Blair Park 2005, LLC, Petitioner Vs. City Of Jackson, Respondent

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

Blair Park 2005 LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-003119 

 

City of Jackson, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

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

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

indicated. 

 

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

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

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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after 

December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 

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

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-003119 

Page 2 of 2 

 

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

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

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

8.66%, and (ix) after December 31, 2025, through June 30, 2026, at the rate of 8.48%. 

 

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

 

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

 

 

 

 

 

 

 

 

 

By _____________________________ 

Entered: November 21, 2025 

jcr 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Blair Park 2005, LLC, 

Petitioner, 

v 

MTT Docket No. 25-003119 

City of Jackson, 

Parcel # 8-191400000 

Respondent. 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

1. 

The case is pending in the Entire Tribunal. 

2. 

The subject property is in Jackson County. 

3. 

The subject parcel identification number is 8-191400000. 

4. 

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 

2024 

4,438,400 

2,219,200 

2,219,200 

5. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax year 

True Cash Value 

Assessed Value 

Taxable Value 

2024 

3,600,000 

1,800,000 

1,800,000 

6. 

If this stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax years 

(attach additional page if necessary): 

7. 

List all reasons (with explanation) why the stipulation’s taxable value does not equal the 

prior year TV multiplied by the applicable inflation rate. (e.g. transfer of ownership, 

additions, losses, omitted property etc...)

Page 2

8. 

List any special terms or conditions being proposed by the parties that would affect the 

execution of this Consent 

Judgment including, but not limited to, the joint payment of the 

refund, the waiver of interest, etc. (attach additional page if necessary): 

Any refund will be made payable to “Blair Park 2005, LLC” and mailed to counsel, 

Peter Ellenson, 30500 Northwestern Highway, Suite 500, Farmington Hills, MI 48334. 

Petitioner may communicate directly with city and county treasurers to effectuate this 

provision. 

Signature of Petitioner’s Authorized Representative: 

/s/ Peter Ellenson 

Printed Name: Peter Ellenson 

Date: November 20, 2025 

Signature of Respondent’s Authorized Representative: 

HAS 

Printed Name: Matthew Hagerty 

Date: 

J 

1) z2e28 

~

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Blair Park 2005, LLC, 

Petitioner, 

v 

MTT Docket No. 25-003119 

City of Jackson, 

Parcel # 8-191400000 

Respondent. 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

1. 

The case is pending in the Entire Tribunal. 

2. 

The subject property is in Jackson County. 

3. 

The subject parcel identification number is 8-191400000. 

4. 

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 

2024 

4,438,400 

2,219,200 

2,219,200 

5. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax year 

True Cash Value 

Assessed Value 

Taxable Value 

2024 

3,600,000 

1,800,000 

1,800,000 

6. 

If this stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax years 

(attach additional page if necessary): 

7. 

List all reasons (with explanation) why the stipulation’s taxable value does not equal the 

prior year TV multiplied by the applicable inflation rate. (e.g. transfer of ownership, 

additions, losses, omitted property etc...)

Page 2

8. 

List any special terms or conditions being proposed by the parties that would affect the 

execution of this Consent 

Judgment including, but not limited to, the joint payment of the 

refund, the waiver of interest, etc. (attach additional page if necessary): 

Any refund will be made payable to “Blair Park 2005, LLC” and mailed to counsel, 

Peter Ellenson, 30500 Northwestern Highway, Suite 500, Farmington Hills, MI 48334. 

Petitioner may communicate directly with city and county treasurers to effectuate this 

provision. 

Signature of Petitioner’s Authorized Representative: 

/s/ Peter Ellenson 

Printed Name: Peter Ellenson 

Date: November 20, 2025 

Signature of Respondent’s Authorized Representative: 

HAS 

Printed Name: Matthew Hagerty 

Date: 

J 

1) z2e28 

~

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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

Blair Park 2005, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-003119

City Of Jackson,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on October 15, 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 6, 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

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

Blair Park 2005, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-003119

City Of Jackson,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on October 15, 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 6, 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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLAIR PARK 2005, LLC, 

Petitioner, 

-vs- 

CITY OF JACKSON, 

Respondent. 

MOAHR Docket No. 25-003119 

Parcel No. 8-191400000 

ANSWER TO PETITION AND 

AFFIRMATIVE DEFENSES 

PETER ELLENSON (P47383) 

LAW OFFICE OF PETER ELLENSON PC 

Attorney for Petitioner 

30500 Northwestern Highway, Ste 500 

Farmington Hills, MI 48334 

248/406-4443 

peter@ellensonlaw.com 

JACKSON CITY ATTORNEY'S OFFICE 

BY: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

RESPONDENT CITY OF JACKSON'S 

ANSWER TO PETITION 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and for its Answer to Petitioner’s Petition, states as follows: 

1. 

