Fossores, Petitioner Vs. City Of Jackson, Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FOSSORES, 

Petitioner, 

v 

 

 

 

 

 

 

MTT Docket No. 24-004252 

CITY OF JACKSON, 

Respondent. 

 

PROOF OF SERVICE 

 

I certify that on October 1, 2026, I served a copy of Respondent’s Prehearing Statement upon 

Petitioner’s counsel of record, Ryan L. Phillips (P73731), Ryan L. Phillips PC, by email at 

ryan@phillipsprobatelaw.com 

 

I declare that the statement above is true to the best of my information, knowledge, and belief. 

 

/s/ Matthew M. Hagerty 

______________________________ 

 

Date: October 1, 2026 

Matthew M. Hagerty (P66015) 

Jackson City Attorney 

Attorney for Respondent City of Jackson 

161 W. Michigan Ave., Jackson, MI 49201

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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: 24-004252

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

Party Filing Document 

Other

Files

Document Type: Proof of Service: Misc Documents

Attachment File Name: Proof of Service MTT 24-004252 10.1.26

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FOSSORES, 

Petitioner, 

v 

 

 

 

 

 

 

MTT Docket No. 24-004252 

CITY OF JACKSON, 

Respondent. 

 

____ PETITIONER’S PROPERTY PREHEARING STATEMENT 

__X__ RESPONDENT’S PROPERTY PREHEARING STATEMENT 

 

Petitioner’s representative: Ryan L. Phillips PC, Ryan L. Phillips P73731 

Respondent’s representative: Jackson City Attorney’s Office, Matthew M. Hagerty P66015 

I. 

VALUATION INFORMATION: 

A. The true cash value (TCV), assessed value (AV), and taxable value (TV) for each 

parcel and tax year at issue as established by the Board of Review: 

Parcel Number: 2-005700000 

Year 

TCV 

AV 

TV 

2024 

374400 

187200 

186270 

2025 

530200 

265100 

192044 

2026 

478600 

239300 

197229 

 

B. Your contentions of TCV, state equalized value (SEV), and TV for each parcel and 

tax year at issue: 

Parcel Number: 2-005700000 

Year 

TCV 

SEV 

TV 

2024 

374400 

187200 

186270 

2025 

530200 

265100 

192044 

2026 

478600 

239300 

197229

Page 2

2 

 

C. Amounts in dispute for the tax year(s) at issue: 

Parcel Number: 2-005700000 

Year 

TCV 

SEV 

TV 

2024 

 

 

186270 

2025 

 

 

192044 

2026 

 

 

197229 

II. 

TAX INFORMATION: 

A. Have taxes been paid for each property for each tax year at issue? 

____ Yes __X__ No 

III. 

FACTUAL STATEMENT OF CLAIMS: 

A. Describe any additions or losses for each property for each tax year at issue (by 

parcel number and tax year): 

Not applicable. 

B. Classification of each property for each tax year at issue (by parcel number): 

Parcel 2-005700000: 201-Commercial. 

C. Current use of each property for each tax year at issue, if different than above (by 

parcel number): 

The subject property is utilized as an Airbnb rental property and is currently listed for 

sale. It is not used predominantly as a property owned and utilized by a religious society 

for religious services or for teaching the religious truths and beliefs of the society. 

D. Contention of highest and best use for each property for each tax year at issue, if 

different than property’s current use for each tax year at issue (by parcel number): 

Not applicable. Valuation is not in dispute. 

E. Your factual statement of claims in support of your contentions, including 

additions and losses, if any (i.e., what facts are you relying on in support of your 

claim or defense?): 

The subject property is not exempt from ad valorem taxation for the 2024, 2025, or 2026 

tax years. It was properly placed on the

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3

Page 4

4

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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: 24-004252

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

Party Filing Document 

Other

Files

Document Type: Prehearing Statement

Attachment File Name: Respondent Prehearing Statement MTT 24-004252

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPT. OF LICENSING AND REGULATORY AFFIRAS 

FOSSORES, a domestic nonprofit corporation, 

Petitioner, 

MICHIGAN TAX TRIBUNAL, 

ENTIRE TRIBUNAL 

MOAHR docket no. 24-004252 

CITY OF JACKSON, Respondent. 

