Genesee Mall Realty LLC Petitioner Vs. Township Of Flint Respondent
- Petitioner
- Genesee Mall Realty LLC
- Respondent
- Township Of Flint
Case overview
- Docket number
- 26-002822-TT
- Status
- Ready Sched Prehearing Date Certain
- CaseType
- ET Property
- Division
- ET
- County
- Genesee
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 6 | Prehearing General Call | Not recorded | Not recorded | 10/16/2026 | Not recorded | Download |
| 5 | Answer was received | RESP | Not recorded | 08/03/2026 | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 07/28/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 07/27/2026 | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 07/27/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/21/2026 | $600.00 | Download |
Documents
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR NOTICE OF SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Genesee Mall Realty LLC, Petitioner, v MTT Docket No. 26-002822 Township of Flint, Respondent. Please be advised that 26-002822 has been placed on a two-week Prehearing General Call commencing September 16, 2027. Unless ordered otherwise, parties will be notified at least 28 days before they are scheduled to appear. Scheduling will not necessarily occur in the order in which the cases are listed below. Parties are required to submit a valuation disclosure or written notification that no valuation disclosure is required by the dates indicated herein. A “valuation disclosure” is defined as documentary or other tangible evidence in a property tax proceeding that a party relies upon in support of the party’s contention as to the true cash value of the subject property or any portion thereof and contains the party’s value conclusion and data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241. Users who file documents with the Tribunal are advised that filed documents are public records and will appear for public viewing on the Tribunal’s Tax Docket Lookup. If a user wishes to file a document for consideration by the Tribunal and prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents covered by the order will not be published. Documents filed prior to the issuance of a Protective Order will be published. In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or redacting personal identifying information (PII) from all documents filed with or offered to the Tribunal rests solely with the parties and their attorneys. The Tribunal is not responsible for or required to review, redact, or screen documents at the time of filing for PII whether filed electronically or on paper. A party, representative, or interested person (i.e. third party not part of an appeal) may request that the Tribunal redact PII contained in a previously filed document by submitting a Request for Redactions. The Request for Redactions form is available on the Entire Tribunal and Small Claims pages of the Tribunal’s website. Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s website for more information. 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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MTT Docket No. 26-002822 Page 2 of 3 IT IS ORDERED that the parties shall: a. If no valuation disclosure is required, notify the Tribunal and the opposing parties in writing within 21 days of entry of this order that no valuation disclosure is being filed. The notice shall indicate the reason or reasons why no valuation disclosure is required (i.e., exemption claim, etc.). b. If a valuation disclosure is required, file and exchange their valuation disclosures by May 20, 2027. Valuation disclosures will not be admitted into evidence unless disclosed and furnished in accordance with this order (even though admissible) except upon a finding of good cause by the Tribunal. IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing Statements by May 20, 2027. Witnesses, with the exception of rebuttal witnesses, will not be allowed to testify unless disclosed in the Prehearing Statement and the Prehearing Statement is furnished in accordance with this order except upon a finding of good cause by the Tribunal. Failure to file the Prehearing Statement may result in holding a party or parties in default. See TTR 237. IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on May 20, 2027, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. Discovery relative to the valuation disclosure prepared for purposes of litigating this case or the valuation expert that prepared that valuation disclosure is not permitted during “Pre-Valuation Disclosure” discovery. IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on September 16, 2027, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation disclosure, the opposing party’s valuation expert, and the witnesses identified on the opposing party’s Prehearing Statement. IT IS FURTHER ORDERED that if this case is not scheduled for a date certain prehearing conference during the time frame indicated it may be scheduled for a date certain prehearing conference at any time subsequent to the completion date for this Prehearing General Call. Parties will, however, be notified in writing approximately one week before they are scheduled to appear. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: October 16, 2026
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MTT Docket No. 26-002822 Page 3 of 3 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR NOTICE OF SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Genesee Mall Realty LLC, Petitioner, v MTT Docket No. 26-002822 Township of Flint, Respondent. Please be advised that 26-002822 has
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MTT
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M
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CHARTER TOWNSHIP OF FLINT Assessment Division 1490 S. Dye Road Phone: (810) 732-1350 William Fowler, . os Bo Fax: (810) 732-0866 MMAO, PPE Flint, Michigan 48532 assessingdept@flinttownship.org Assessor July 30, 2026 Office of the Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 RE: MTT Docket No.: 26-002822 Genesee Mall Realty LLC v Township of Flint Parcel(s): 07-28-100-014 Dear Honorable Michigan Tax Tribunal: Enclosed for filing, please find Respondent’s Reply to Petitioner’s Petition (in the Entire Tribunal) and Respondents Proof of Service. Respectfully submitted, Paula Dotson Deputy Assessor Charter Township of Flint
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Genesee Mall Realty LLC MTT Docket no.: 26-002822 Petitioner Parcel 07-28-100-014 v Flint Township, Genesee County Respondent Ryan Gibbs Paula Dotson The Gibbs Firm LPA Deputy Assessor, Charter Township of Flint 2355 Auburn Avenue 1490 S. Dye Road Cincinnati, OH 45219 Flint, MI 48532 513.381.3890 810.600.3227 RESPONDENT’S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2026 ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 1. Respondent neither admits nor denies the statements and or allegations set forth in paragraph 1of Petitioner’s Petition. Respondent admits the statements and or allegations set forth in paragraph 2 of Petitioner’s Petition. Respondent neither admits nor denies the statements and or allegations set forth in paragraph 3 of Petitioner’s Petition.
