Bbc Saginaw LLC Petitioner Vs. City Of Saginaw Respondent
- Petitioner
- Bbc Saginaw LLC
- Respondent
- City Of Saginaw
Case overview
- Docket number
- 26-001328-TT
- Status
- Ready Schedule
- CaseType
- ET Property
- Division
- ET
- County
- Saginaw
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 5 | Answer was received | RESP | Not recorded | 09/22/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | Not recorded | Not recorded | 09/15/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 08/06/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 08/06/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/24/2026 | $400.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
Read document text excerpt
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL BBC SAGINAW LLC, Petitioner, MTT DOCKET NO: 26-001328 V. CITY OF SAGINAW, a Michigan municipal corporation Respondent. Aaron M. Fales, P.C. City of Saginaw By: Aaron M. Fales (P72864) By: Amy L. Lusk (P63702), City Attorney Attorney for Petitioner Attorney for Respondent 330 Hamilton Row, Ste. 350 1315 S. Washington Avenue Birmingham, Michigan 48009 Saginaw, Michigan 48601 (248) 767-9840 (989) 759-1404 afaleslaw@gmail.com alusk@saginaw-mi.com RESPONDENT’S ANSWER TO PETITION Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, answers Petitioner’s Petition and says as follows: 1. In response to the allegations of Paragraph 1, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 2. In response to the allegations of Paragraph 2, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 3. In response to the allegations of Paragraph 3, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 4. In response to the allegations of Paragraph 4, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 5. In response to the allegations of Paragraph 5, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs.
Page 2
6. In response to the allegations of Paragraph 6, Respondent DENIES in the manner and for stated and for the reason same are untrue. Respondent asserts there is no actionable dispute at issue. 7. In response to the allegations of Paragraph 7, Respondent DENIES in the manner and form stated and for the reason same are untrue. a. In response to the allegations of Paragraph 7a, Respondent DENIES in the manner and form stated and for the reason same are untrue. b. In response to the allegations of Paragraph 7b, Respondent DENIES in the manner and form stated and for the reason same are untrue. c. In response to the allegations of Paragraph 7c, Respondent DENIES in the manner and form stated and for the reason same are untrue. d. In response to the allegations of Paragraph 7d, Respondent DENIES in the manner and form stated and for the reason same are untrue. Wherefore, Respondent requests that the Tax Tribunal deny Petitioner’s request for relief. Respectfully submitted, Dated: September 22, 2026 By: /s/ Amy L. Lusk Amy L. Lusk (P63702), City Attorney City of Saginaw Attorney for Respondent 1315 S. Washington Avenue Saginaw, Michigan 48601
Page 3
RESPONDENT’S AFFIRMATIVE DEFENSES Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, hereby asserts the following as Affirmative Defenses: 1. Petitioner failed to exhaust its administrative remedies. 2. Petitioner failed to state a claim against Respondent upon which relief could be granted. 3. The Tribunal lacks subject matter jurisdiction over the case. 4. The Tribunal lacks personal jurisdiction over the parties. 5. Petitioner has failed to file this case in the proper venue. 6. Petitioner has failed to mitigate its alleged damages. 7. Respondent was not properly served. 8. Petitioner’s claims are barred, in whole or in part, by waiver, estoppel, laches, and/or unclean hands. 9. Respondent is entitled to governmental immunity. 10. Petitioner’s claims are barred, in whole or in part, by the applicable statute of limitations. 11. Petitioner’s claims are barred, in whole or in part, because they are moot. 12. Petitioner lacks standing to appeal the tax assessment. 13. Respondent reserves the right to alter, amend, add, modify, or delete any or all of its affirmative defenses in this matter. Wherefore, Respondent requests that the Tax Tribunal deny Petitioner’s request for relief. Respectfully submitted, Dated: September 22, 2026 By: /s/ Amy L. Lusk Amy L. Lusk (P63702), City Attorney City of Saginaw Attorney for Respondent 1315 S. Washington Avenue Saginaw, Michigan 48601
Page 4
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL BBC SAGINAW LLC, Petitioner, MTT DOCKET NO: 26-001328 V. CITY OF SAGINAW, a Michigan municipal corporation Respondent. Aaron M. Fales, P.C. City of Saginaw By: Aaron M. Fales (P72864) By: Amy L. Lusk (P63702), City Attorney Attorney for Petitioner Attorney for Respondent 330 Hamilton Row, Ste. 350 1315 S. Washington Avenue Birmingham, Michigan 48009 Saginaw, Michigan 48601 (248) 767-9840 (989) 759-1404 afaleslaw@gmail.com alusk@saginaw-mi.com I, Amy L. Lusk, state that on September 22, 2026, I served a copy of Respondent’s Answer to Petition, Affirmative Defenses, and Proof of Service in the above cause via e- filing upon the following: Michigan Tax Tribunal Attorney Aaron Fales Dated: September 22, 2026 By: /s/ Amy L. Lusk Amy L. Lusk
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Respondent MTT DOCKET NO. 26-001328 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Saginaw (SAGINAW) First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) Section 2: Attorney/Authorized Representative’s Contact Information First Name Amy M.I. Last Name Lusk Firm Name (if any) City of Saginaw Address (No., Street, P.O. Box or Rural Route) 1315 S. Washington Avenue City or Town Saginaw State Michigan ZIP Code 48601 Telephone Number 9897591404 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) alusk@saginaw-mi.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Amy Lusk /s/
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL BBC SAGINAW LLC, Petitioner, Vv. MTT Docket # 26-001328 CITY OF SAGINAW, Respondent. PROOF OF SERVICE STATE OF MICHIGAN } ) ss. COUNTY OF OAKLAND) Aaron M. Fales, being duly sworn, deposes and says that on September I$ , 2026 he served a copy of Petitioner's Petition on the parties named on the attached list. Aaron M. Fales
Page 2
BY CERTIFIED UNITED STATES MAIL. RETURN RECEIPT REQUESTED: « 4 aw TON AVENUE
Page 3
STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR BBC Saginaw LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001328 City Of Saginaw, 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), “[tlhe 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: August 6, 2026 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
Page 4
STATE OF MICHIGAN
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
BBC SAGINAW LLC,
Petitioner,
MTT Docket #26- 001328
VS.
