B & S Holding LLC, Petitioner Vs. City Of Muskegon, Respondent
- Petitioner
- B & S Holding LLC
- Respondent
- City Of Muskegon
Case overview
- Docket number
- 25-001869-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Muskegon
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 14 | Order of Dismissal | Not recorded | Not recorded | 05/13/2026 | Not recorded | Download |
| 13 | Notice of Filing of Motion to Withdraw | Not recorded | Not recorded | 05/07/2026 | Not recorded | Download |
| 12 | Motion to Withdraw Appeal was received. | PET | Not recorded | 04/27/2026 | $0.00 | Download |
| 11 | Proof of Service of Misc Documents was received. | RESP | Not recorded | 04/24/2026 | Not recorded | Download |
| 10 | Prehearing General Call | Not recorded | Not recorded | 01/02/2026 | Not recorded | Download |
| 9 | Order Setting Aside P Default | Not recorded | Not recorded | 11/07/2025 | Not recorded | Download |
| 8 | Proof of service of petition was received. | PET | Not recorded | 09/24/2025 | Not recorded | Download |
| 7 | Order Holding Party in Default | Not recorded | Not recorded | 09/24/2025 | Not recorded | Download |
| 6 | Answer was received | RESP | Not recorded | 07/11/2025 | Not recorded | Download |
| 5 | Petition has been verified | PET | 2 | 07/28/2025 | Not recorded | Download |
| 4 | Notice of Docket Number ET | Not recorded | Not recorded | 07/28/2025 | Not recorded | Download |
| 3 | Attachments to the Petition were filed | PET | Not recorded | 05/30/2025 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 05/30/2025 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 05/30/2025 | $650.00 | Download |
Documents
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner has filed a Motion to Withdraw the Petition and Respondent has not filed an objection to the requested withdrawal. Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending issues and closes the 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
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MTT Docket No. 25-001869 Page 2 of 2 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. By:___________________________________ Patricia L. Halm, Tribunal Chair Entered: May 13, 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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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner has filed a Motion to Withdraw the Petition and Respondent has not filed an objection to the requested withdrawal. Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending issues and closes the 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
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M
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above- captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or representatives), Respondent has seven days from the service of the motion to file a response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of the case or by objecting to the motion. If Respondent does not timely submit a concurrence or objection to the request, it will be deemed to be a concurrence and the request will be granted, unless otherwise ordered by the Tribunal. If the request is granted, the case will be dismissed. If a request is not granted or the Tribunal has not notified you that it has been granted, you are required to attend the hearing. For your convenience, you may use the Tribunal’s form “Response to Motion to Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small Claims” page, depending on the division in which the case is pending. To submit the response, please fill out the form and file it with the Tribunal by e-mail or e-filing.1 By: Tribunal Clerk__________ Entered: May 7, 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 1 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the efficient administration of justice.