Ryan L. Phillips PC 

City of Jackson 

Ryan L. Phillips P73731 

Mark M. Porterfield P57917 

Attorney for Petitioner 

Attorney for Respondent 

180 W Michigan Ave., suite 603 

161 W Michigan Ave. 

Jackson, MI 49201 

Jackson, MI 49201 

(517) 796-3907 

(517) 788-4050 

ryan@phillipsprobatelaw.com 

mportetfield@cityofjackson.org 

PROOF OF SERVICE 

Ryan L. Phillips states that he served Petitioner's Property Prehearing Statement upon Mark 

M. Porterfield by email sent to his address listed above on October 1, 2026. 

7 plLLL 

Ryan L. Phillips, Attorney for Petitioner

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 24-004252 

CITY OF JACKSON 

, 

Respondent(s) 

X__ 

PETITIONER'S PROPERTY PREHEARING STATEMENT 

RESPONDENT'S PROPERTY PREHEARING STATEMENT 

Petitioner's representative: Ryan L. Phillips PC, Ryan L. Phillips P73731 

Respondent's representative: Jackson City Attorney's Office, Matthew M. Hagerty P66015 

Il. 

VALUATION INFORMATION: 

A. The true cash value (TCV), assessed value (AV), and taxable value (TV) for each 

parcel and tax year at issue as established by the Board of Review: 

Parcel Number: 2-005700000 

Year 

TCV 

AV 

TV 

2024 

374400 

187200 

186270 

2025 

530200 

265100 

192044 

2026 

478600 

239300 

197229 

B. Your contentions of TCV, state equalized value (SEV), and TV for each parcel 

and tax year at issue: 

Parcel Number: 2-005700000 

Year 

TCV 

SEV 

TV 

2024 

374400 

187200 

0 

2025 

530200 

265100 

0 

2026 

478600 

239300 

0 

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 2

MTT Docket No. 24-004252 

Page 2 of 4 

C. Amounts in dispute for the tax year(s) at issue: 

Parcel Number: 2-005700000 

Year 

TCV 

SEV 

TV 

2024 

186270 

2025 

192044 

2026 

197229 

TAX INFORMATION: 

A. Have taxes been paid for each property for each tax year at issue? 

__Yes _x No 

FACTUAL STATEMENT OF CLAIMS: 

A. Describe any additions or losses for each property for each tax year at issue (by 

parcel number and tax year): 

not applicable 

Classification of each property for each tax year at issue (by parcel 

number): 201-Commercial 

Current use of each property for each tax year at issue, if different than above 

(by parcel number): 

House of public worship owned by a religious society and used predominantly 

for religious services and for teaching the religious truths and beliefs of the 

SOCIEty. 

. Contention of highest and best use for each property for each tax year at issue, if 

different than property's current use for each tax year at issue (by parcel 

number): 

not applicable 

Your factual statement of claims in support of your contentions, including 

additions and losses, if any (i.e., what facts are you relying on in support of your 

claim or defense?): 

The property at issue is a house of public worship, owned by a religious society and

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Iv.

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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: 24-004252

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

Party Filing Document 

Petitioner

Files

Document Type: Prehearing Statement

Attachment File Name: 261001 statement prehearing Fossores

Document Type: Proof of Service: Misc Documents

Attachment File Name: 261001 pos Fossores

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

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

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

NOTICE OF DECEMBER 1-15, 2026 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE FOR NON-PROPERTY TAX AND 

PROPERTY TAX EXEMPTION CASES 

 

Fossores, 

Petitioner, 

 

v 

MTT Docket No. 24-004252 

City of Jackson, 

Respondent. 

 

 

Please be advised that this case has been placed on a two-week Prehearing General 

Call commencing December 1, 2026. Parties will be notified at least one week before 

they are scheduled to appear. 

 

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. 

 

IT IS ORDERED that discovery is CLOSED on October 1, 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. 

 

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

Statements by October 1, 2026. Witnesses, with the exception of rebuttal witnesses,

Page 2

MTT Docket No. 24-004252 

Page 2 of 2 

will not be allowed to testify unless disclosed in the

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Page 1

iB 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No._24-004252 

CITY OF JACKSON 

Respondent(s) 

MOTION TO SET ASIDE DEFAULT 

1. 

