Cmg Pcp Associates LLC, Petitioner Vs. Township Of Washington, 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 

CMG PCP Associates LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001813 

 

Washington Township, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

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, 2013, through June 30, 2016, at the rate of 4.25%, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001813 

Page 2 of 2 

 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

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

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

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

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

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

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

and (xix) after December 31, 2025, through June 30, 2026, at a 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: January 12, 2026 

am 

 

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 HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

v 

MTT Docket No. 25-001813 

WASHINGTON TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

These cases is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

The Property Parcel is No: 24-04-14-100-034 

3. 

The values for the property identified above as established by Respondent's 

Board of Review are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Valve 

Assessed Value 

Value 

2025 

$2,070,600 

$1,035,300 

$763,221 

4. 

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

settlement purposes are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Value 

Assessed Value 

Value 

2025 

$1,400,000 

$700,000 

$700,000 

5. 

If 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

Page 2

MTT Docket No. 25-001813 

Entire Tribunal Consent Judgment 

but not limited to, the joint payment of the refund, the waiver of interest, 

etc.: 

REFUNDS ARE TO BE MADE PAYABLE TO THE LAW OFFICE OF AARON M. FALES, 

P.C. AND SENT CARE OF SAID COUNSEL TO: LAW OFFICE OF AARON FALES 

PC 330 HAMILTON ROW, STE. 350, BIRMINGHAM, MI 48009. 

WHEREFORE, the parties hereto respectfully request the Tribunal grant the Parties 

Stipulation, and order any other relief as necessary in this matter. 

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

SIEBERT & DLOSKI, PLLC 

Attorneys for Petitioner, 

Attorneys for Respondent, 

By: Lz a 

By: 

be § 

Mh / NA~— 

Aaron Fales (P72864) 

Christine D. Anderson 

330 Hamilton Row, Suite 350 

19500 Hall Road, Ste 101 

Birmingham, MI 48009 

Clinton Township, MI 48038 

248-767-9840 

586.469.3800 

Dated: 

1/1226 

Dated: 

[ 

3 

2 

1/12/26

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

v 

MTT Docket No. 25-001813 

WASHINGTON TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

These cases is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

The Property Parcel is No: 24-04-14-100-034 

3. 

The values for the property identified above as established by Respondent's 

Board of Review are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Valve 

Assessed Value 

Value 

2025 

$2,070,600 

$1,035,300 

$763,221 

4. 

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

settlement purposes are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Value 

Assessed Value 

Value 

2025 

$1,400,000 

$700,000 

$700,000 

5. 

If 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

Page 2

MTT Docket No. 25-001813 

Entire Tribunal Consent Judgment 

but not limited to, the joint payment of the refund, the waiver of interest, 

etc.: 

REFUNDS ARE TO BE MADE PAYABLE TO THE LAW OFFICE OF AARON M. FALES, 

P.C. AND SENT CARE OF SAID COUNSEL TO: LAW OFFICE OF AARON FALES 

PC 330 HAMILTON ROW, STE. 350, BIRMINGHAM, MI 48009. 

WHEREFORE, the parties hereto respectfully request the Tribunal grant the Parties 

Stipulation, and order any other relief as necessary in this matter. 

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

SIEBERT & DLOSKI, PLLC 

Attorneys for Petitioner, 

Attorneys for Respondent, 

By: Lz a 

By: 

be § 

Mh / NA~— 

Aaron Fales (P72864) 

Christine D. Anderson 

330 Hamilton Row, Suite 350 

19500 Hall Road, Ste 101 

Birmingham, MI 48009 

Clinton Township, MI 48038 

248-767-9840 

586.469.3800 

Dated: 

1/1226 

Dated: 

[ 

3 

2 

1/12/26

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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

NOTICE OF NOVEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

CMG PCP Associates LLC,

Petitioner,

v

 

 

Township Of Washington,

Respondent.