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MTT Docket No. 26-002822 Respondent admits the statements and or allegations set forth in paragraph 4 of Petitioner’s Petition. Respondent admits the statements and or allegations set forth in paragraph 5 of Petitioner’s Petition. Respondent admits the property is identified as class code 201 as set forth in paragraph 6 of Petitioner’s Petition. Respondent neither admits nor denies the statement set forth in paragraph 7 of Petitioner’s Petition and leaves Petitioner to its proofs. Respondent admits the statements and or allegations set forth in paragraph 8 of Petitioner’s Petition. N/A 10. Respondent neither admits nor denies the statements and/or allegations set forth in paragraph 10 of Petitioner’s Petition as said paragraph is merely the opportunity for Petitioner to set forth its contention of value. mathematical calculation of the difference between Respondent’s valuations and Petitioners contention of value. 11. Respondent denies the statements and or allegations set forth in paragraph 11 of Petitioner’s Petition. 12. Respondent neither admits nor denies the statements and/or allegations set forth in paragraph 12 of Petitioners Petition as said paragraph is merely the mathematical calculation of the difference between Respondent’s valuations and Petitioner’s contention of value. 13. Respondent denies the statements and or allegations set forth in paragraph 13 of Petitioner’s Petition because they are untrue. 14. Respondent denies the statements and or allegations set forth in paragraph 14 of Petitioner’s Petition because they are untrue. 15. Respondent denies the statements and or allegations set forth in paragraph 15 of
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MTT Docket No. 26-002822 17. Respondent denies the statements and or allegations set forth in paragraph 17 of Petitioner’s Petition because they are untrue. 18. Respondent denies the statements and or allegations set forth in paragraph 18 of Petitioner’s Petition because they are untrue. 19. Respondent denies the statements and or allegations set forth in paragraph 19 of Petitioner’s Petition because they are untrue. 20. Respondent denies the statements and or allegations set forth in paragraph 20 of Petitioner’s Petition because they are untrue. 21. Respondent denies the statements and or allegations set forth in paragraph 21 of Petitioner’s Petition because they are untrue. 22. Respondent denies the statements and or allegations set forth in paragraph 22 of Petitioners Petition because they are untrue. 23. Respondent neither admits nor denies the statements and/or allegations set forth in paragraph 23 of Petitioner’s Petition. Respondent leaves Petitioner to meeting its required burden of proof. The requests and actions presented in Petitioner’s closing paragraph should be denied. Respondent’s Response submitted on this date, July 30, 2026, by: /s/ Paula Dotson Paula Dotson Deputy Assessor Charter Township of Flint
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Genesee Mall Realty LLC Petitioner v Flint Township, Genesee County Respondent MTT DOCKET NO.: 26-002822 PROOF OF SERVICE STATE OF MICHIGAN ) GENESEE COUNTY) THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on July 30, 2026, she caused to be served upon: Ryan Gibbs Michigan Tax Tribunal The Gibbs Firm LPA PO Box 30232 2355 Auburn Avenue Lansing, Michigan 48909 Cincinnati, OH 45219 by enclosing the same in an envelope, plainly addressed to said party at the above address, with lawful United States first class postage affixed thereon and by placing same in the United States mail. /s/ Paula Dotson July 30, 2026 Date Paula Dotson Deputy Assessor
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Zo- ©02%2¢ ay 72 CHARTER TOWNSHIP OF FLI} 1490 S. Dye Road 5 J Flint, Michigan 48532 9589 0710 5270 L5kk 730k 05 Office of the Chief Clerk, Michigan Tax Tribunal ®.0. Box 30232 Received Lansing, MI 48909 4 AUG 06 2026 LARA RE Fi MEU ATE en SRS RAN HE Ra
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GIBBS National Property Tax Appeals and Litigation July 28, 2026 VIA ELECTRONIC FILING Michigan Tax Tribunal P.O. Box 30232 Lansing, Michigan 48909 Re: Proof of Service Genesee Mall Realty, LLC v. Flint Charter Township Docket no. 26-002822 Dear Clerk to the Tribunal: Enclosed for filing with the Tribunal, please find a Proof of Service for the above-referenced matter. If you have any questions or concerns, please do not hesitate to contact me directly at (513) 381- 3890. Thank you and best regards, Ryan J. Gibbs RJG/jaw