A default was entered against me on 11/07/2025 

and, 

if applicable, the default 

was extended on 12/12/2025 

2. 

Good cause exists to set aside the default because: 

See Attachment to Motion to Set Aside Default. 

3. 

| ask this Tribunal to set aside the default. 

Re lll. penasy 

TE here) 

Ryan L. Phillips 

[Print/type name of person signing] 

| certify that on this date 

| served a copy of this Motion, and any additional documentation, on the 

opposing party or their representative. 

2\ao\a— 

\o AA Ls 

Date 

(sign here) 

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 2

STATE OF MICHIGAN 

DEPT. OF LICENSING AND REGULATORY AFFIRAS 

FOSSORES, a domestic nonprofit corporation, 

Petitioner, 

MICHIGAN TAX TRIBUNAL, ENTIRE 

TRIBUNAL 

MOAHR docket no. 24-004252 

CITY OF JACKSON, Respondent. 

Ryan L. Phillips PC 

City of Jackson 

Ryan L. Phillips P73731 

Mark M. Porterfield P57917 

Attorney for Petitioner 

Attorney for Respondent 

180 W Michigan Ave., suite 603 

161 

W Michigan Ave. 

Jackson, M149201 

Jackson, M1 49201 

(517) 796-3907 

(517) 788-4050 

@philli 

batel 

field@cityofiack 

ATTACHMENT TO MOTION TO SET ASIDE DEFAULT 

FACTUAL BACKGROUND 

Pursuant to this Honorable Court’s Order Severing 2024 and 2025 Tax Years and 

Assigning to Docket Number 24-004252, Petitioner filed its Entire Tribunal Property Tax 

Petition on November 3, 2025. At that time, Petitioner's Paralegal sent a copy of said Petition 

to Counsel for Respondent, Attorney Mark M. Porterfield. 

On November 5, 2025, this Honorable Court issued its Notice of Docket Number. That 

Notice of Docket Number provided Petitioner with 45 days to serve interested persons. That 

Notice of Docket Number provided that a new proof of service must be filed even if one was 

already filed with the Petition. 

Still, only 

2 days later, this Honorable Court issued its Order 

of Default. No additional 

proof of service had been filed as required by the Notice of Docket Number (where 43 days 

remained during which that service could 

be perfected). This Order of Default was 

apparently based on a November 3, 2025

Page 3

T

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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 

Fossores, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 24-004252 

 

City of Jackson, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION TO SET ASIDE DEFAULT 

 

On December 22, 2025, Petitioner filed a motion requesting the Tribunal set aside the 

default entered in this case on November 7, 2025. 

 

Respondent has not filed a response to the motion. 

 

The Tribunal has considered the motion and the case file and finds that Petitioner was 

held in default because Petitioner filed a defective proof of service.1 Petitioner timely 

responded but failed to cure the default and the Tribunal entered an order extending the 

time to cure on December 12, 2025. Having now filed the required proof of service for 

the petition, a motion to set aside default, paid the required motion filing fee, and 

submitted proof that the motion was served on Respondent, Petitioner has complied 

with the Tribunal’s orders as required by TTR 237. As such, the Tribunal finds good 

cause to grant the motion and set aside the default. Therefore, 

 

IT IS ORDERED that Petitioner’s Motion to Set Aside Default is GRANTED. 

 

 

Entered: January 22, 2026 

 

 

By _____________________________ 

smm 

 

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. 

 

 

1 The Tribunal’s November 7, 2025 order provided that “the proof of service indicates that Petitioner has 

failed to serve all required parties-in-interest. See TTR 227. Specifically, Petitioner failed to serve the city 

clerk, the township supervisor or clerk, the county equalization director for any county affected, the county 

clerk for any county affected, the secretary of the local school board, the treasurer of the state of 

Michigan.”

Page 2

MTT Docket No. 24-004252 

Page 2 of 2 

 

By: Tribunal Clerk

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Page 1

DEPART! 

DEC 26 15 

RECEIVED 

JAN 16 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNA) 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

- 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES 

; 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MOAHR Docket No. 24-004262 

CITY OF JACKON 

p 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1s 

Property Parcel No; 2-006700000 

(if more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above Is x 

real 

___personal. 

3. 

