are not true. 

Respondent acknowledges the statements or allegations set forth in paragraph 12 of 

Petitioner’s Petition. 

Wherefore Respondent requests the relief and actions requested by Petitioner be denied. 

Respondent leaves Petitioner to meeting its required burden of proof. 

Respondent’s Response submitted on this date, 

July 1, 2026, by: 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

3459 Miller LLC 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

MTT DOCKET NO.: 26-000694 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

GENESEE COUNTY) 

THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on 

July 1, 2026, she caused to be served upon: 

Jason Long & Jerome Pesick 

Michigan Tax Tribunal 

Williams, Williams, Rattner & Plunkett 

PO Box 30232 

380 N. Old Woodward Ave., Ste. 300 

Lansing, Michigan 48909 

Birmingham, MI 48009 

by enclosing the same in an envelope, plainly addressed to said party at the above address, with 

lawful United States first class postage affixed thereon and by placing same in the United States 

mail. 

July 1,2026 

Nr 

la Aor 

Date 

Paula Dotson 

Deputy Assessor

Page 5

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

3459 Miller, LLC, 

Docket No. 26-000694 

Petitioner, 

Parcel No. 07-27-100-021 

v. 

Township of Flint, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, Notice of Docket Number, and this Proof of Service, on the 

persons listed below, by the means identified below, by placing those documents in 

duly stamped, addressed envelopes, and placing the envelopes in the United States 

mail on June 11, 2026. 

PERSONS SERVED: 

Certified Mail 

First Class Mail 

Clerk 

Clerk 

Secretary of School Board 

Charter Township of 

Genesee County 

Carman-Ainsworth Community 

Flint 

1101 Beach St. 

Schools 

1490 S Dye Rd 

Flint, MI 48502 

G-3475 W. Court Street 

Flint, MI 48532 

Flint, MI 48532 

Assessor 

Director of 

State Treasurer 

Charter Township of 

Equalization 

Michigan Department of 

Flint 

Genesee County 

Treasury 

1490 S. Dye Rd. 

1101 Beach Street 

Austin Building 

Flint, MI 48532 

Room 206, Flint, MI 

430 W. Allegan 

48502-1468 

Lansing, MI 

4 

< 

Monica Athanas

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Page 1

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000694

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: 3459 POS - Petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

3459 Miller, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 07-27-100-021 

 

v. 

 

Township of Flint, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner 3459 Miller, LLC, by and through its attorneys, Williams, Williams, 

Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax 

Petition. 

The Parties 

1. 

Petitioner 3459 Miller, LLC is a Michigan limited liability company with 

its principal place of business in Michigan located at 4143 Lindow Drive, Sterling 

Heights, Michigan 48310. 

2. 

Respondent Township of Flint is a Michigan township with its principal

Page 2

offices located at 1490 S. Dye Road, Flint, MI 48532. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 07-27-100-021 and 

commonly known as 3459 Miller Road, Flint, Michigan 48507 (the “Subject 

Property”). 

4. 

The Subject Property is located in Genesee County and is within the 

Carman-Ainsworth School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,310,000 

 655,000 

 646,207 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 800,000 

 400,000 

 400,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 510,000 

 255,000 

 246,207

Page 3

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

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Page 1

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

3459 Miller, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000694

Township of Flint, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: June 2, 2026

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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

3459 Miller, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 07-27-100-021 

 

v. 

 

Township of Flint, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner 3459 Miller, LLC, by and through its attorneys, Williams, Williams, 

Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax 

Petition. 

The Parties 

1. 

Petitioner 3459 Miller, LLC is a Michigan limited liability company with 

its principal place of business in Michigan located at 4143 Lindow Drive, Sterling 

Heights, Michigan 48310. 

2. 

Respondent Township of Flint is a Michigan township with its principal

Page 2

offices located at 1490 S. Dye Road, Flint, MI 48532. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 07-27-100-021 and 

commonly known as 3459 Miller Road, Flint, Michigan 48507 (the “Subject 

Property”). 

4. 

The Subject Property is located in Genesee County and is within the 

Carman-Ainsworth School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,310,000 

 655,000 

 646,207 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 800,000 

 400,000 

 400,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 510,000 

 255,000 

 246,207

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10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

3459 Miller, LLC

Home Address (No., Street, P.O. Box or Rural Route)

4143 Lindow Drive 

City or Town

Sterling Heights

State

Michigan

ZIP Code

48310

Telephone Number

248-642-0333

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

jpesick@wwrplaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Address (No., Street, P.O. Box or Rural Route)

380 N Old Woodward Ave

Suite 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-642-0333

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

jpesick@wwrplaw.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

1490 S. Dye Road

Flint

Michigan

48532

Taxing Authority (City or Township)

Township of Flint (GENESEE)

County

Genesee

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

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STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

07-27-100-021

Classification of Property: Real 

Commercial

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

655000

Current Taxable Value as established by the Board of Review:

646207

What do you believe is the fair market value (also known as True Cash Value)?

800000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

400000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest 

State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jerome P. Pesick

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.