Epr2 LLC Petitioner Vs. City Of Ann Arbor Respondent

Page 1

STATE OF MCHIGAN 

MICHIGAN TAX TRIBUNAL 

EPR2 LLC, 

 

Petitioner, 

V 

City of Ann Arbor, 

 

Respondent. 

MTT Docket No. 26-001496 

Aaron M. Fales (P72864) 

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

Attorney for Petitioner 

330 Hamilton Row, Suite 350 

Brimingham, Michigan 48009 

(248) 767-9840 

aaron@afaleslaw.com 

John W. Reiser (P45050) 

OFFICE OF THE CITY ATTORNEY 

Attorney for Respondent 

301 E. Huron Street, 3rd Floor 

Ann Arbor, Michigan 48104-1908 

(734) 794-6170 

jreiser@a2gov.org 

RESPONDENT CITY OF ANN ARBOR’S 

RESPONSE TO PETITION 

Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City 

Attorney’s Office, responds in opposition to the Petition of EPR2 LLC (“Petitioner”) 

as follows: 

1. 

Respondent leaves Petitioner to its proofs. 

2. 

Admit. 

3. 

Admit. 

4. 

Respondent leaves Petitioner to its proofs. 

5. 

Respondent leaves Petitioner to its proofs as to (a) through (d). 

6. 

Respondent leaves Petitioner to its proofs.

Page 2

2 

7. 

Respondent leaves Petitioner to its proofs and denies subparagraphs (a) 

through (d) as untrue. 

For the reasons stated above, Respondent requests that the Tribunal deny 

Petitioner’s request and affirm its 2026 assessed and taxable values. 

Dated: October 13, 2026 

Respectfully submitted, 

OFFICE OF THE CITY ATTORNEY 

By: /s/ John W. Reiser 

 

 

John W. Reiser (P45050) 

Attorney for Respondent 

301 E. Huron Street, 3rd Floor 

Ann Arbor, Michigan 48104-1908 

(734) 794-6170 

jreiser@a2gov.org 

AFFIRMATIVE DEFENSES 

Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City 

Attorney’s Office, and for its Affirmative Defenses to the Petition of EPR2 LLC 

(“Petitioner”), states the following: 

1. 

Respondent reserves the right to raise affirmative defenses as the same 

become apparent in the court of this litigation. 

Dated: October 13, 2026 

Respectfully submitted, 

OFFICE OF THE CITY ATTORNEY 

By: /s/ John W. Reiser 

 

 

John W. Reiser (P45050) 

Attorney for Respondent 

301 E. Huron Street, 3rd Floor 

Ann Arbor, Michigan 48104-1908 

(734) 794-6170 

jreiser@a2gov.org

Page 3

3 

PROOF OF SERVICE 

I hereby certify that on October 13, 2026, I emailed a true and correct copy of 

the foregoing Response to Petition and Affirmative Defenses to the above-named 

attorney for petitioner at the address listed above. 

/s/ Dawn M. Bagozzi 

 

Legal Assistant

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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. 26-001496

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Ann Arbor (WASHTENAW)

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

John

M.I.

W.

Last Name

Reiser

Firm Name (if any)

City Attorneys Office

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

301 E. Huron Street, 3rd Floor

City or Town

Ann Arbor

State

 Michigan

ZIP Code

48104

Telephone Number

734-794-6170

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

jreiser@a2gov.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

John W. Reiser

/s/

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

EPRLLC, 

Petitioner, 

v. 

MTT Docket # 26-001496 

CITY OF ANN ARBOR, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

} ss. 

COUNTY OF OAKLAND) 

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

2026 he served a 

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

a 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

ANN ARBOR 

301 IL HURON STREET, P.O. BOX 8647 

ANN ARBOR, MI 48107-8647 

ASSESSOR 

ANN ARBOR 

301 E. HURON STREET, P.O. BOX 8647 

ANN ARBOR, MI 48107-8647 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WASHTENAW COUNTY 

PO BOX 8645 

ANN ARBOR, M} 48107-8645 

DIRECTOR OF EQUALIZATION 

WASHTENAW COUNTY 

PO BOX 8645 

ANN ARBOR, MT 48107-8645 

SECRETARY OF SCHOOL BOARD 

ANN ARBOR PUBLIC SCHOOLS 

2555 8. STATE STREET 

ANN ARBOR, MI 48104 

STATE TREASURER 

MICHIGAN DEPAR IMENT 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 |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

EPR2 LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001496 

City Of Ann Arbor, 

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), “[tlhe respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” 

Failure to do so 

will result in Respondent being placed in default. 