If more than one parcel of real property Is under appeal, are the properties 

contiguous? ___ Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4, 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identifled above Is classified as 201-commerclal 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent's ___ March ___ July ___December Board of Review.

Page 2

MOAHR Docket No, _ 24-804262 

Page 2 of 4 

10, 

11. 

12. 

13. 

14. 

This petition Is prepared and filed pursuant to the Order Sovering 2024 and 2026 Tax years 

and Assigning to Docket Number 24-004262 of the MTT, dated October 13, 2025. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (l.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to Invoke the Tribunals authority over the assessment or 

assessments at issue (attach additional page if necessary): 

This petition ls prepared and filed pursuant to the Order Severing 2024 and 2026 Tax yaais 

and Assigning to Docket Number 24-004262 of the MTT, dated October 13, 2025, 

The property or properties at issue are located in Jackson 

County, The 

property or properties’ address Is: 

506 Wildwood Ave., Jackson, Mi 49201 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): City of Jackson 

Petitioner's legal residence or principal office

Page 3

MOAHR

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Page 1

iB 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No._24-004252 

CITY OF JACKSON 

Respondent(s) 

MOTION TO SET ASIDE DEFAULT 

1. 

A default was entered against me on 11/07/2025 

and, 

if applicable, the default 

was extended on 12/12/2025 

2. 

Good cause exists to set aside the default because: 

See Attachment to Motion to Set Aside Default. 

3. 

| ask this Tribunal to set aside the default. 

Re lll. penasy 

TE here) 

Ryan L. Phillips 

[Print/type name of person signing] 

| certify that on this date 

| served a copy of this Motion, and any additional documentation, on the 

opposing party or their representative. 

2\ao\a— 

\o AA Ls 

Date 

(sign here) 

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 2

STATE OF MICHIGAN 

DEPT. OF LICENSING AND REGULATORY AFFIRAS 

FOSSORES, a domestic nonprofit corporation, 

Petitioner, 

MICHIGAN TAX TRIBUNAL, ENTIRE 

TRIBUNAL 

MOAHR docket no. 24-004252 

CITY OF JACKSON, Respondent. 

Ryan L. Phillips PC 

City of Jackson 

Ryan L. Phillips P73731 

Mark M. Porterfield P57917 

Attorney for Petitioner 

Attorney for Respondent 

180 W Michigan Ave., suite 603 

161 

W Michigan Ave. 

Jackson, M149201 

Jackson, M1 49201 

(517) 796-3907 

(517) 788-4050 

@philli 

batel 

field@cityofiack 

ATTACHMENT TO MOTION TO SET ASIDE DEFAULT 

FACTUAL BACKGROUND 

Pursuant to this Honorable Court’s Order Severing 2024 and 2025 Tax Years and 

Assigning to Docket Number 24-004252, Petitioner filed its Entire Tribunal Property Tax 

Petition on November 3, 2025. At that time, Petitioner's Paralegal sent a copy of said Petition 

to Counsel for Respondent, Attorney Mark M. Porterfield. 

On November 5, 2025, this Honorable Court issued its Notice of Docket Number. That 

Notice of Docket Number provided Petitioner with 45 days to serve interested persons. That 

Notice of Docket Number provided that a new proof of service must be filed even if one was 

already filed with the Petition. 

Still, only 

2 days later, this Honorable Court issued its Order 

of Default. No additional 

proof of service had been filed as required by the Notice of Docket Number (where 43 days 

remained during which that service could 

be perfected). This Order of Default was 

apparently based on a November 3, 2025

Page 3

T

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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

Fossores, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 24-004252

City Of Jackson,

Respondent.

NOTICE OF NO ACTION

TAKE NOTICE that the Tribunal has reviewed the file in the above-captioned case and 

finds that:

The Tribunal has received Petitioner's December 16, 2025 filing. That filing requires a 

motion with the appropriate motion fee. As such, the filing is not properly pending, and 

no action will be taken unless a motion and appropriate filing fee are filed within 14 days 

of the issuance of this notice. 

Filing fees for Entire Tribunal motions are governed by TTR 223 and filing fees for Small 

Claims motions are governed by TTR 269. The rules and a summary of the fees can be 

found on the Tribunal’s website at www.michigan.gov/taxtrib.