Parcel No. 21-4333-00400
CITY OF SAGINAW,
Respondent.
;
PETITION
BBC SAGINAW
LLC
(“Petitioner”), through
its attorneys, Law Office
of
Aaron M. Fales, P.C., says:
1.
Petitioner's principal office address
is PO Box 810, Royal Oak, MI
48068.
Petitioner
is a party
in interest with respect fo property taxes on real
property tax parcel no. 21-4333-00400 ("Petitioner's Property"), at 2220 Veterans
Memorial Pkwy., Saginaw, Ml.
2.
Respondent, City of Saginaw, assesses and collects property taxes
on Petitioner's Property.
3.
In 2026, Respondent determined the taxable value of Petitioner's
Property
to
be
$1,039,200
and
assessed
Petitioner's
Property
at
$1,039,900
resulting in a state equalized value of the same amount based on the tenativePage 5
4,
Petitioner's
Property
is
classified
as
Industrial
Real
Property.
Petitioner's Property
is industrial property.
Petitioner believes that Petitioner's
Property was designed to be used for industrial purposes.
5.
This matter involves issues relating to: {a) valuation, (b) assessment,
(c) taxable value, and (d) uniformity.
6.
Af this time, Petitioner believes, as
it relates to taxable value, that
there is a dispute relative to the value of a loss.
7.
The 2026 assessment, including state equalized value and taxable
value,
imposed
on
Petitioners
Property,
and
the
taxes
to
be
levied
and
collected thereon, are invalid and unlawful and operate as a fraud upon the
taxpayer for the reasons that:
(a)
The
assessment,
including
state
equdlized
value
and/or
taxable value, exceeds the amount permitted by the Michigan Constitution and
applicable statutes;
(b)
The
assessment,
including
state
equalized
value
and/or
taxable value, are af higher percentages of true cash value than permissible
under the Michigan Constitution and applicable statutes;
lc)
The
assessment,
including
taxable
value
and/or
state
equalized value, are based upon an erroneous determination of the true cashPage 6
(d} The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable value of Petitioner's Property from $1,039,900 to $540,000, and reducing the 2026 assessed and state equalized values of Petitioner's Property from $1,039,900 to $540,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully submitted, LAW OFFICE OF AARON M. FALES, P.C. Attorney for Petitioner AY Aaron M. Fales (P72864) 330 Hamilton Row, Ste. 350 Birmingham, MI 48009 (248) 767-9840 By: Dated: May 24, 2026
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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 MICHIGAN TAX TRIBUNAL Docket Number: 26-001328 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: 26 - SAGINAW POS Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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Page 1
STATE OF MICHIGAN
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
BBC SAGINAW LLC,
Petitioner,
vs.
CITY OF SAGINAW,
Respondent.
/
MTT Docket #26-
Parcel No. 21-4333-00400
PETITION
BBC SAGINAW LLC (“Petitioner”), through its attorneys, Law Office of
Aaron M. Fales, P.C., says:
1.
Petitioner's principal office address is PO Box 810, Royal Oak, MI
48068. Petitioner is a party in interest with respect to property taxes on real
property tax parcel no. 21-4333-00400 ("Petitioner's Property"), at 2220 Veterans
Memorial Pkwy., Saginaw, MI.
2.
Respondent, City of Saginaw, assesses and collects property taxes
on Petitioner's Property.
3.