Respondent neither admits nor denies the allegation contained in Paragraph 

1 of 

Petitioner’s Petition. 

2. 

Respondent neither admits nor denies the allegation contained in Paragraph 2 of 

Petitioner’s Petition.

Page 2

10. 

11. 

12. 

13. 

14. 

15. 

In response to Paragraph 

3, Respondent states that the City of Jackson Assessing 

department assesses property taxes on the subject property which are collected by 

collected by the City of Jackson Treasurer. 

Respondent admits the allegation contained in Paragraph 4 of Petitioner’s Petition. 

Respondent admits the allegation contained in Paragraph 5 of Petitioner’s Petition. 

Respondent neither admits nor denies the allegations contained in Paragraph 6 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent admits the allegation contained in Paragraph 7 of Petitioner’s Petition. 

Respondent neither admits nor denies the allegations contained in Paragraph 

8 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent neither admits nor denies the allegations contained in Paragraph 9 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent neither admits nor denies the allegations contained in Paragraph 10 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent admits the allegation contained in Paragraph 11 of Petitioner’s Petition. 

Respondent admits the allegation contained in Paragraph 12 of Petitioner’s Petition. 

Respondent denies the allegation contained in Paragraph 13 of Petitioner’s Petition. 

Respondent states that the allegations contained in paragraph 14 merely represent the 

conclusion of the pleader. 

Respondent states that the allegations contained in paragraph 15 merely represent the 

conclusion of the pleader and that Petitioner’s claims to a refund, interest and costs are 

denied as untrue.

Page 3

16. Respondent denies the allegation contained in Paragraph 16 of Petitioner’s Petition as 

untrue. 

17. Respondent admits that the assessments for TY 2025 are currently under appeal in 

docket no. 25-001273 are neither admit nor deny the remaining allegations. 

WHEREFORE, 

Respondent 

requests 

this Honorable 

Tribunal 

dismiss 

Petitioner’s 

Petition in its entirety, that it assess actual costs and attorney fees against Petitioner for costs 

incurred in responding to the Petition, and further requests all other relief the Tribunal deems to be 

just and equitable. 

Respectfully submitted, 

4 

DATED: October 22, 2025 

BY: 

Z = AN 

Office of the City Attorney 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, City of Jackson, by and through 

its attorneys, the City 

Attorney’s Office, and states the following Affirmative Defenses alternatively and consecutively: 

1. 

The subject property’s assessed, 

true cash, and taxable values are levied 

in 

accordance with the Michigan General Property Tax Act and Michigan Constitution. 

2. 

The subject property is assessed in accordance with generally accepted assessing 

standards. 

B82 

The subject property is assessed at no more than 50% of its true cash value.

Page 4

4. 

Petitioner has failed to state a claim upon which relief can be granted. 

5. 

Respondent reserves the right 

to amend 

its affirmative defenses through the 

conclusion of discovery.

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-003119

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Jackson (JACKSON)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Matthew

M.I.

M.

Last Name

Hagerty

Firm Name (if any)

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

161 W. Michigan Ave.

City or Town

Jackson

State

Michigan

ZIP Code

49201

Telephone Number

517-788-4050

Fax Number

866-971-2117

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

mhagerty@cityofjackson.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Matthew M. Hagerty

/s/

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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

Blair Park 2005, LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-003119

City Of Jackson,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Respondent 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: October 15, 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 

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.

Page 2

MTT Docket No. 25-003119

Page 2 of 6

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)

Page 3

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

Blair Park 2005, LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-003119

City Of Jackson,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Respondent 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: October 15, 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

Page 4

MTT

Page 5

STATE

Page 6

M

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

Blair Park 2005, LLC 

: 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No, 25-003119 

City of Jackson 

, 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Peter Ellenson 

states that on 9/2/25 

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): 

Jackson Assessor, 161 W Michigan Avenue, Jackson, MI 49201 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

Jackson Clerk, 161 W Michigan Avenue, Jackson, MI 49201 

3. 

County Equalization Director (via first class mail or personal service): 

Jackson County Equalization Director, 120 W Michigan Ave #2, Jackson MI 49201 

4. 

County Clerk (via first class mail or personal service): 

Jackson County Clerk, 120 W Michigan Ave, Jackson, Ml 49201 

5. 

