Flagstar Bank, N.A., Petitioner Vs. City Of Jackson, Respondent

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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

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

Flagstar Bank N.A., 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001690 

 

City of Jackson, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

 

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%, 

(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, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001690 

Page 2 of 2 

 

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: November 24, 2025 

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 

FLAGSTAR BANK, N.A,, 

Petitioner, 

v 

MTT Docket No. 25-001690 

CITY OF JACKSON, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

Property Parcel No: 4-0264.1000 

3. 

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

Board of Review are: 

2025 True Cash Value (TCV) 

2025 AV/SEV 

2025 TV 

$1,942,200 

$971,100 

$773,085 

4, 

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

settlement purposes are: 

2025 True Cash Value (TCV) 

2025 AV/SEV 

2025TV 

$1,400,000 

$700,000 

$700,000 

LH 

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 

Tribunal's authority over those tax year or years (attach additional page 

if 

necessary): 

6. 

List separately any special terms 

or conditions being proposed by the 

parties that would affect the execution of this Consent Judgment including, 

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

etc.:

Page 2

MTT Docket No. 25-0016%90 

Entire Tribunal Consent Judgment 

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

P.C. AND SENT CARE OF SAID COUNSEL TO 330 HAMILTON ROW, SUITE 350, 

BIRMINGHAM, MI 48009. 

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

City of Jackson 

Attorneys for ys 

Respondent, 

By: Fz all 

By: 77 

Aaron Fales (P72864) 

Matthew Haggert 

/ 

330 Hamilton Row, Ste. 350 

Jackson City Attorney 

Birmingham, MI 48009 

161 W Michigan Ave. 

248-767-9840 

Jackson, MI 49201 

aaron@afaleslaw.com 

517-788-4050 

mhaggerty@cityofjackson.org 

Dated: 

_11/20/25 

Dated: 

//- zo-25

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

FLAGSTAR BANK, N.A,, 

Petitioner, 

v 

MTT Docket No. 25-001690 

CITY OF JACKSON, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

Property Parcel No: 4-0264.1000 

3. 

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

Board of Review are: 

2025 True Cash Value (TCV) 

2025 AV/SEV 

2025 TV 

$1,942,200 

$971,100 

$773,085 

4, 

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

settlement purposes are: 

2025 True Cash Value (TCV) 

2025 AV/SEV 

2025TV 

$1,400,000 

$700,000 

$700,000 

LH 

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 

Tribunal's authority over those tax year or years (attach additional page 

if 

necessary): 

6. 

List separately any special terms 

or conditions being proposed by the 

parties that would affect the execution of this Consent Judgment including, 

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

etc.:

Page 2

MTT Docket No. 25-0016%90 

Entire Tribunal Consent Judgment 

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

P.C. AND SENT CARE OF SAID COUNSEL TO 330 HAMILTON ROW, SUITE 350, 

BIRMINGHAM, MI 48009. 

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

City of Jackson 

Attorneys for ys 

Respondent, 

By: Fz all 

By: 77 

Aaron Fales (P72864) 

Matthew Haggert 

/ 

330 Hamilton Row, Ste. 350 

Jackson City Attorney 

Birmingham, MI 48009 

161 W Michigan Ave. 

248-767-9840 

Jackson, MI 49201 

aaron@afaleslaw.com 

517-788-4050 

mhaggerty@cityofjackson.org 

Dated: 

_11/20/25 

Dated: 

//- zo-25

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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

Flagstar Bank, N.A., 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001690

City Of Jackson,

Respondent.

ORDER SETTING ASIDE DEFAULT

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

Respondent was held in default on October 15, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: November 6, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Flagstar Bank, N.A., 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001690

City Of Jackson,

Respondent.

ORDER SETTING ASIDE DEFAULT

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

Respondent was held in default on October 15, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: November 6, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

FLAGSTAR BANK, FSB, 

Petitioner, 

-VS- 

CITY OF JACKSON, 

Respondent. 

MTT Docket No. 25-001690 

Parcel No. 4-0264.1000 

ANSWER TO PETITION AND 

AFFIRMATIVE DEFENSES 

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

BY: Aaron M. Fales (P72864) 

Attorney for Petitioner 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

JACKSON CITY ATTORNEY'S OFFICE 

BY: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

RESPONDENT CITY OF JACKSON’S 

ANSWER 

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

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

I. 

Respondent admits the allegation contained in Paragraph 1 of Petitioner’s Petition. 

2. 

Respondent admits the allegation contained in Paragraph 2 of Petitioner’s Petition. 

3. 

Respondent admits the allegation contained in Paragraph 3 of Petitioner’s Petition. 

4. 

Respondent neither admits nor denies the allegation contained in Paragraph 4 of 

Petitioner’s Petition and leaves Petitioner to its proofs.

Page 2

5. 

Respondent neither admits or denies the allegations made 

in Paragraph 

5 

of 

Petition’s Petition and leaves Petitioner to its proofs. 

6. 

Respondent admits the allegation contained in Paragraph 6 of Petitioner’s Petition. 

7. 

Respondent denies the allegations of paragraph 7(a)-(d) inclusive, as untrue and 

further constitutes a legal conclusion. 

The property’s Assessed Value is 50% of the True Cash 

Value. 

WHEREFORE, 

Respondent 

requests 

this Honorable 

Tribunal 

dismiss 

Petitioner’s 

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

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

be just and equitable. 

Respectfully submitted, 

DATED: October 22, 2025 

BY: 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

Page 3

AFFIRMATIVE DEFENSES 

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

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

1. 

