Cmg Trillium, LLC, Petitioner Vs. Township Of Clinton, 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 Trillium, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002167

Township Of Clinton,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: June 16, 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

CMG Trillium, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002167

Township Of Clinton,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: June 16, 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

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.

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

 

CMG TRILLIUM, LLC, 

 

 

 

Petitioner, 

 

v 

 

CLINTON TOWNSHIP, 

 

Respondent.

 

 

 

 

MOAHR Docket No. 25-002167 

 

 

_____________________________________________________________________________/ 

 

Aaron M. Fales (P72864) 

Law Office of Aaron M. Fales, P.C. 

Attorney for Petitioner 

330 Hamilton Row, Suite 350 

Birmingham, MI 48009 

(248) 767-9840 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, Michigan 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO WITHDRAW 

 

 

Petitioner and Respondent, by and through their respective attorneys, jointly request the 

Tribunal withdraw this matter with no costs to either party. 

 

Respectfully Submitted, 

 

By: /s/ Aaron M. Fales 

Aaron M. Fales (P72864) 

Law Office of Aaron M. Fales, P.C. 

Attorney for Petitioner 

330 Hamilton Row, Suite 350 

Birmingham, MI 48009 

(248) 767-9840

 By: /s/ Laura M. Hallahan 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Hallahan & Associates, P.C. 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

 Date: 6/15/26 

 

 

 

 Date: 6/15/26

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.

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: 25-002167

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

Party Filing Document 

Joint

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Joint Motion to WD - CMG Tril Clinton

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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.

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 JANUARY 19 - 29, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

CMG Trillium, LLC,

Petitioner,

v

 

 

Township Of Clinton,

Respondent.

 MTT Docket No. 25-002167

Please be advised that 25-002167 has been placed on a two-week Prehearing General 

Call commencing January 19, 2027. 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. 25-002167

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 September 22, 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 September 22, 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 

September 22, 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 

January 19, 2027, 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 time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: February 17, 2026

Page 3

MTT Docket No. 25-002167

Page 3 of 3

PROOF OF SERVICE

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

parties or their

Page 4

STATE OF

Page 5

M

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.

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

CMG TRILLIUM, LLC, 

 

 

 

Petitioner, 

 

v 

 

CLINTON CHARTER TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-002167 

 

Parcel No. 16-11-19-477-005 

 

_____________________________________________________________________________/ 

 

AARON M. FALES (P72864) 

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

Attorney for Petitioner 

330 Hamilton Row, Suite 350 

Birmingham, MI 48009 

(248) 767-9840 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, Clinton Charter Township, by and through its attorneys, Hallahan & 

Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the truth 

of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

2

4. 

Respondent admits that subject property is classified as commercial real property. 

With respect to the remainder of the allegations set forth in Paragraph 4, Respondent lacks 

knowledge or information sufficient to form a belief as to the truth of the allegations contained 

therein and, therefore, leaves Petitioner to its proofs. 

5. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies 

Petitioner’s claims have merit and denies that Petitioner is entitled to any relief. 

6. 

Respondent acknowledges Petitioner’s belief of a dispute relative to a value of a 

loss but denies any such loss has occurred. 

7. 

Respondent denies the allegations in Paragraph 7, including subparagraphs (a)-(d), 

for the reason that the same are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional. 

8. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to its requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent, Clinton Charter Township, requests the Tribunal dismiss the 

Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, 

and award Respondent its costs and attorney fees.

Page 3

3

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: October 24, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Clinton Charter Township, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

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

Page 4

4

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. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

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

12.

Page 5

5

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.

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. 25-002167

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Clinton (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

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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.

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

oO 

MG TRILLIUM LLC, 

Petitioner, 

v. 

MTT Docket # 25-002167 

CLINTON TOWNSHIP, 

Respondent. 