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL GENESEE MALL REALTY, LLC, Petitioner, v. MTT Docket No. 26-002822 FLINT CHARTER TOWNSHIP, Parcel No(s): 07-28-100-014 Respondent. Ryan J. Gibbs The Gibbs Firm, LPA Petitioner's Representative 2355 Auburn Avenue Cincinnati, Ohio 45219 (513) 381-3890 PROOF OF SERVICE Ryan J. Gibbs, first being duly sworn upon oath, states that a copy of the foregoing petition was mailed to: VIA CERTIFIED U.S. MAIL Ms. Paula Dotson, Assessor Flint Charter Township 1490 S. Dye Road
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VIA FIRST-CLASS U.S. MAIL Ms. Mellissa Hayduk, Director Genesee County Equalization 324 S. Saginaw Street, Suite 8B Flint, MI 48502 Domonique D. Clemons Genesee County Clerk 324 S. Saginaw Street, Suite A Flint, MI 48502 Ms. Andrea Fick Secretary of the Board of Education Swartz Creek Public School District 8354 Cappy Lane Swartz Creek, MI 48473 Michigan Department of Treasury 430 W Allegan Street Lansing, MI 48922 Onl uly 2% , 2026 by depositing said copy with the U.S. Post Office in Cincinnati, Ohio in an envelope having sufficient postage. Ryan J. Gibbs and The Gibbs Firm, LPA Petitioner’s Representative 2355 Auburn Avenue Cincinnati, Ohio 45219 (513) 381-3890 Ryan@thegibbsfirm.com
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN ADMINISTRATIVE HEARING SYSTEM
MICHIGAN TAX TRIBUNAL
GENESEE MALL REALTY, LLC
Petitioner,
MTT Docket No. Zip— op2¥2Lv.
CHARTER TOWNSHIP OF FLINT,
Parcel No(s). 07-28-100-014 Respondent.
Ryan J. Gibbs
The Gibbs Firm, LPA
Petitioner’s Representative
2355 Auburn Avenue
Cincinnati, Ohio 45219
(513) 381-3890
PETITION
Petitioner, Genesee Mall Realty, LLC ("Petitioner"), by and through its
representative, Ryan J. Gibbs, as authorized by MCL 205.735(3); and TTR 792.1205(1),
state the following for its Petition:
1. Petitioner, Genesee Mall Realty, LLC principal offices are located at 150 Great
Neck Road, Suite 304 Great Neck, NY 11021
2. Respondent Charter Township of Flint, is the entity responsible under statute
for the levy and collection of Michigan ad valorem real property taxes imposed by thePage 5
205.735(3), and/or was responsible for the payment of ad valorem real property taxes for the property, in Respondent, Charter Township of Flint at 4600 Miller Road and designated by Respondent as the captioned parcel (hereinafter, the "subject property"). 4. At issue in this matter are ad valorem real property taxes for the subject property assessed by Respondent as of December 31,2025, tax day for the 2026 tax year (the "year in issue"). 5. The subject property consists of land, land improvements, building improvements and is located within Charter Township of Flint, Genesee County, Michigan, and the Swartz Creck Community School District. 6. The subject property is real property. The parcel is classified by Respondent for tax purposes as 201. 7. The present appeal involves a combination of the matter types (valuation; assessment; taxable value; uniformity and exemption) specified in TTR 792.10227 (3) (oxi). 8. For the year in issue, Respondent assigned on the Notice of Assessment state equalized, assessed, and taxable values to the subject property as follows: AV ~ | Tax. Value “Year | TLD. Number(s) N True Cash § $2,875,100 | $2,875,100 | $2,875,1002026 | 07-28-100-014 | $5750200 10. The total assessment-indicated cash value for the subject property for the year
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methodologies support Petitioner’s contention of a total true cash value set forth below of $1,250,000. Year | LD.Number(s) | TrueCash SEV AV Tax. Value | = Value Co 2026 |07-28-100-014 | $1,250,000 | $625000 | $625,000 | $625,000 12. As set forth below, a total of $4,500,200 in true cash value, $2,250,100 in state equalized, assessed value, and $2,250,100 in taxable value is in controversy for tax year 2026 subject to alterations in cash value contentions that may be necessary as this matter progresses. —— Year LD. Number(s) |" True Cash AV Tax. Value Value 2026 | $4,500,200 $2,250,100 $2,250,100 $2,250,100 07-28-100-014 13. The assessment issued by Respondent for the subject property for the year in issue is unlawful and invalid because the assessment, as equalized, exceeds 50% of the property's cash value contrary to applicable provisions of statute and constitution, infer alia, Const of 1963, art 9, §3 and MCL 211.27a(1). 14. The assessment issue by Respondent for the subject property for the year at issue is unlawful and invalid because it overstates the value as of December 31, 2025, the relevant tax day. 15. The assessment issued by Respondent for the subject property for the year in issue is unlawful and invalid because the valuation methodology used by Respondent to r the subject property is not the methodology that most
