Record Finder / 26-001448-TT
Michigan

Canyon Venture III LLC Petitioner Vs. Township Of Saginaw Respondent

Petitioner
Canyon Venture III LLC
Respondent
Township Of Saginaw

Case overview

Docket number
26-001448-TT
Status
Answer Due
CaseType
ET Property
Division
ET
County
Saginaw
Judge
No judge assigned

Docket history

Line #SubjectFilerLine RefEnter Date/Post MarkFeeRelated Item
9DocumentationNot recordedNot recorded10/12/2026Not recordedDownload
8Proof of Service of Misc Documents was received.Not recordedNot recorded10/12/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
7Answer was receivedRESPNot recorded10/12/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
6AppearanceRESPNot recorded09/29/2026Not recordedDownload
5Proof of service of petition was received.Not recordedNot recorded09/15/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
4Amended PetitionNot recordedNot recorded09/14/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
3Petition has been verifiedPET108/12/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
2Notice of Docket Number ETNot recordedNot recorded08/12/2026Not recordedDownload
1A petition was received.PETNot recorded05/26/2026$400.00Download
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload

Documents

Canyon Venture III LLC v Township of Saginaw (26-001448) correspondence.pdfRead complete document text →
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Page 1

BRAUN KENDRICK 

FRANCIS J. KEATING 

ATTORNEYS AT LAW 

Attorney 

TEL: 989.631.1027 

FAX: 989.631.9880 

EMAIL: frakea@braunkendrick.com 

October 12, 2026 

VIA ELECTRONIC FILING 

Ms. Samantha M. Welton 

Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

Re: 

Canyon Venture III LLC v Township of Saginaw 

MTT Docket No.: 26-001448 

Dear Ms. Welton: 

Enclosed please find Respondent’s Answer to Amended Petition and Proof of Service for the above- 

referenced matter. Please file the same in your usual manner. 

Thank you for your attention to this matter. 

If you have any questions regarding it, please contact me. 

Very 

trul 

s 

CIS J. KEATING 

FIK/1s 

Enclosures 

cc: 

Client (w/encs) 

Aaron M. Fales (w/encs) 

4904-7266-8119, v. 

1 

BRAUN KENDRICK FINKBEINER PL.C. 

MIDLAND 

SAGINAW 

MT. PLEASANT 

), 

pidland 

BRAUN KENDRICK.COM

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Canyon Venture III LLC v Township of Saginaw (26-001448) Proof of Service.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURE III LLC, 

Petitioner, 

MTT Docket No.: 26-001448 

\4 

TOWNSHIP OF SAGINAW, 

Respondent. 

LAW OFFICES OF AARON M. FALES, P.C. 

BRAUN KENDRICK FINKBEINER P.L.C. 

By: 

Aaron M. Fales (P72864) 

By: 

Francis J. Keating (P39223) 

Attorney Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Suite 350 

4301 Fashion Square Blvd. 

Birmingham, MI 48009 

Saginaw, MI 48603 

(248) 767-9840 

(989) 498-2100 

afaleslaw(@gmail.com 

frakea@braunkendrick.com 

PROOF OF SERVICE 

LEE STADLER, duly sworn, deposes and says that she is a secretary in the employ of 

BRAUN KENDRICK FINKBEINER P.L.C., attorneys for the Respondent, Township of Saginaw, 

and states that on the \&3 

day of October, 2026, she served a copy of Respondent’s Answer to 

Amended Petition via first class mail, by placing same in an envelope with sufficient postage 

attached and plainly addressed to: 

Aaron M. Fales, 330 Hamilton Row, Suite 350, Birmingham, 

MI 48009. 

LEE STADLER 

4932-5722-7223, v. 1

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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: 26-001448

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

Party Filing Document 

Respondent

Files

Document Type: Proof of Service: Misc Documents

Attachment File Name: Canyon Venture III LLC v Township of Saginaw (26-001448) Proof of 

Service

Document Type: Documentation

Attachment File Name: Canyon Venture III LLC v Township of Saginaw (26-001448) 

correspondence

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Canyon Venture III LLC v Township of Saginaw (26-001448) Respondent's Answer to Amended Petition.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURE III LLC, 

Petitioner, 

MTT Docket No.: 26-001448 

v 

TOWNSHIP OF SAGINAW, 

Respondent. 

LAW OFFICES OF AARON M. FALES, P.C. 

BRAUN KENDRICK FINKBEINER P.L.C. 