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

case. 

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

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

or the Tribunal's rules. 

By: Tribunal Clerk 

Entered: August 14, 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

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

EPR2 LLC, 

Petitioner, 

MTT Docket #26. 00149 

vs. 

Parcel No. 09-12-06-401-010 

CITY OF ANN ARBOR, 

Respondent. 

/ 

PETITION 

EPR2 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., Suite 

110, Farmington 

Hills, Ml 48334. 

Petitioner is a party in interest with respect to 

property taxes on 

real property tax parcel 

no. 09-12-06-401-010 

("Petitioner's 

Property"), at 905 W Eisenhower, Ann Arbor, Ml. 

2. 

Respondent, City of Ann Arbor assesses and collects property faxes 

on Petitioner's Property. 

3. 

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

Property to be $718,200 and assessed Petitioner's Property at $891,700 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 Petitioner's 

Property was designed to be used as 

a commercial purposes. 

5. 

This matter involves issues relating fo: {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 

equdlized 

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

Page 6

(d) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable 

value, 

and 

the 

mode 

of 

assessment 

adopted 

by 

Respondent, 

discriminate against Petitioner and deny Petitioner 

its constitutional 

rights 

to 

uniformity, equal protection and due process of law. 

WHEREFORE, 

Petitioner requests 

that 

the 

Tax Tribunal 

enter 

an Order 

reducing 

the 

2026 

taxable 

value 

of 

Petitioner's 

Property 

from 

$718,900 

to 

$400,000, 

and 

reducing 

the 

2026 

assessed 

and 

state 

equalized 

values 

of 

Petitioner's Property from $891,700 to $400,000, 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 

PAY 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, Ml 48009 

(248) 767-9840 

By: 

Dated: May 26, 2026

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001496

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 - EPR AA POS

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 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

EPR2 LLC, 

Petitioner, 

vs. 

CITY OF ANN ARBOR, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 09-12-06-401-010 

 

PETITION 

 

 

EPR2 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., Suite 

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

property taxes on real property tax parcel no. 09-12-06-401-010 ("Petitioner's 

Property"), at 905 W Eisenhower, Ann Arbor, MI. 

 

2. 

Respondent, City of Ann Arbor assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $718,900 and assessed Petitioner's Property at $891,700 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 $718,900 to 

$400,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $891,700 to $400,000, 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, 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

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

EPR2 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]

905 W Eisenhower

Ann Arbor

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48103

Taxing Authority (City or Township)

City Of Ann Arbor (WASHTENAW) 

County

Washtenaw

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:

09-12-06-401-010

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:

891700

Current Taxable Value as established by the Board of Review:

718900

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

800000

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

400000

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

400000

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: 26052686987183

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.

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

EPR2 LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001496

City Of Ann Arbor, 

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, 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 ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

EPR2 LLC, 

Petitioner, 

vs. 

CITY OF ANN ARBOR, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 09-12-06-401-010 

 

PETITION 

 

 

EPR2 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., Suite 

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

property taxes on real property tax parcel no. 09-12-06-401-010 ("Petitioner's 

Property"), at 905 W Eisenhower, Ann Arbor, MI. 

 

2. 

Respondent, City of Ann Arbor assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $718,900 and assessed Petitioner's Property at $891,700 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 $718,900 to 

$400,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $891,700 to $400,000, 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, 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

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

EPR2 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]

905 W Eisenhower

Ann Arbor

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48103

Taxing Authority (City or Township)

City Of Ann Arbor (WASHTENAW) 

County

Washtenaw

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:

09-12-06-401-010

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:

891700

Current Taxable Value as established by the Board of Review:

718900

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

800000

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

400000

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

400000

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: 26052686987183

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.