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16. To the extent that Respondent has relied upon market data to achieve the assessment imposed for the 2026 tax year, Respondent's analysis of the selling prices of allegedly comparable properties is flawed; a properly-conducted study of the market for properties akin to the subject property at its location will reveal that the subject property's 2026 cash value is that identified by Petitioner in this Petition. 17. The taxable value issued by Respondent for the subject property for the year in issue is unlawful and invalid because it
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o
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR MICHIGAN TAX TRIBUNAL Docket Number: 26-002822 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: MTT Docket 26-002822 Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00 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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Gl B RB S | Propetty RECEIVED MAY 27 2026 National Property Tax Appeals and Litigation MICHIGAN TAX TRIBUNAL May 20, 2026 VIA CERTIFIED MAIL Tranlnfo:4606 261239871 06/26/26 Michigan Tax Tribunal Chit: 3120 Amtz $600.00 P.O. Box 30232 ID: THE GIBES FIRM- Lansing, Michigan 48909 Re: Tax Year 2026 Petition Genesee Mall Realty, LLC v. Charter Township of Flint Parcel no(s): 07-28-100-014 Dear Clerk to the Tribunal: Enclosed for filing with the Tribunal, please find an original and a copy of a tax year 2026 petition for the above-referenced property. Ihave also enclosed a check in the amount of $600.00 for the necessary filing fees. Please time stamp the copy that has been provided and return it to our office in the enclosed pre-paid, pre-addressed envelope. If you have any questions or concerns, please do not hesitate to contact me directly at (513) 381-3890. Thank you and best regards, Ryan J. Gibbs jaw/RIG
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN ADMINISTRATIVE HEARING SYSTEM
MICHIGAN TAX TRIBUNAL
GENESEE MALL REALTY, LLC
Petitioner,
MTT Docket No.Vv.
CHARTER TOWNSHIP OF FLINT,
Parcel No(s). 07-28-100-014 Respondent.
Ryan J. Gibbs
The Gibbs Firm, LPA
Petitioner’s Representative
2355 Auburn Avenue
Cincinnati, Ohio 45219
(513) 381-3890
PETITION
Petitioner, Genesee Mall Realty, LLC ("Petitioner"), by and through its
representative, Ryan J. Gibbs, as authorized by MCL 205.735(3); and TTR 792.1205(1),
state the following for its Petition:
1. Petitioner, Genesee Mall Realty, LLC principal offices are located at 150 Great
Neck Road, Suite 304 Great Neck, NY 11021
2. Respondent Charter Township of Flint, is the entity responsible under statute
collection of Michigan ad valorem real property taxes imposed by thePage 3
205.735(3), and/or was responsible for the payment of ad valorem real property taxes for the property, in Respondent, Charter Township of Flint at 4600 Miller Road and designated by Respondent as the captioned parcel (hereinafter, the "subject property"). 4. At issue in this matter are ad valorem real property taxes for the subject property assessed by Respondent as of December 31, 2025, tax day for the 2026 tax year (the "year in issue"). 5. The subject property consists of land, land improvements, building improvements and is located within Charter Township of Flint, Genesee County, Michigan, and the Swartz Creek Community School District. 6. The subject property is real property. The parcel is classified by Respondent for tax purposes as 201. 7. The present appeal involves a combination of the matter types (valuation; assessment; taxable value; uniformity and exemption) specified in TTR 792.10227 (3)(©)(iid)- 8. For the year in issue, Respondent assigned on the Notice of Assessment state equalized, assessed, and taxable values to the subject property as follows: Year 1.D. Number(s) True Cash SEV AV Tax. Value Value $5,750,200 $2,875,100 | $2,875,100 $2,875,1002026 | 07-28-100-014 cash value for the subject property for the year otal assessment-indicated
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methodologies support Petitioner’s contention of a total true cash value set forth below of $1,250,000. Year LD. Number(s) True Cash SEV AV Tax. Value Value 2026 07-28-100-014 $1,250,000 $625,000 $625,000 $625,000 12. As set forth below, a total of $4,500,200 in true cash value, $2,250,100 in state equalized, assessed value, and $2,250,100 in taxable value is in controversy for tax year 2026 subject to alterations in cash value contentions that may be necessary as this matter progresses. Year LD. Number(s) True Cash SEV AV Tax. Value Value 2026 07-28-100-014 $4,500,200 $2,250,100 | $2,250,100 | $2,250,100 13. The assessment issued by Respondent for the subject propeity for the year in issue is unlawful and invalid because the assessment, as equalized, exceeds 50% of the propertyroperty's cash value contrary to applicablep p provisions of statute and constitution, infer alia, Const of 1963, art 9, §3 and MCL 211.27a(1). 14. The assessment issue by Respondent for the subject property for the year at issue is unlawful and invalid because it overstates the value as of December 31, 2025, the relevant tax day. 15. The assessment issued by Respondent for the subject property for the year in issue is unlawful and invalid because the valuation methodology used by Respondent to