PROOF 

OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on September 26, 2025 he served a 

>f Petitioner’s Petition on the parties named on the attached list. 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

CLINTON TWP. - MACOMB 

40700 ROMEO PLANK ROAD 

CLINTON TWP., MI 48038-2617 

ASSESSOR 

CLINTON TWP 

- MACOMB 

40700 ROMEO PLANK ROAD 

CLINTON TWP., MI 48038-2917 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., STH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

CLINTONDALE COMMUNITY SCHOOLS 

35100 LITTLE MACK AVENUE 

CLINTON TWP., MI 48035-2633 

STATE TREASURER 

MICHIGAN DEPARTVIENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING MT 48927.

Page 3

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG TRILLIUM, LLC, 

Petitioner, 

MTT Docket #25. 

00 2167( 

Parcel No. 16-11-19-477-005 

CLINTON CHARTER TOWNSHIP, 

Respondent. 

vl 

PETITION 

CMG 

TRILLIUM, 

LLC 

(“Petitioner”), through 

its attorneys, Law Office 

of 

Acron M. Fales, 

P.C., says: 

1. 

Petitioner's principal office address 

is 43900 Garfield 

Rd., Ste. 203, 

Zinfon Twp., MI 48038. 

Petitioner is a party in interest with respect to property 

foxes on real property tax parcel no. 16-11-19-477-005 ("Petitioner's Property"), at 

37399 Garfield, Clinton Twp., Ml 48036. 

2. 

Respondent, Clinfon Township assesses and collects property taxes 

on Petitioner's Property. 

3. 

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

Froperty 

to 

be 

$1,792,055 

and 

assessed 

Petitioner's 

Property 

at 

$2,592,500 

‘sulting In a state equalized value of the same amount based on the tenative 

equalization factor.

Page 4

4. 

Petitioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

ier's Property 

is an office 

Building. 

Petitioner believes that 

Petitioner's 

operiy was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, 

taxable value, and (d) uniformity. 

At this time, Petitioner believes, as 

it relates to taxable value, that 

sre is a dispute relative to the value of a loss. 

he 2025 assessment, including state equalized value and taxable 

lve, 

Imposed 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

llected thereon, 

are invalid and unlawful and operate as a fraud upon the 

(payer for 

the reasons that: 

(a) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

a 

ble value, exceeds the amount permitted by the Michigan Constitution and 

fatutes; 

[®] 

lb) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

«ble 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 

ecualized value, are based upon an erroneous determination of the true cash

Page 5

(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 

$1,792,055 

to 

$1,000,000, and reducing 

the 

2025 assessed 

and 

state equalized values 

of 

Petitioner's Property from $2,592,500 to $1,000,000, and requiring Respondent to 

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

Respectfully submitted, 

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

Attorney for Petitioner 

NY Ad 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

By: 

Dated: May 29, 2025

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.

Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG TRILLIUM, LLC, 

Petitioner, 

vs. 

CLINTON CHARTER TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 16-11-19-477-005 

 

PETITION 

 

 

CMG TRILLIUM, 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. 16-11-19-477-005 ("Petitioner's Property"), at 

37399 Garfield, Clinton Twp., MI 48036. 

 

2. 

Respondent, Clinton Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $1,792,055 and assessed Petitioner's Property at $2,592,500 

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 $1,792,055 to 

$1,000,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $2,592,500 to $1,000,000, 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

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.

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 Trillium, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002167

Township Of Clinton, 

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 14, 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

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.

Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

CMG TRILLIUM, LLC, 

Petitioner, 

vs. 

CLINTON CHARTER TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 16-11-19-477-005 

 

PETITION 

 

 

CMG TRILLIUM, 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. 16-11-19-477-005 ("Petitioner's Property"), at 

37399 Garfield, Clinton Twp., MI 48036. 

 

2. 

Respondent, Clinton Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $1,792,055 and assessed Petitioner's Property at $2,592,500 

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 $1,792,055 to 

$1,000,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $2,592,500 to $1,000,000, 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

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.

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 Trillium, 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 Clinton (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:

16-11-19-477-005

Classification of Property: Real 

Commercial

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

2592500

Current Taxable Value as established by the Board of Review:

1792055

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

2000000

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

1000000

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

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.