In 2026, Respondent determined the taxable value of Petitioner's
Property to be $1,039,900 and assessed Petitioner's Property at $1,039,900
resulting in a state equalized value of the same amount based on the tenative
equalization factor.Page 2
4. Petitioner's Property is classified as Industrial Real Property. Petitioner's Property is industrial property. Petitioner believes that Petitioner's Property was designed to be used for industrial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. The 2026 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; (c) The assessment, including taxable value and/or state equalized value, are based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and are based upon the application of wrong principles; and,
Page 3
(d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable value of Petitioner's Property from $1,039,900 to $540,000, and reducing the 2026 assessed and state equalized values of Petitioner's Property from $1,039,900 to $540,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Dated: May 24, 2026 Respectfully submitted, LAW OFFICE OF AARON M. FALES, P.C. Attorney for Petitioner By: _________________________ Aaron M. Fales (P72864) 330 Hamilton Row, Ste. 350 Birmingham, MI 48009 (248) 767-9840
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Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Petitioner MTT DOCKET NO. Section 1: Petitioner’s Contact Information Filer type: Organization Local Unit of Government First Name M.I. Last Name/Company Name BBC Saginaw LLC Home Address (No., Street, P.O. Box or Rural Route) PO Box 810 City or Town Saginaw State Michigan ZIP Code 48068 Telephone Number 2487679840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Aaron M.I. Last Name Fales Firm Name (if any) Law Office of Aaron M Fales, P.C. Address (No., Street, P.O. Box or Rural Route) 330 Hamilton Row Suite 350 City or Town Birmingham State Michigan ZIP Code 48009 Telephone Number 248-767-9840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 2220 Veterans Memorial Pkwy. saginaw
Page 2
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48601 Taxing Authority (City or Township) City Of Saginaw (SAGINAW) County Saginaw 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.) N/A Section 5: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values If “Other”, please explain: Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 21-4333-00400 Classification of Property: Real (check one) Industrial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 1039900 Current Taxable Value as established by the Board of Review: 1039900 What do you believe is the fair market value (also known as True Cash Value)? 1080000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 540000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 540000 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.
Page 3
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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/ Aaron Fales Payment Information Amount: 400 Success: True Message: "" Waiver Code: Transaction Number: 26052486727645 Supporting Waiver 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 BBC Saginaw LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001328 City Of Saginaw, 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: August 6, 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
Page 2
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 BBC Saginaw LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001328 City Of Saginaw, 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: August 6, 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
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
BBC SAGINAW LLC,
Petitioner,
vs.
CITY OF SAGINAW,
Respondent.
/
MTT Docket #26-
Parcel No. 21-4333-00400
PETITION
BBC SAGINAW LLC (“Petitioner”), through its attorneys, Law Office of
Aaron M. Fales, P.C., says:
1.
Petitioner's principal office address is PO Box 810, Royal Oak, MI
48068. Petitioner is a party in interest with respect to property taxes on real
property tax parcel no. 21-4333-00400 ("Petitioner's Property"), at 2220 Veterans
Memorial Pkwy., Saginaw, MI.
2.
Respondent, City of Saginaw, assesses and collects property taxes
on Petitioner's Property.
3.
In 2026, Respondent determined the taxable value of Petitioner's
Property to be $1,039,900 and assessed Petitioner's Property at $1,039,900
resulting in a state equalized value of the same amount based on the tenative
equalization factor.Page 2
4. Petitioner's Property is classified as Industrial Real Property. Petitioner's Property is industrial property. Petitioner believes that Petitioner's Property was designed to be used for industrial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. The 2026 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; (c) The assessment, including taxable value and/or state equalized value, are based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and are based upon the application of wrong principles; and,
Page 3
(d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable value of Petitioner's Property from $1,039,900 to $540,000, and reducing the 2026 assessed and state equalized values of Petitioner's Property from $1,039,900 to $540,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Dated: May 24, 2026 Respectfully submitted, LAW OFFICE OF AARON M. FALES, P.C. Attorney for Petitioner By: _________________________ Aaron M. Fales (P72864) 330 Hamilton Row, Ste. 350 Birmingham, MI 48009 (248) 767-9840
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Petitioner MTT DOCKET NO. Section 1: Petitioner’s Contact Information Filer type: Organization Local Unit of Government First Name M.I. Last Name/Company Name BBC Saginaw LLC Home Address (No., Street, P.O. Box or Rural Route) PO Box 810 City or Town Saginaw State Michigan ZIP Code 48068 Telephone Number 2487679840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Aaron M.I. Last Name Fales Firm Name (if any) Law Office of Aaron M Fales, P.C. Address (No., Street, P.O. Box or Rural Route) 330 Hamilton Row Suite 350 City or Town Birmingham State Michigan ZIP Code 48009 Telephone Number 248-767-9840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 2220 Veterans Memorial Pkwy. saginaw
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48601 Taxing Authority (City or Township) City Of Saginaw (SAGINAW) County Saginaw 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.) N/A Section 5: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values If “Other”, please explain: Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 21-4333-00400 Classification of Property: Real (check one) Industrial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 1039900 Current Taxable Value as established by the Board of Review: 1039900 What do you believe is the fair market value (also known as True Cash Value)? 1080000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 540000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 540000 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.
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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/ Aaron Fales Payment Information Amount: 400 Success: True Message: "" Waiver Code: Transaction Number: 26052486727645 Supporting Waiver Documents:
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