 MTT Docket No. 25-001813

Please be advised that 25-001813 has been placed on a two-week Prehearing General 

Call commencing November 16, 2026. Unless ordered otherwise, parties will be 

notified at least 28 days before they are scheduled to appear. Scheduling will not 

necessarily occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 25-001813

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by July 20, 2026. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by July 20, 2026. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

July 20, 2026, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

November 16, 2026, which means all discovery has been requested, all Motions to 

Compel have been filed, and all requested or ordered discovery has been exchanged 

by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s 

valuation disclosure, the opposing party’s valuation expert, and the witnesses identified 

on the opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any

Page 3

MT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

-VS- 

MOAHR Docket No: 25-001813 

TOWNSHIP OF WASHINGTON, 

Respondent. 

/ 

AARON M. FALES (P72864) 

CHRISTINE D. ANDERSON (P45141) 

Attorney for Petitioner 

Attorney for Respondent 

330 Hamilton Row, Ste. 350 

SEIBERT AND DLOSKI, PLLC 

Birmingham, MI 

48009 

19500 Hall Road, Suite 101 

(248)767-9840 

Clinton Township, MI 48038 

afaleslaw@amail.com 

(586) 469-3800 

canderson@seibertanddloski.com 

PROOF OF SERVICE 

KATHLEEN J. HAMEL states that she is an employee of Seibert and Dloski, PLLC 

and that on September 26, 2025, she served Charter Township of Washington's Answer 

to Petition and this Proof of Service upon counsel of record listed in the above-referenced 

caption via email. 

| declare the above is true and correct to the best of my knowledge, 

information and belief. 

/)

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

-Vs- 

MOAHR Docket No: 25-001813 

TOWNSHIP OF WASHINGTON, 

Respondent. 

/ 

AARON M. FALES (P72864) 

CHRISTINE D. ANDERSON (P45141) 

Attorney for Petitioner 

Attorney for Respondent 

330 Hamilton Row, Ste. 350 

SEIBERT AND DLOSKI, PLLC 

Birmingham, MI 

48009 

19500 Hall Road, Suite 101 

(248)767-9840 

Clinton Township, MI 48038 

afaleslaw@amail.com 

(586) 469-3800 

canderson@seibertanddloski.com 

RESPONDENT'S ANSWER TO PETITION 

The 

Charter Township 

of Washington 

(“Respondent”), 

by 

and 

through 

its 

attorneys, SEIBERT AND DLOSKI, PLLC, answers the Petition as follows: 

1. 

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

allegations contained in Paragraph 1. 

2. 

Respondent admits the allegations contained in Paragraph 2. 

3. 

Respondent admits the allegations contained in Paragraph 3.

Page 2

5. 

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

allegations contained in Paragraph 5. 

6. 

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

allegations contained in Paragraph 6. 

7. 

Respondent denies the allegations contapined in Paragraph 7 as they are 

untrue and further denies Petitioner is entitled to the requested relief as the subject parcel 

was lawfully and uniformally assessed for the tax year at issue. 

WHEREFORE, 

the Respondent respectfully requests the Tax Tribunal 

dismiss the Petition and award the Respondent its costs and attorney fees. 

Respectfully submitted, 

os AND DLOSKI, PLLC 

Jay. 

By: Christine D. Anderson (P45141) 

Attorney for Roe 

SEIBERT AND DLOSKI, PLLC 

19500 Hall Road, Suite 101 

Clinton Township, MI 48038 

Dated: September 26, 2025 

(586) 469-3800

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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. 25-001813

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Washington (MACOMB)

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

Christine

M.I.

D

Last Name

Anderson

Firm Name (if any)

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

19500 Hall Rd Ste 101

City or Town

Clinton Twp

State

Michigan

ZIP Code

48038

Telephone Number

586-469-3800

Fax Number

586-469-2443

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

canderson@seibertanddloski.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Christine D. Anderson

/s/

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES LLC, 

Petitioner, 

V. 

MTT Docket # 25-001813 

TOWNSHIP OF WASHINGTON, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

3/7 

a gll 

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

y 

2025 he served a copy of Petitioner's Petition on the parties named on the attached list. 

er 

iil 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

Washington Township Assessor 

57900 Van Dyke 

Washington, MI 48094 

Washington Township Clerk 

57900 Van Dyke 

Washington, MI 48094 

AND BY FIRST CLASS UNITED STATES MAIL: 

Macomb County Equalization Director 

10 N Main, 3" Floor 

Mt. Clemens, MI 48043 

Macomb County Clerk 

1% Floor — Court Bldg. 