By: 

Aaron M. Fales (P72864) 

By: 

Francis J. Keating (P39223) 

Attorney Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Suite 350 

4301 Fashion Square Blvd. 

Birmingham, MI 48009 

Saginaw, MI 48603 

(248) 767-9840 

(989) 498-2100 

afaleslaw(@gmail.com 

frakea@braunkendrick.com 

RESPONDENT’S ANSWER TO AMENDED PETITION 

NOW COMES Respondent, Township of Saginaw, by and through its attorneys, Braun 

Kendrick Finkbeiner P.L.C., and for its Answer to Amended Petition, states as follows: 

1. 

Respondent admits that real property tax parcel no. 23-12-4-16-3008-006 is also 

known 

as 4598 

State 

Street, Saginaw, Michigan 48603. 

Respondent lacks knowledge 

or 

information sufficient to form a belief as to the truth of the remaining allegations in paragraph 1. 

2. 

Admitted. 

3. 

Admitted. 

4. 

Respondent admits that the subject property is classified Commercial Improved. 

Respondent lacks knowledge or information sufficient to form a belief as to the truth of the 

remaining allegations in paragraph 4. 

4896-9211-3879, v. 1

Page 2

5. 

Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations in paragraph 5. 

6. 

Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations in paragraph 6. 

7. 

Respondent denies as untrue the allegations in paragraph 7. 

7a. 

Respondent denies as untrue the allegations in paragraph 7a. 

7b. 

Respondent denies as untrue the allegations in paragraph 7b. 

Tc. 

Respondent denies as untrue the allegations in paragraph 7c. 

7d. 

Respondent denies as untrue the allegations in paragraph 7d. 

NEW MATTERS AND AFFIRMATIVE DEFENSES 

1. 

Petitioner has failed to allege specific and sufficient facts to set forth a cause of 

action against Respondent. 

2. 

Petitioner has failed 

to allege specific and sufficient facts 

to establish fraud, 

discrimination, or illegality on the part of the Respondent. 

3. 

Petitioner may not be the real party in interest to bring this tax appeal. 

4. 

Petitioner may not have standing to bring this tax appeal. 

S. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive 

at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

6. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner's 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

4896-9211-3879, v. 1

Page 3

7: 

Respondent reserves the right to assert additional affirmative defenses during the 

pendency of this action. 

WHEREFORE, 

Respondent, 

Township 

of Saginaw, 

respectfully 

requests 

that 

this 

Honorable Tribunal provide it with the following relief: 

A. 

Dismiss the Petition with prejudice, and award Respondent its costs and attorney 

fees wrongfully incurred in the defense of this action; and 

B. 

Provide Respondent with such other relief as the Tribunal deems appropriate. 

BRAUN KENDRICK FINKBEINER P.L.C. 

Dated: October /Z 

,2026 

BY: Ta KEATING (P39223) 

Attorney 

for Respondent 

4896-9211-3879, v. 1

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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. 26-001448

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township 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

Francis

M.I.

J

Last Name

Keating

Firm Name (if any)

Braun Kendrick

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

4301 Fashion Square Blvd.

City or Town

Saginaw

State

 Michigan

ZIP Code

48603

Telephone Number

9894982100

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

frakea@braunkendrick.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Francis J. Keating

/s/

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Page 1

BRAUN KENDRICK 

FRANCIS J. KEATING 

ATTORNEYS AT LAW 

Attorney 

TEL: 989.631.1027 

FAX: 989.631.9880 

EMAIL: frakea@braunkendrick.com 

September 28, 2026 

VIA E-MAIL: taxtrib@michigan.gov 

Ms. Samantha M. Welton 

Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

Re: 

Canyon Venture III LLC v Township of Saginaw 

MTT Docket No.: 26-001448 

Dear Ms. Welton: 

Enclosed please find Respondent's Appearance and Proof of Service for the above-referenced matter. 

Please file the same in your usual manner. 

Thank you for your attention to this matter. 

If you have any questions regarding it, please contact me. 

Ve 

RANCIS 

J. KEATING 

FIK/ls 

Enclosures 

cc: 

Client (w/encs) 

Aaron M. Fales (w/encs) 

4920-3338-3124, v. 

1 

BRAUN KENDRICK FINKBEINER PLC. 

MIDLAND 

SAGINAW 

MT. PLEASANT 

1864 

BRAUNKENDRICK.COM

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURE III LLC, 

Petitioner, 

MTT Docket No.: 26-001448 

v 

TOWNSHIP OF SAGINAW, 

Respondent. 