Secretary of the local school board (via first class mail or personal service): 

Secretary of the Board, Jackson Public Schools, 522 Wildwood, Jackson, MI 49201 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

/s/ Peter Ellenson 

Peter Ellenson 

[Signature of person 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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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

ol Park 2008, LC 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No, 25-001273 

City of Jackson 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Peter Ellenson 

states that on July 28, 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): 

Jackson Assessor, 161 W Michigan Ave, Jackson, MI 49201 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

Jackson Clerk, 161 W. Michigan Ave., Jackson, Michigan 49201 

3. 

County Equalization Director (via first class mail or personal service): 

Jackson County Equalization Director, 120 W Michigan Ave #2, Jackson, MI 49201 

4. 

County Clerk (via first class mail or personal service): 

Jackson County Clerk, 120 W Michigan Ave, Jackson, MI 49201 

5. 

Secretary of the local school board (via first class mail or personal service): 

Secretary of the Board, Jackson Public Schools, 522 Wildwood Ave.,Jackson MI 49201 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

/s/ Peter Ellenson 

Peter Ellenson 

[Signature of person 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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLAIR PARK 2005, LLC, 

 

Petitioner, 

v 

 

 

 

 

 

 

 

MTT Dkt. No. 

 

 

 

 

 

 

 

 

 

CITY OF JACKSON, 

 

 

 

 

 

Respondent. 

 

 

 

 

Parcel No. 8-191400000 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

 

Attorney for Petitioner 

 

 

 

 

 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

248 406 4443 

peter@ellensonlaw.com 

______________________________________/ 

 

 

ENTIRE TRIBUNAL TAX PETITION – TY 2024 

 

 

NOW COMES Petitioner, BLAIR PARK 2005, LLC, through its attorney, PETER 

ELLENSON, and states as follows in support of this Petition: 

1. 

Petitioner is a party in interest with respect to the property taxes for the following 

parcel number: 8-191400000, located at 100 Blair Park Drive, Jackson, MI 49202. 

 

2. 

Petitioner’s principal office address is c/o Independent Management S, 14381 

North Road, Fenton, MI 48430 

3. 

Respondent City of Jackson assesses and collects the ad valorem property taxes 

associated with the subject parcel. 

4. 

The subject property is classified as commercial improved (201). 

5. 

The subject property is located in Jackson County. 

6. 

This appeal involves the property’s true cash and taxable values.

Page 2

7. 

The tax year at issue is 2024. 

8. 

No Board of Review protest was required or filed for the property. 

9. 

On information and belief, the ad valorem property taxation on this property was 

controlled by a PILOT agreement through 12/31/23. 

10. 

During calendar year 2024, neither party realized that the PILOT had expired. 

The City did not issue a revised (standard) assessment or a revised (standard) tax bill at any time 

during CY 2024. The taxpayer paid taxes in accordance with the PILOT agreement. 

11. 

On July 22, 2025, the City issued a July Board of Review Notice Change, 

imposing the 2024 assessments set forth below. 

12. 

The 2024 values for the subject property as established by the Respondent at its 

July 2025 Board of Review are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

4,438,400 

 

 

2,219,200 

 

 

2,219,200 

 

13. 

Petitioner contends that the values for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

3,600,000 

 

 

1,800,000 

 

 

1,800,000 

 

14. 

The values in dispute for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

838,400 

 

 

419,200 

 

 

419,200 

 

15. 

Petitioner requests that this Honorable Tribunal order the assessing entity to 

correct its tax rolls to reflect taxable, assessed and state equalized values as indicated above (or 

on the attached supplement) to issue refunds as appropriate, and to pay interest and costs.

Page 3

16. 

The basis for the requested relief is that the assessed and taxable values exceed 

50% of the true cash value of the subject property. 

17. 

The assessments for the subject property are under appeal for TY 2025 in case 

number 25-001273. A consolidation of the two cases may be appropriate in the future. 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: August 7, 2025 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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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

Blair Park 2005, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-003119

City Of Jackson, 

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 20, 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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Page 1

CITY OF 

J AC KS oS N 

City Assessor’s Office 

161 W. Michigan Ave. 

Jackson, MI 49201 

Founded 1829 

Phone: (517) 788-4033 + Facsimile: (866) 902-7891 

Jul 22, 2025 

“JUL 2 8 2025 

BLAIR PARK 2005 LLC 

C/O INDEPENDENT MANAGEMENT SVC 

14381 NORTH RD 

FENTON MI 48430 

2025 JULY BOARD OF REVIEW CHANGE NOTICE 

100 BLAIR PARK DR 

8-191400000 

Dear Property Owner: 

On Jul 22, 2025 

, the July Board of Review made the following correction to the assessed, capped and 

taxable values or to the Principal Residence Exemption (PRE) for the above referenced parcel. 

