Record Finder / 26-001328-TT
Michigan

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 #SubjectFilerLine RefEnter Date/Post MarkFeeRelated Item
5Answer was receivedRESPNot recorded09/22/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
4Proof of service of petition was received.Not recordedNot recorded09/15/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
3Petition has been verifiedPET108/06/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
2Notice of Docket Number ETNot recordedNot recorded08/06/2026Not recordedDownload
1A petition was received.PETNot recorded05/24/2026$400.00Download
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload

Documents

City of Saginaw Answer and Affirmative Defenses.pdfRead complete document text →
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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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EntireTribunalCaseISAnswer.pdfRead complete document text →
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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 - 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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Page 1

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 tenative

Page 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 cash

Page 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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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: 26-001328

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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2026 - Saginaw - Petition.pdfRead complete document text →
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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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EntireTribunalCaseISPetition.pdfRead complete document text →
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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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ET_Notice_of_Docket_Number.2026-08-06_17-30-49.pdfRead complete document text →
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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

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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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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