The property’s assessed, true cash and taxable values are levied in accordance with the 

Michigan General Property Tax Act and Michigan Constitution. 

2. 

The property is assessed in accordance with generally accepted assessing standards. 

3. 

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

4. 

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

5. 

Respondent reserves the right to amend its affirmative defenses through the conclusion 

of discovery. 

Respectfully submitted, 

DATED: October 22, 2025 

BY: 

y 

4 

4 

MATTHEW M. HAGERTY/(P66015) 

MARK M. PORTE 

(P57917) 

Office of the City Attorney 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201 

CERTIFICATE OF SERVICE 

STATE OF MICHIGAN 

) 

) ss 

COUNTY OF JACKSON 

) 

The undersigned certifies under penalty of perjury that on October 22, 2025 she served copies of 

Respondent City 

of Jackson’s Answer 

to Petition and Affirmative Defenses upon the 

Petitioner by first class mail with postage fully prepaid to the following address: 

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

Attorney for Petitioner 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

3

Page 4

DATED: 

October 22, 2025 

Revit» fHrtdtetC 

ROBERTA HUBBELL

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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. 25-001690

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Jackson (JACKSON)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Matthew

M.I.

M.

Last Name

Hagerty

Firm Name (if any)

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

161 W. Michigan Ave.

City or Town

Jackson

State

Michigan

ZIP Code

49201

Telephone Number

517-788-4050

Fax Number

866-971-2117

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

mhagerty@cityofjackson.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Matthew M. Hagerty

/s/

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Flagstar Bank, N.A.,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001690

City Of Jackson,

Respondent.

ORDER OF DEFAULT

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

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

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

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

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

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: October 15, 2025

Patricia L. Halm, Tribunal Chair

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

i “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received.

Page 2

MTT Docket No. 25-001690

Page 2 of 6

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Flagstar Bank, N.A.,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001690

City Of Jackson,

Respondent.

ORDER OF DEFAULT

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

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

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

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

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

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.ii 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: October 15, 2025

Patricia L. Halm, Tribunal Chair

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

ii “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is

Page 4

MTT

Page 5

S

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

FLAGSTAR BANK N.A., 

Petitioner, 

Vv. 

MTT Docket # 25-001690 

CITY OF JACKSON, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

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

Wf 

; 

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

ee 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

AND BY FIRST-CLASS UNITED STATES MAIL:

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Flagstar Bank, N.A., 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-001690 

City Of Jackson, 

Respondent. 

NOTICE OF DOCKET NUMBER 

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case. 

Under TTR 235(1), “[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: July 22, 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 

FLAGSTAR BANK, N.A., 

Petitioner, 

MTT Docket #25- OU LA0 

vs: 

Parcel No. 4-0264.1000 

CITY OF JACKSON, 

Respondent. 

/ 

PETITION 

FLAGSTAR BANK, N.A. (“Petitioner”), through 

its attorneys, Law Office of 

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

1: 

Petitioner's principal office address 

is 5151 

Corporate 

Dr., Troy, MI 

48098. 

Petitioner 

is a party 

in interest with respect to property taxes on real 

property tax parcel no. 4-0264.1000 ("Petitioner's Property"), at 301 W Michigan 

, 

Jackson, MI. 

2. 

Respondent, City of Jackson assesses and collects property taxes 

on Petitioner's Property. 

3. 

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

Property to be $773,085 and assessed Petitioner's Property at $971,100 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 fo 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. 

7s 

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: 

(@) 

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 6

(d) 

The 

assessment, 

including

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

FLAGSTAR BANK, N.A., 

Petitioner, 

vs. 

CITY OF JACKSON, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 4-0264.1000 

 

PETITION 

 

 

FLAGSTAR BANK, N.A. (“Petitioner”), through its attorneys, Law Office of 

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

 

1. 

Petitioner's principal office address is 5151 Corporate Dr., Troy, MI 

48098. Petitioner is a party in interest with respect to property taxes on real 

property tax parcel no. 4-0264.1000 ("Petitioner's Property"), at 301 W Michigan , 

Jackson, MI. 

 

2. 

Respondent, City of Jackson assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $773,085 and assessed Petitioner's Property at $971,100 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 $773,085 to 

$500,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $971,100 to $500,000, 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

Flagstar Bank, N.A., 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001690

City Of Jackson, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: July 22, 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 

FLAGSTAR BANK, N.A., 

Petitioner, 

vs. 

CITY OF JACKSON, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 4-0264.1000 

 

PETITION 

 

 

FLAGSTAR BANK, N.A. (“Petitioner”), through its attorneys, Law Office of 

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

 

1. 

Petitioner's principal office address is 5151 Corporate Dr., Troy, MI 

48098. Petitioner is a party in interest with respect to property taxes on real 

property tax parcel no. 4-0264.1000 ("Petitioner's Property"), at 301 W Michigan , 

Jackson, MI. 

 

2. 

Respondent, City of Jackson assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

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

Property to be $773,085 and assessed Petitioner's Property at $971,100 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 $773,085 to 

$500,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $971,100 to $500,000, 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

Flagstar Bank, N.A.

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

5151 Corporate Dr

City or Town

Flagstar Bank FSB

State

Michigan

ZIP Code

48098

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)

City Of Jackson (JACKSON)

County

Jackson

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

4-0264.1000

Classification of Property: Real 

Commercial

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

971100

Current Taxable Value as established by the Board of Review:

773085

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

1000000

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

500000

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

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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