LAW OFFICES OF AARON M. FALES, P.C. 

BRAUN KENDRICK FINKBEINER P.L.C. 

By: 

Aaron M. Fales (P72864) 

By: 

Francis J. Keating (P39223) 

Attorney Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Suite 350 

4301 Fashion Square Blvd. 

Birmingham, MI 48009 

Saginaw, MI 48603 

(248) 767-9840 

(989) 498-2100 

afaleslaw(@gmail.com 

frakea@braunkendrick.com 

APPEARANCE 

NOW COMES Braun Kendrick Finkbeiner P.L.C., by Francis 

J. Keating, and hereby 

enters its Appearance on behalf of Respondent, Township of Saginaw. 

BRAUN KENDRICK FINKBEINER P.L.C. 

Dated: September 77, 2026 

BY 

FRANCIS 

/ATING (P39223) 

Attorne 

for Respondent 

4908-3368-0852, v. 1

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURE IIT LLC, 

Petitioner, 

MTT Docket No.: 26-001448 

\% 

TOWNSHIP OF SAGINAW, 

Respondent. 

LAW OFFICES OF AARON M. FALES, P.C. 

BRAUN KENDRICK FINKBEINER P.L.C. 

By: 

Aaron M. Fales (P72864) 

By: 

Francis J. Keating (P39223) 

Attorney Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Suite 350 

4301 Fashion Square Blvd. 

Birmingham, MI 48009 

Saginaw, MI 48603 

(248) 767-9840 

(989) 498-2100 

afaleslaw(@gmail.com 

frakea@braunkendrick.com 

PROOF OF SERVICE 

LEE STADLER, duly sworn, deposes and says that she is a secretary in the employ of 

BRAUN KENDRICK FINKBEINER P.L.C., attorneys for the Respondent, Township of Saginaw, 

and states that on the A9¥day 

of September, 2026, she served 

a copy of Respondent’s 

Appearance via first class mail, by placing same in an envelope with sufficient postage attached 

and plainly addressed to: Aaron M. Fales, 330 Hamilton Row, Suite 350, Birmingham, MI 48009. 

a Voc A~ 

LEE STADLER 

4902-7315-1444, v. 1

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26 - SAG T - Canyon POS.pdfRead complete document text →
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Page 1

CANYON VENTURES HI LLC, 

Petitioner, 

TOWNSHIP OF SAGINAW, 

Respondent. 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

MTT Docket # 26-001448 

PROOF OF SERVICE 

Aaron M. Fales, being duly sworn, deposes and says that on September /< 

2026 he served a 

copy of Petitioner's Petition on the parties named on the attached list. 

Aaron M. Fales

Page 2

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Canyon Venture lll LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001448 

Township 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 12, 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 3

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

SAGINAW 

1315S. WASHINGTON AVENUE 

SAGINAW, MI 48401 

ASSESSOR 

SAGINAW 

1315S. WASHINGTON AVENUE 

SAGINAW, Mi 48601 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

SAGINAW COUNTY 

111 8. MICHIGAN AVENUE 

SAGINAW, MI 48602-2019 

DIRECTOR OF EQUALIZATION 

SAGINAW COUNTY 

117 

8S. MICHIGAN AVENUE 

SAGINAW, MI 48602-2019 

SECRETARY OF SCHOOL BOARD 

SAGINAW CITY SCHOOL DISTRICT 

550 MILLARD STREET 

SAGINAW CITY, MI 48407-1140 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, Mi 48922

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURES Ill LLC, 

Petitioner, 

MTT Docket #26- 001448 

vs. 

Parcel No. 23-12-4-16-3008-006 

SAGINAW CHARTER TOWNSHIP, 

Respondent. 

/ 

AMENDED PETITION 

CANYON VENTURES 

Hit LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales, P.C., says: 

1. 

Petitioner's principal office address 

is 30201 Orchard Lake Rd. 

, Ste. 

110, Farmington 

Hills, MI 48334. 

Petitioner 

is a party in interest with respect to 

property faxes on real property tax parcel no. 23-12-4-16-3008-006 (“Petitioner's 

Property"), at 4598 State St., Saginaw, MI, 48603. 

2. 

Respondent, Saginaw Township assesses and collects property taxes 

on Petitioner's Property. 

3. 