Entered: December 17, 2025

By: Tribunal Clerk

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

MTT Docket No. 24-004252

Page 2 of 4

Fossores, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 24-004252

City Of Jackson,

Respondent.

NOTICE OF NO ACTION

TAKE NOTICE that the Tribunal has reviewed the file in the above-captioned case and 

finds that:

The Tribunal has received Petitioner's December 16, 2025 filing. That filing requires a 

motion with the appropriate motion fee. As such, the filing is not properly pending, and 

no action will be taken unless a motion and appropriate filing fee are filed within 14 days 

of the issuance of this notice. 

Filing fees for Entire Tribunal motions are governed by TTR 223 and filing fees for Small 

Claims motions are governed by TTR 269. The rules and a summary of the fees can be 

found on the Tribunal’s website at www.michigan.gov/taxtrib.

Entered: December 17, 2025

By: Tribunal Clerk

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

Page 3

S

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Page 1

Eo Cd 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 24-004252 

CITY OF JACKSON 

, 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Kristie A. Phillips 

states that on 12/16/25 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. 

Assessor (via certified mail): 

Jason Yoakam, 

City Assessor 

161 W. Michigan Ave., 

9th floor, Jackson, 

MI 49201 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

Andrea Muray, Clerk of the City of Jackson 

161 W. Michigan Ave., Jackson, 

MI 49201 

3. 

County Equalization Director (via first class mail or personal service): 

Joseph VanHassel, Equalization Director, MMAO 

120 W Michigan Ave #2. Jackson. 

MI 49201 

4. 

County Clerk (via first class mail or personal service): 

Cierra Sowle, County Clerk for County of Jackson 

120 W. Michigan Ave., Jackson. MI 49201 

5. 

Secretary of the local school board (via first class mail or personal service): 

Cheryl Simonetti. Secretary of JPS School Board 

522 Wildwood Ave, Jackson, 

MI 49201 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

XK) 

SF 

\L. 

Kristie A. Phillips 

ailing copy] 

[Print/type name of person serving/mailing copy] 

Q 

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

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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 

Fossores, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 24-004252 

 

City of Jackson, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER EXTENDING TIME FOR PETITIONER TO CURE DEFAULT 

 

On November 10, 2025, Petitioner filed proof of service of the petition in response to the 

Tribunal’s November 7, 2025 Order of Default. 

 

The Tribunal has considered the response and the case file and finds that Petitioner 

was held in default because Petitioner failed to provide proof evidencing the service of 

the petition on the six parties in interest.1 Although Petitioner timely responded to the 

Order of Default, their attempt to cure is incomplete because Petitioner’s response 

failed to comport with TTR 227(6).2 Though the Tribunal finds an extension of time to 

cure the default appropriate, Petitioner’s failure to comply with Tribunal orders and its 

Rules of Practice and Procedure has established a history of deliberate delay that would 

justify dismissal of the case for failure to timely comply with this order.3 Therefore, 

 

IT IS ORDERED that the time for Petitioner to cure the default is EXTENDED. 

 

IT IS FURTHER ORDERED that Petitioner must complete the following to cure the 

default: (1) file proof of service of the petition compliant with Tribunal Rules, (2) file a 

Motion to Set Aside Default, (3) pay the $50.00 fee required for the filing of the motion, 

(4) file proof the motion was served on Respondent. The foregoing must be filed with 

the Tribunal within 14 days of the entry of this order.4 

 

1 The order further stated, “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).” 

2 A list of Tribunal rules and forms are available online at www.michigan.gov/taxtrib. 

3 See Grimm v Dep’t of Treasury, 291 Mich App 140 (2010). 

 

4 “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.

Page 2

MT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

FOSSORES, 

| 

Petitioner, 

MTT Docket No. 24-004252 

-Vs- 

Parcel No. 2-005700000 

CITY OF JACKSON, 

ANSWER TO PETITION AND 

AFFIRMATIVE DEFENSES 

Respondent. 

| 

/ 

RYAN L. PHILLIPS 

JACKSON CITY ATTORNEY'S OFFICE 

Attorney for Petitioner 

BY: Matthew M. Hagerty (P66015) 

| 

180 W. Michigan Avenue, Suite 603 

Mark M. Porterfield (P57917) 

| 

Jackson, MI 49201 

Attorneys for Respondent 

(517) 796-3907 

161 W. Michigan Avenue 

(517) 788-4050 

mhagerty@cityofjackson.org 

| 

mporterfield@cityofjackson.org 

Jackson, MI 49201 

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: 

1. 