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above- captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or representatives), Respondent has seven days from the service of the motion to file a response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of the case or by objecting to the motion. If Respondent does not timely submit a concurrence or objection to the request, it will be deemed to be a concurrence and the request will be granted, unless otherwise ordered by the Tribunal. If the request is granted, the case will be dismissed. If a request is not granted or the Tribunal has not notified you that it has been granted, you are required to attend the hearing. For your convenience, you may use the Tribunal’s form “Response to Motion to Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small Claims” page, depending on the division in which the case is pending. To submit the response, please fill out the form and file it with the Tribunal by e-mail or e-filing.2 By: Tribunal Clerk__________ Entered: May 7, 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 2 Though you may file the response by hard copy
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FLANAGAN |BILTON LLC NS Nationwide Property Tax Law Firm SENT VIA FEDEX MICHIGAN TAX TRIBUNAL PO BOX 30232 LANSING, MI 48906 RE: B&S HOLDING LLC MTT DOCKET NO: 25-001869 Michigan Tax Tribunal, The purpose of this letter to submit our Motion To Withdraw for the abovementioned case. Please mail any further notices regarding this appeal of the subject property to: Flanagan Bilton LLC, 1 North LaSalle St, Ste 2100, Chicago, IL 60602. Please feel free to contact me with questions, comments, or requests for additional information Sincerely, Huan Cassioppi Tran
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON |. BROWN, DPA GOVERNOR LANSING DIRECTOR B &S HOLDING LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No.25-001869 CITY OF MUSKEGON Respondent(s) MOTION TO WITHDRAW APPEAL 1. 1 wish to withdraw my appeal in the above-captioned docket. 2. Good cause exists to grant withdrawal because: The referenced Docket No. is a duplicate filing. 3. l ask this Tribunal to grant my request to withdraw the appeal and dismiss the above- captioned docket. Please select one of the following: __ lam filing this Motion to Withdraw before Respondent filed an Answer or a responsive motion with the Tribunal. x_ lam filing this Motion to Withdraw after Respondent has filed an Answer or Responsive Motion with the Tribunal. | attached to this Motion Respondent's written consent to withdraw my petition, ° shall grant Respondent the opportunity to object to this withdrawal. Pa pat i Huan Cassioppi Tran Party/Represeriative (sign here) Print name of person signing
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&B STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR B & S HOLDING LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No.25-001869 CITY OF MUSKEGON , Respondent(s) PROOF OF SERVICE JENNY POLENISIAK states that on 4/27/2026 he/she [Name of person serving/mailing petition] [date of service] served a copy of the MOTION TO WD relative to the above-captioned matter upon: [Provide name and address of the party/people being served] BRENNEN J. GORMAN (P80958) 601 Terrace Street, PO Box 786 Muskegon, MI 49440 Jenny Polenisial [Signature of person who is serving/mailing copyl
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RECEIVED Visit 801 Terrace Street, Muskegon, MI 48440 PARMENTER :escemeion R24 0 LAW MICHIGAN Tax TRIBUNAL J April 22,2026 Michigan Tax Tribunal SENT VIA MAIL P.0. Box 30232 Lansing, MI 48909 Re: B &SHOLDING LLC v. CITY OF MUSKEGON MTT Docket No. 25-001869 Dear Clerk: Enclosed for filing please find: 1. Proof of Service for Respondent's First Interrogatories and Request for Production of Documents to Petitioner Should you have any questions or require additional information please do not hesitate to contact our office, Thank you. Very truly yours, fort Ot olessn) Taylor Anderson Legal Assistant Direct P: (231) 722-5428 Direct F: (231) 722-5528 Email: taylor@parmenterlaw.com le Enclosure
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL * kk B & S HOLDING LLC, MTT Docket No. 25-001869 Petitioner, v CITY OF MUSKEGON, Respondent. / Huan Cassioppi Tran Brennen J. Gorman (P80958) FLANAGAN BILTON LLC PARMENTER LAW Authorized Representative for Petitioner Attorneys for Respondent 1 N LaSalle Street 601 Terrace Street, PO Box 786 Chicago, IL 60602 Muskegon, MI 49440-1192 (313) 782-5000 (231) 722-1621 susan.chun@fblax.com brennen@parmenterlaw.com / PROOF OF SERVICE The undersigned certifies that on this 22nd day of April 2026, Respondent’s First Set of Interrogatories and Request for Production of Documents to Petitioner and this Proof of Service were served upon the Authorized Representative for Petitioner, Huan Cassioppi Tran, at his address of record via First-Class Mail, and by transmitting the same electronically to the email address of listed above.
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PARMENTER LAW PO Box 786, Muskegon, MI 49443-0786 Michigan Tax Tribunal P.O. Box 30232 Lansing, M1 48909 -CLASS FIRST US POSTAGE ri § 0006232890 Received APR 24 2026 LARA
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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 NOTICE OF DECEMBER 1 - 14, 2026 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE B & S Holding LLC, Petitioner, v City Of Muskegon, Respondent. MTT Docket No. 25-001869 Please be advised that 25-001869 has been placed on a two-week Prehearing General Call commencing December 01, 2026. 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.