In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $977,300 and assessed Petitioner's Property at $977,300 resulting in 

a state equalized value of the same amount based on the tenative equalization

Page 5

4, 

Petitioner's 

Property 

is 

classified 

as Commercial 

Real 

Property. 

Petitioner's Property 

is commercial property. 

Petitioner believes that

Page 6

(dj

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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: 26-001448

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 - SAG T - Canyon POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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2026 AMENDED Petition - JK - 4598 State.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURES III LLC, 

Petitioner, 

vs. 

SAGINAW CHARTER TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 23-12-4-16-3008-006 

 

AMENDED PETITION 

 

 

CANYON VENTURES III LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 30201 Orchard Lake Rd. , Ste. 

110, Farmington Hills, MI 48334. Petitioner is a party in interest with respect to 

property taxes on real property tax parcel no. 23-12-4-16-3008-006 ("Petitioner's 

Property"), at 4598 State St., Saginaw, MI, 48603. 

 

2. 

Respondent, Saginaw Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

 In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $977,300 and assessed Petitioner's Property at $977,300 resulting in 

a state equalized value of the same amount based on the tenative equalization 

factor. 

001448

Page 2

4. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is commercial property. Petitioner believes that Petitioner's 

Property was designed to be used as a commercial 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 $977,300 to 

$500,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $977,300 to $500,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Suite 350 

 Birmingham, MI 48009 

 (248) 767-9840 

 

 

 

 

9/14/26

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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: 26-001448

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

Party Filing Document 

Petitioner

Files

Document Type: Amended Petition

Attachment File Name: 2026 AMENDED Petition - JK - 4598 State

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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2026 Petition - JK - 4598 State.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURES III LLC, 

Petitioner, 

vs. 

SAGINAW CHARTER TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 23-12-4-16-3008-06 

 

PETITION 

 

 

CANYON VENTURES III LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 30201 Orchard Lake Rd. , Ste. 

110, Farmington Hills, MI 48334. Petitioner is a party in interest with respect to 

property taxes on real property tax parcel no. 23-12-4-16-3008-06 ("Petitioner's 

Property"), at 4598 State St., Saginaw, MI, 48603. 

 

2. 

Respondent, Saginaw Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

 In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $977,300 and assessed Petitioner's Property at $977,300 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 Commercial Real Property. 

Petitioner's Property is commercial property. Petitioner believes that Petitioner's 

Property was designed to be used as a commercial 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 $977,300 to 

$500,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $977,300 to $500,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 26, 2026 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Suite 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

Canyon Venture III LLC

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

30201 Orchard Lake Rd.

City or Town

Farmington Hills

State

Michigan

ZIP Code

48334

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]

4598 State St.

Saginaw

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48603

Taxing Authority (City or Township)

Township 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:

23-12-4-16-3008-06

Classification of Property: Real (check one)

Commercial (check one)

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

977300

Current Taxable Value as established by the Board of Review:

977300

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

1000000

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

500000

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

500000

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: 26052686960383

Supporting Waiver Documents:

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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

Canyon Venture III LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001448

Township 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 12, 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

Canyon Venture III LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001448

Township 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 12, 2026

PROOF OF SERVICE

I certify

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURES III LLC, 

Petitioner, 

vs. 

SAGINAW CHARTER TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 23-12-4-16-3008-06 

 

PETITION 

 

 

CANYON VENTURES III LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 30201 Orchard Lake Rd. , Ste. 

110, Farmington Hills, MI 48334. Petitioner is a party in interest with respect to 

property taxes on real property tax parcel no. 23-12-4-16-3008-06 ("Petitioner's 

Property"), at 4598 State St., Saginaw, MI, 48603. 

 

2. 

Respondent, Saginaw Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

 In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $977,300 and assessed Petitioner's Property at $977,300 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 Commercial Real Property. 

Petitioner's Property is commercial property. Petitioner believes that Petitioner's 

Property was designed to be used as a commercial 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 $977,300 to 

$500,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $977,300 to $500,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 26, 2026 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Suite 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

Canyon Venture III LLC

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

30201 Orchard Lake Rd.

City or Town

Farmington Hills

State

Michigan

ZIP Code

48334

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]

4598 State St.

Saginaw

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48603

Taxing Authority (City or Township)

Township 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:

23-12-4-16-3008-06

Classification of Property: Real (check one)

Commercial (check one)

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

977300

Current Taxable Value as established by the Board of Review:

977300

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

1000000

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

500000

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

500000

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: 26052686960383

Supporting Waiver Documents:

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