Action Taken: 

Original 

Corrected 

Year 

Assessed 

Capped 

Taxable 

Year 

Assessed 

Capped 

Taxable 

2024 

2,219,20 

2,219,200 

2,219,200 

2024 

2,219,20 

2,219,200 

2,219,200 

The action of the July Board of Review may be appealed to the Michigan Tax Tribunal within 35 days after 

the final decision, ruling or determination. 

To appeal to the Michigan Tax Tribunal, file a petition with the 

MTT that can be obtained from their website: http://iwww.michigan.gov/taxtrib 

If you have any questions regarding the above changes, please do not hesitate to contact us at 

517-788-4033 

Sincerely, 

City of Jackson Board of Review 

(Rev. 07-21)

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLAIR PARK 2005, LLC, 

 

Petitioner, 

v 

 

 

 

 

 

 

 

MTT Dkt. No. 

 

 

 

 

 

 

 

 

 

CITY OF JACKSON, 

 

 

 

 

 

Respondent. 

 

 

 

 

Parcel No. 8-191400000 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

 

Attorney for Petitioner 

 

 

 

 

 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

248 406 4443 

peter@ellensonlaw.com 

______________________________________/ 

 

 

ENTIRE TRIBUNAL TAX PETITION – TY 2024 

 

 

NOW COMES Petitioner, BLAIR PARK 2005, LLC, through its attorney, PETER 

ELLENSON, and states as follows in support of this Petition: 

1. 

Petitioner is a party in interest with respect to the property taxes for the following 

parcel number: 8-191400000, located at 100 Blair Park Drive, Jackson, MI 49202. 

 

2. 

Petitioner’s principal office address is c/o Independent Management S, 14381 

North Road, Fenton, MI 48430 

3. 

Respondent City of Jackson assesses and collects the ad valorem property taxes 

associated with the subject parcel. 

4. 

The subject property is classified as commercial improved (201). 

5. 

The subject property is located in Jackson County. 

6. 

This appeal involves the property’s true cash and taxable values.

Page 2

7. 

The tax year at issue is 2024. 

8. 

No Board of Review protest was required or filed for the property. 

9. 

On information and belief, the ad valorem property taxation on this property was 

controlled by a PILOT agreement through 12/31/23. 

10. 

During calendar year 2024, neither party realized that the PILOT had expired. 

The City did not issue a revised (standard) assessment or a revised (standard) tax bill at any time 

during CY 2024. The taxpayer paid taxes in accordance with the PILOT agreement. 

11. 

On July 22, 2025, the City issued a July Board of Review Notice Change, 

imposing the 2024 assessments set forth below. 

12. 

The 2024 values for the subject property as established by the Respondent at its 

July 2025 Board of Review are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

4,438,400 

 

 

2,219,200 

 

 

2,219,200 

 

13. 

Petitioner contends that the values for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

3,600,000 

 

 

1,800,000 

 

 

1,800,000 

 

14. 

The values in dispute for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

838,400 

 

 

419,200 

 

 

419,200 

 

15. 

Petitioner requests that this Honorable Tribunal order the assessing entity to 

correct its tax rolls to reflect taxable, assessed and state equalized values as indicated above (or 

on the attached supplement) to issue refunds as appropriate, and to pay interest and costs.

Page 3

16. 

The basis for the requested relief is that the assessed and taxable values exceed 

50% of the true cash value of the subject property. 

17. 

The assessments for the subject property are under appeal for TY 2025 in case 

number 25-001273. A consolidation of the two cases may be appropriate in the future. 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: August 7, 2025 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Blair Park 2005, LLC

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

14381 North Road

City or Town

Fenton

State

Michigan

ZIP Code

48430

Telephone Number

2484064443

Fax Number

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

peter@ellensonlaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Peter

M.I.

Last Name

Ellenson

Firm Name (if any)

Peter Ellenson PC

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

30500 Northwestern Hwy

Suite 500

City or Town

Farmington Hills

State

Michigan

ZIP Code

48334

Telephone Number

248-406-4443

Fax Number

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

peter@ellensonlaw.com

Section 5: Issue

Please designate one: 

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

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

100 Blair Park Drive

Jackson

Michigan

49202

Taxing Authority (City or Township)

City Of Jackson (JACKSON)

County

Jackson

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.)

Page 2

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:

8-191400000

Classification of Property: Real 

Commercial

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

2219200

Current Taxable Value as established by the Board of Review:

2219200

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

3600000

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

1800000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

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

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

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

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

Fee Information

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

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

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

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

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

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

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

Electronic

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