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MTT Docket No. 25-001869 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 August 4, 2026. 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 August 4, 2026. 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 August 4, 2026, 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
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MT
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER SETTING ASIDE DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that Petitioner was held in default on September 24, 2025, and the default has been timely cured. The documents curing the default can be reviewed through the docket search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the document link next to the line item entry for the documents. Therefore, IT IS ORDERED that the Default is SET ASIDE. By_________________________________ Patricia L. Halm, Tribunal Chair Entered: November 7, 2025 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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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER SETTING ASIDE DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that Petitioner was held in default on September 24, 2025, and the default has been timely cured. The documents curing the default can be reviewed through the docket search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the document link next to the line item entry for the documents. Therefore, IT IS ORDERED that the Default is SET ASIDE. By_________________________________ Patricia L. Halm, Tribunal Chair Entered: November 7, 2025 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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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR B & S HOLDING LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) Vv MTT Docket No. 25-001869 CITY OF MUSKEGON , Respondent(s) PROOF OF SERVICE FOR PROPERTY TAX PETITION *To be filed after the Tribunal issues the Notice of Docket Number* JENNY POLENISIAK states that on 06/05/2025 he/she [Name of person serving/mailing petition] [date of service] served a copy of the Petition relative to the above-captioned matter upon: [Provide name and address of the following entities] 1. Assessor (via certified mail): MUSKEGON ASSESSOR 933 TERRACE ST TRACKING #: 9402-6091-0515-6138-9715-24 MUSKEGON, MI 49440 2. City Clerk or Township Supervisor/Clerk (via certified mail). ATTN: ANN MEISCH 933 TERRACE ST TRACKING #: 9402-6091-0515-6627-5484-42 MUSKEGON, MI 49440 3. County Equalization Director (via first class mail or personal service): ATTN: DONNA VANDERVRIES 173 E APPLE AVE, STE 201 TRACKING #: 9402-6091-0515-6138-9762-77 MUSKEGON, MI 49442 4. County Clerk (via first class mail or personal service): ATTN: KAREN BUIE 1903 MARQUETTE AVE. STE A104 TRACKING #: 9402-6091-0515-6138-9766-35 MUSKEGON, NI 49442 5. Secretary of the local school board (via first class mail or personal service): ATTN: CYNTHIA BANKHEAD 35 S SHERIDAN DR TRACKING #: 9402-6091-0515-6627-5506-50 MUSKEGON, Mi 49442 6. State Treasurer (via first class mail): TRACKING #: 9402-6091-0515-6627-5510-60 Michigan Department of Treasury, State Treasurer 430 W. Allegan Lansing, MI 48922 JENNY POLENISIAK son who is serving/mailing copy] [Print/type name of person serving/mailing copy] 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
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner failed to file proof evidencing service of the petition. See TTR 227. The Tribunal finds that placing Petitioner in default, rather than dismissal of this case, may effectuate the efficient administration of this appeal. As such, Petitioner must submit the proof of service within 14 days of the entry of this order. Tribunal rules and information on Entire Tribunal petitions can be found on our website at www.michigan.gov/taxtrib. Therefore, IT IS ORDERED that Petitioner is HELD IN DEFAULT. IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated above, within 14 days of the entry of this order.i Failure to comply with this order will result in the defaulted party being required to file a motion to set aside the default (with appropriate filing fee). ) | ~ 7 » ™~ 2 ( By: \_/Q CLLLLAA o NEOTIYES Entered: September 24, 2025 Patricia L. Halm, Tribunal Chair PROOF OF SERVICE | 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 i “A submission by mail is considered filed on the date indicated by the United States Postal Service postmark on the envelope containing the submission. A submission without a postmark or with an illegible 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
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MTT Docket No. 25-001869 Page 2 of 2 postmark is considered filed on the date the submission is received by the tribunal. A submission by commercial delivery service is considered filed on the date the submission is given to the commercial service for delivery to the tribunal as indicated by the receipt date on the package containing the submission. A