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. 

Petitioner did not answer Paragraph 3; therefore, Respondent cannot respond. 

4. 

Petitioner did not answer Paragraph 4; therefore, Respondent cannot respond. 

5. 

Petitioner did not answer Paragraph 5; therefore, Respondent cannot respond. 

6. 

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

1

Page 2

7. 

Petitioner did not answer Paragraph 7; therefore, Respondent cannot respond. 

8. 

Respondent admits that the petition was submitted pursuant to order of the 

Tribunal dated October 13, 2025, assigned MTT docket no. 24-004252. 

9. 

Respondent admits that the petition was submitted pursuant to order of the Tribunal 

dated October 13, 2025, assigned MTT docket no. 24-004252. 

10. 

Respondent admits the allegation contained in Paragraph 10 of Petitioner’s Petition. 

11. 

Respondent admits the allegation contained in Paragraph 11 of Petitioner’s Petition. 

12. 

Respondent neither admits nor denies the allegation contained in Paragraph 12 of 

Petitioner’s Petition and leaves Petitioner to its proofs. 

13. 

Respondent admits that the issue on appeal involves a claimed exemption from ad 

valorem taxation and further answers that such claimed exemption was denied by this Tribunal on 

October 15, 2025 as set forth in this Tribunal’s Final Opinion and Judgment granting Respondent’s 

motion for summary disposition pursuant to MCR 2.116(C)(10) in MTT Docket No. 23-000609. 

14. 

Respondent admits the allegation

Page 3

Final

Page 4

MATT

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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. 24-004252

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

CLERK OF THE CITY OF JACKSON

10,

161 W. Michigan Ave., Jackson, MI 49201

Mark M Porterfield, Jackson City Attorney's Office

161 W. Michigan Ave., Jackson, MI 49201

Ey 

as 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES, a Domestic Nonprofit Corp. 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No._24-004252 

CITY OF JACKSON 

Respondent(s) 

PROOF OF SERVICE 

KRISTIE A. PHILLIPS 

states that on 

NOVEMBER10,2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Emre RieunaL proerry 

Tax eToN relative to the above-captioned matter upon: 

[Provide name and address of the party/people being served] 

CLERK OF THE CITY OF JACKSON 

161 W. Michigan Ave., Jackson, MI 49201 

Mark M Porterfield, Jackson City Attorney's Office 

161 W. Michigan Ave., Jackson, MI 49201 

ON 0 0D 

[Signature of person who is sgrving/mailing copy] 

KRISTIE A. PHILLIPS 

[Print/type name of person serving/mailing copy] 

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

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Page 1

CLERK OF THE CITY OF JACKSON

10,

161 W. Michigan Ave., Jackson, MI 49201

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

|. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES, a Domestic Nonprofit Corp. 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No._24-004252 

CITY OF JACKSON 

Respondent(s) 

PROOF OF SERVICE 

KRISTIE A. PHILLIPS 

states that on 

NOVEMBER10,2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Emre RieunaL proerry 

Tax eToN relative to the above-captioned matter upon: 

[Provide name and address of the party/people being served] 

CLERK OF THE CITY OF JACKSON 

161 W. Michigan Ave., Jackson, MI 49201 

ON 0 0D 

[Signature of person who is sgrving/mailing copy] 

KRISTIE A. PHILLIPS 

[Print/type name of person serving/mailing copy] 

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

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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

Fossores,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 24-004252

City Of Jackson,

Respondent.