40 N Main Street 

Mt. Clemens, MI 48043 

Romeo Community Schools 

Secretary of the School Board 

316 N. Main St. 

Romeo, MI 48065 

State Treasurer 

Michigan Department of Treasury 

Treasury Building 

430 W. Allegan St. 

Lansing, MI 48922

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

CMG PCP Associates LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-001813 

Township Of Washington, 

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 205.7354, 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 Tribunals rules. 

By: __ Tribunal Clerk 

Entered: July 24, 2025 

PROOF OF SERVICE 

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

parties or their attorneys or authorized representatives, 

if any, utilizing either the mailing 

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

representatives. 

By: Tribunal Clerk 

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

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

MTT Docket #25. 001813 

Vs. 

Parcel No. 24-04-14-100-034 

WASHINGON TOWNSHIP, 

Respondent. 

/ 

PETITION 

CMG PCP ASSOCIATES, LLC (“Petitioner”), through its attorneys, Law Office 

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

1 

Petitioner's principal office address 

is 43900 Garfield 

Rd., Ste. 203, 

Clinton Twp., MI 48038. 

Petitioner 

is a party in interest with respect to property 

taxes on real property tax parcel no. 24-04-14-100-034 ("Petitioner's Property"), at 

64582 Van Dyke Ave., Washington, MI. 

2: 

Respondent, Washington Township assesses and collects property 

taxes on Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $763,221 and assessed Petitioner's Property at $1,035,300 resulting 

in 

a 

state 

equalized 

value 

of 

the same 

amount 

based 

on 

the 

tenative 

equalization factor.

Page 5

4. 

Petitioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

Petitioner's Property 

is an office Building. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for 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 2025 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

Page 6

(d)

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

vs. 

WASHINGON TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 24-04-14-100-034 

 

PETITION 

 

 

CMG PCP ASSOCIATES, LLC (“Petitioner”), through its attorneys, Law Office 

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

 

1. 

Petitioner's principal office address is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 24-04-14-100-034 ("Petitioner's Property"), at 

64582 Van Dyke Ave., Washington, MI. 

 

2. 

Respondent, Washington Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

 In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $763,221 and assessed Petitioner's Property at $1,035,300 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 an office Building. Petitioner believes that Petitioner's 

Property was originally designed to be used for 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 2025 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 2025 taxable value of Petitioner's Property from $763,221 to 

$550,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $1,035,300 to $550,000, and requiring Respondent to 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 29, 2025 

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

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

CMG PCP Associates LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001813

Township Of Washington, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: July 24, 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 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

vs. 

WASHINGON TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 24-04-14-100-034 

 

PETITION 

 

 

CMG PCP ASSOCIATES, LLC (“Petitioner”), through its attorneys, Law Office 

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

 

1. 

Petitioner's principal office address is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 24-04-14-100-034 ("Petitioner's Property"), at 

64582 Van Dyke Ave., Washington, MI. 

 

2. 

Respondent, Washington Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

 In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $763,221 and assessed Petitioner's Property at $1,035,300 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 an office Building. Petitioner believes that Petitioner's 

Property was originally designed to be used for 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 2025 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 2025 taxable value of Petitioner's Property from $763,221 to 

$550,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $1,035,300 to $550,000, and requiring Respondent to 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 29, 2025 

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

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

CMG PCP Associates LLC

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

43900 Garfield Rd.

Suite 203

City or Town

Clinton Twp.

State

Michigan

ZIP Code

48038

Telephone Number

2487679840

Fax Number

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

aaron@afaleslaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Aaron

M.I.

M

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, Ste. 350

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-767-9840

Fax Number

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

afaleslaw@gmail.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]

Michigan

Taxing Authority (City or Township)

Township Of Washington (MACOMB)

County

Macomb

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:

24-04-14-100-034

Classification of Property: Real 

Commercial

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

1035300

Current Taxable Value as established by the Board of Review:

763221

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

1100000

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

550000

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 Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Aaron Fales

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