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner failed to file proof evidencing service of the petition. See TTR 227. The Tribunal finds that placing Petitioner in default, rather than dismissal of this case, may effectuate the efficient administration of this appeal. As such, Petitioner must submit the proof of service within 14 days of the entry of this order. Tribunal rules and information on Entire Tribunal petitions can be found on our website at www.michigan.gov/taxtrib. Therefore, IT IS ORDERED that Petitioner is HELD IN DEFAULT. IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated above, within 14 days of the entry of this order.i Failure to comply with this order will result in the defaulted party being required to file a motion to set aside the default (with appropriate filing fee). By:_______________________________ Entered: September 24, 2025 Patricia L. Halm, Tribunal Chair 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 i “A submission by mail is considered filed on the date indicated by the United States Postal Service postmark on the envelope containing the submission. A submission without a postmark or with an illegible postmark is considered filed on the date the submission is received by the tribunal. A submission by
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MTT Docket No. 25-001869 Page 2 of 4 commercial delivery service is considered filed on the date the submission is given to the commercial service for delivery to the tribunal as indicated by the receipt date on the package containing the submission. A submission by personal service is considered filed on the date the submission is received. A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal act, MCL 205.735a.” TTR 225(5)
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-001869 City Of Muskegon, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner failed to file proof evidencing service of the petition. See TTR 227. The Tribunal finds that placing Petitioner in default, rather than dismissal of this case, may effectuate the efficient administration of this appeal. As such, Petitioner must submit the proof of service within 14 days of the entry of this order. Tribunal rules and information on Entire Tribunal petitions can be found on our website at www.michigan.gov/taxtrib. Therefore, IT IS ORDERED that Petitioner is HELD IN DEFAULT. IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated above, within 14 days of the entry of this order.ii Failure to comply with this order will result in the defaulted party being required to file a motion to set aside the default (with appropriate filing fee). By:_______________________________ Entered: September 24, 2025 Patricia L. Halm, Tribunal
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MTT
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RECEIVED Co JUL 11 2005 MICHIG it STATE OF MICHIGAN AI TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL * kk B & S HOLDING LLC, MTT Docket No. 25-001869 Petitioner, v CITY OF MUSKEGON, Respondent. / Huan Cassioppi Tran Brennen J. Gorman (P80958) FLANAGAN BILTON LLC PARMENTER LAW Authorized Representative for Petitioner Attorneys for Respondent 1 N LaSalle Street 601 Terrace Street, PO Box 786 Chicago, IL 60602 Muskegon, MI 49440-1192 (313) 782-5000 (231) 722-1621 susan.chun@fblax.com brennen@parmenterlaw.com ENTIRE TRIBUNAL PROPERTY TAX ANSWER NOW COMES the Respondent, City of Muskegon, by and through its attorneys, Parmenter Law, and in its Answer to Petitioner’s Property Tax Petition states as follows: 1. Admit that Paragtaph 1 of the Petition and Multiple Parcel Petition Form 1 of 1, paragraphs 1 through 4 are admitted. 2. Admit, 3. Admit.
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7. N/A. 8. N/A. 9. N/A. 10. Admit. 11. Deny; the assessments were by the City of Muskegon. 12. Admit. 13. Admit issues raised but deny allegations. 14. Admit. 15. N/A. 16. Admit. 17. Admit. 18. Admit. 19. Admit that this is Petitioner’s position. 20. Admit that this is Petitioner’s position. Dated: July £ 2025 PARMENTER LAW By: Brennen J. Gorman (P80958) Attorneys for Respondent
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL * kk B & S HOLDING LLC, MTT Docket No. 25-001869 Petitioner, v CITY OF MUSKEGON, Respondent. / Huan Cassioppi Tran Brennen J. Gorman (P80958) FLANAGAN BILTON LLC PARMENTER LAW Authorized Representative for Petitioner Attorneys for Respondent 1 N LaSalle Street 601 Terrace Street, PO Box 786 Chicago, IL 60602 Muskegon, MI 49440-1192 (313) 782-5000 (231) 722-1621 susan.chun@fblax.com brennen@parmenterlaw.com / PROOF OF SERVICE n The undersigned certifies that on this Fa day of July 2025, copies of Respondent’s Appearance and this Proof of Service were served upon the Authorized Representative for Petitioner, Huan Cassioppi Tran, at his/her address of record via first-class mail. Abels Qn dass ad Tylor Anderson Legal Assistant for PARMENTER LAW
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RECEIVED
JuL 112025
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
* kk
B & S HOLDING LLC,
MTT Docket No. 25-001869
Petitioner,
v
CITY OF MUSKEGON,
Respondent.