ORDER OF DEFAULT

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

Petitioner filed proof evidencing service of the petition. However, the proof of service 

indicates that Petitioner has failed to serve all required parties-in-interest. See TTR 

227. Specifically, Petitioner failed to serve the city clerk , the township supervisor or 

clerk , the county equalization director for any county affected, the county clerk for any 

county affected, the secretary of the local school board, the treasurer of the state of 

Michigan. As such, Petitioner must submit a revised proof of service within 14 days of 

the entry of this order. Tribunal rules and information on Entire Tribunal petitions can be 

found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Petitioner 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: November 7, 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

Page 2

MTT Docket No. 24-004252

Page 2 of 6

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

Page 3

STATE

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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

Fossores, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 24-004252

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: November 5, 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

Fossores, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

|. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES, a Domestic Nonprofit Corp. 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No._24-004252 

CITY OF JACKSON 

; 

Respondent(s) 

PROOF OF SERVICE 

KRISTIE A. PHILLIPS 

states that on 

NOVEMBER 3, 2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Emre RieunaL prorerry 

Tax PeToN relative to the above-captioned matter upon: 

[Provide name and address of the party/people being served] 

CITY OF JACKSON 

MARK M. PORTERFIELD, P57917 

161 W. MICHIGAN AVE. 

JACKSON, MI 49201 

OSD 0 

[Signature of person who is sgrving/mailing copy] 

KRISTIE A. PHILLIPS 

[Print/type name of person serving/mailing copy] 

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

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

FOSSORES 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MOAHR Docket No. 24-604262 

CITY OF JACKON 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 2-005700000 

(if more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is x__real 

___personal. 

3. 

If more than one parce! of real property is under appeal, are the properties 

contiguous? ___ Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4, 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? __ Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201-commercial 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent's 

March 

July 

___December Board of Review. 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunals authority over the 

assessment or assessments at issue (attach additional page if necessary): 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

611 W. OTTAWA ST « P.O. BOX 30232 « LANSING, MICHIGAN 48809-8185 « 517-335-9760

Page 2

MOAHR Docket No. 

_24-004262 

Page 2 of 4 

10. 

11. 

12. 

13. 

14. 

This petition is prepared and filed pursuant to the Order Severing 2024 and 2025 Tax years 

and Assigning to Docket Number 24-004252 of the MTT, dated October 13, 2025. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

This petition is prepared and filed pursuant to the Order Severing 2024 and 2025 Tax years 

and Assigning to Docket Number 24-004252 of the MTT, dated October 13,

Page 3

MOAH

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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 

Fossores, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket Nos. 23-000609 & 

 

 

24-004252 

 

City of Jackson, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER SEVERING 2024 AND 2025 TAX YEARS AND ASSIGNING TO 

DOCKET NUMBER 24-004252 

 

On April 14, 2023, Petitioner filed a petition in this case contesting Respondent’s denial 

of a property tax exemption under MCL 211.7s for the 2023 tax year. Respondent filed 

a Motion for Summary Disposition on November 30, 2023, while Petitioner filed a 

Motion for Summary Disposition on December 1, 2023. Responses to the motions were 

filed in January 2024. 

 

Pursuant to MCL 205.737(5): 

 

A motion to amend a petition to add subsequent years is not necessary in 

the following circumstances: 

 (a) If the tribunal has jurisdiction over a petition alleging that the property 

is exempt from taxation, the appeal for each subsequent year for which an 

assessment has been established shall be added automatically to the 

petition. However, upon leave of the tribunal, the petitioner or respondent 

may request that any subsequent year be excluded from appeal at the time 

of the hearing on the petition. 

 

Because the 2023 tax year is being decided on summary disposition and not after a 

hearing, the parties did not have an opportunity to request that subsequent tax years be 

excluded. Further, given the timing of the motions, the motions were not applicable to 

the 2024 and 2025 tax years as the assessments had yet to be established. For these 

reasons, the Tribunal finds that the 2024 and 2025 tax years must be severed from this 

docket and assigned a new docket number. 

 

Therefore, 

 

IT IS ORDERED that the 2024 and 2025 tax years are SEVERED and ASSIGNED to 

MTT Docket No. 24-004252.

Page 2

MTT Docket Nos. 23-000609 & 24-004252 

Page 2 of 2 

 

IT IS FURTHER ORDERED that Petitioner shall file a petition including the 2024 and 

2025 tax years within 21 days of entry of this order. The petition shall note the docket 

number assigned by the Tribunal for the 2024 and 2025 tax years and if filed utilizing 

the Tribunal’s e-filing system, must be filed on the assigned docket as a “Severed 

Petition.”1 

 

IT IS

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