/
Huan Cassioppi Tran
Brennen J. Gorman (P80958)
FLANAGAN BILTON LLC
PARMENTER LAW
Authorized Representative for Petitioner
Attorneys for Respondent
1 N LaSalle Street
601 Terrace Street, PO Box 786
Chicago, IL 60602
Muskegon, MI 49440-1192
(313) 782-5000
(231) 722-1621
susan.chun@fblax.com
brennen@parmenterlaw.com
/
APPEARANCE
PLEASE TAKE NOTICE that Brennen J. Gorman, of Parmenter Law, hereby enters his
appearance on behalf of Respondent, the City of Muskegon.
Dated: July
{
,2025
PARMENTER LAW
a
Brennen J. Gorman (P80958)
Attorneys for RespondentPage 5
n ™ LA PO Box 786, Muskegon, MI 49443-0786 PARMENTER" HH ebebel bagel] 0308 ZELLEBOEEY Michigan Tax Tribunal P.O. Box 30232 Lansing, Michigan 48909 FIRST-CLASS pug US POSTAG PB ls 2p 49440 $ t 0006232890
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR B &S HOLDING LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) \ MTT Docket No. CITY OF MUSKEGON Respondent(s) ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 24-134-300-0011-00 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) 2. The property identified above is X real ___personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? X Yes __ No. (If no, separate Petitions are required for each non- contiguous parcel.) 4. Are all of the parcels of personal property located on a parcel of real property under appeal? X__Yes ___ No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): 6. The property identified above is classified as COMMERCIAL 7. If the assessment or assessments at issue were protested, the protest was made to Respondent's March July December Board of Review. 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
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MTT Docket No. Page 2 of 4 8. 10. 11. 12. 13. 14. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): The property or properties at issue are located in MUSKEGON County. The property or properties’ address is: 1720 E SHERMAN BLVD MUSKEGON, MI 494444 The assessment or assessments at issue were established by the (applicable local governmental unit): CITY OF DETROIT Petitioner’s legal residence or principal office address is: 112 ABBINGTON CIRCLE BATTLE CREEK, MI 49015 This appeal involves issues relating to the (check all that are applicable): X the property or properties’ true cash and taxable values the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or loss? ___ Yes __ No X uniformity of the property or properties’ assessment the property or the properties’ exemption from ad valorem taxation under MCL The tax year(s) at issue are: 2025
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MTT Docket No. Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary): 16. The values for the property identified above as established by Respondent's Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 7,191,600 3,595,800 3,562,310 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 5,034,120 2,517,060 2,517,060 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 2,157,480 1,078,740 1,035,250 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner respectfully requests the Tribunal reduce the tax year 2025 assessed, state equalized, and taxable values of the subject property, and order a refund of the tax year 2025 taxes, with interest, as provided by the Tax Tribunal Act. 20. List the separate and specific facts upon which Petitioner relies to support the
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MTT
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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 B & S Holding LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-001869 City Of Muskegon, 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: July 28, 2025 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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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON |. BROWN, DPA GOVERNOR LANSING DIRECTOR B & SHOLDING LLC , MICHIGAN TAX TRIBUNAL Petitioner, \ MTT Docket No. CITY OF MUSKEGON , Respondent. MULTIPLE PARCEL PETITION FORM 1 OF 1 1. The classification of the property identified herein as established by Respondent's Board of Review is: Tax Year Parcel Number Real/Personal Classification 2025 24-134-300-0009-00 REAL COMMERCIAL 2025 24-134-300-0011-10 REAL COMMERCIAL 2. The values for the property identified herein as established by Respondent's Board of Review are: Tax Year | Parcel Number | True Cash Value Assessed Value Taxable Value 2025 24-134-300-0009-00 | 1,295,800 647,900 647,900 2025 24-134-300-0011-10 | 881,600 440,800 440,800 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
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MTT Docket No. Page 2 of 2 3. Petitioner contends that the values for the property identified herein are: Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value 2025 24-134-300-0009-00| 907,060 453,530 453,530 2025 24-134-300-0011-10) 617,120 308,560 308,560 4. The values in dispute for the property identified herein are: Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value 2025 24-134-300-0009-00] 388,740 194,370 194,370 2025 24-134-300-0011-10| 264,480 132,240 132,240
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR B &S HOLDING LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) \ MTT Docket No. CITY OF MUSKEGON Respondent(s) ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 24-134-300-0011-00 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) 2. The property identified above is X real ___personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? X Yes __ No. (If no, separate Petitions are required for each non- contiguous parcel.) 4. Are all of the parcels of personal property located on a parcel of real property under appeal? X__Yes ___ No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): 6. The property identified above is classified as COMMERCIAL 7. If the assessment or assessments at issue were protested, the protest was made to Respondent's March July December Board of Review. 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
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MTT Docket No. Page 2 of 4 8. 10. 11. 12. 13. 14. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): The property or properties at issue are located in MUSKEGON County. The property or properties’ address is: 1720 E SHERMAN BLVD MUSKEGON, MI 494444 The assessment or assessments at issue were established by the (applicable local governmental unit): CITY OF DETROIT Petitioner’s legal residence or principal office address is: 112 ABBINGTON CIRCLE BATTLE CREEK, MI 49015 This appeal involves issues relating to the (check all that are applicable): X the property or properties’ true cash and taxable values the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or loss? ___ Yes __ No X uniformity of the property or properties’ assessment the property or the properties’ exemption from ad valorem taxation under MCL The tax year(s) at issue are: 2025
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MTT Docket No. Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary): 16. The values for the property identified above as established by Respondent's Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 7,191,600 3,595,800 3,562,310 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 5,034,120 2,517,060 2,517,060 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 2,157,480 1,078,740 1,035,250 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner respectfully requests the Tribunal reduce the tax year 2025 assessed, state equalized, and taxable values of the subject property, and order a refund of the tax year 2025 taxes, with interest, as provided by the Tax Tribunal Act. 20. List the separate and specific facts upon which Petitioner relies to support the
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MTT
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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 B & S HOLDING LLC Home Address (No., Street, P.O. Box or Rural Route) 1184 COPPERWOOD DR City or Town BLOOMFIELD HILLS State Michigan ZIP Code 48302 Telephone Number 312-782-5000 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) HUAN@FBTAX.COM Section 2: Attorney/Authorized Representative’s Contact Information First Name Huan M.I. Last Name Cassioppi Tran Firm Name (if any) FLANAGAN BILTON LLC Address (No., Street, P.O. Box or Rural Route) 1 N LaSalle Street Suite 2100 City or Town Chicago State Illinois ZIP Code 60602 Telephone Number 312-782-5000 Fax Number 312-565-0821 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) susan.chun@fbtax.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?3 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 1720 E SHERMAN BLVD MUSKEGON Michigan Taxing Authority (City or Township) City Of Muskegon (MUSKEGON) County Muskegon If you are appealing more than one parcel, are they contiguous or adjoining? Yes (*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: 24-134-300-0011-10 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 440800 Current Taxable Value as established by the Board of Review: 440800 What do you believe is the fair market value (also known as True Cash Value)? 617120 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 308560 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Parcel Number: 24-134-300-0011-00 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 3595800 Current Taxable Value as established by the Board of Review: 3552310 What do you believe is the fair market value (also known as True Cash Value)? 5034120 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 2517060 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Parcel Number: 24-134-300-0009-00 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 647900 Current Taxable Value as established by the Board of Review: 647900 What do you believe is the fair market value (also known as True Cash Value)? 907060 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR 453530 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:
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STATE OF
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