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16. To the extent that Respondent has relied upon market data to achieve the assessment imposed for the 2026 tax year, Respondent's analysis of the selling prices of allegedly comparable properties is flawed; a properly-conducted study of the market for properties akin to the subject property at its location will reveal that the subject property's 2026 cash value is that identified by Petitioner in this Petition. 17. The taxable value issued by Respondent for the subject property for the year in issue is unlawful and invalid because it is the result of Respondent’s improper “uncapping” of the taxable value in violation of MCL §211.27a, “The General Property Tax Act.” 18. The assessment issued by Respondent for the subject property for the year in issue is unlawful and invalid because the valuation methodology used by Respondent to compute the assessment for the subject property fails to account for all factors limiting value including, but not limited to, the inability of the property to produce positive cash flow sufficient to support the cumulative assessment-indicated cash value for tax year 2026. 19. The assessment issued by Respondent for the subject property for the 2026 tax year is unlawful and invalid because the valuation methodology used by Respondent to compute the assessment for the subject real property at issue is not supported by the law or facts. 20. The assessment issued by Respondent for the subject property for the year in
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of assessment established and in effect for comparably-situated and
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(C) To the
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2355
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Genesee Mall Realty, LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002822 Township of Flint, 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 27, 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 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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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Genesee Mall Realty, LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002822 Township of Flint, 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 27, 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 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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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Genesee Mall Realty, LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002822 Township of Flint, 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:
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Gl B RB S | Propetty RECEIVED MAY 27 2026 National Property Tax Appeals and Litigation MICHIGAN TAX TRIBUNAL May 20, 2026 VIA CERTIFIED MAIL Tranlnfo:4606 261239871 06/26/26 Michigan Tax Tribunal Chit: 3120 Amtz $600.00 P.O. Box 30232 ID: THE GIBES FIRM- Lansing, Michigan 48909 Re: Tax Year 2026 Petition Genesee Mall Realty, LLC v. Charter Township of Flint Parcel no(s): 07-28-100-014 Dear Clerk to the Tribunal: Enclosed for filing with the Tribunal, please find an original and a copy of a tax year 2026 petition for the above-referenced property. Ihave also enclosed a check in the amount of $600.00 for the necessary filing fees. Please time stamp the copy that has been provided and return it to our office in the enclosed pre-paid, pre-addressed envelope. If you have any questions or concerns, please do not hesitate to contact me directly at (513) 381-3890. Thank you and best regards, Ryan J. Gibbs jaw/RIG
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN ADMINISTRATIVE HEARING SYSTEM
MICHIGAN TAX TRIBUNAL
GENESEE MALL REALTY, LLC
Petitioner,
MTT Docket No.Vv.
CHARTER TOWNSHIP OF FLINT,
Parcel No(s). 07-28-100-014 Respondent.
Ryan J. Gibbs
The Gibbs Firm, LPA
Petitioner’s Representative
2355 Auburn Avenue
Cincinnati, Ohio 45219
(513) 381-3890
PETITION
Petitioner, Genesee Mall Realty, LLC ("Petitioner"), by and through its
representative, Ryan J. Gibbs, as authorized by MCL 205.735(3); and TTR 792.1205(1),
state the following for its Petition:
1. Petitioner, Genesee Mall Realty, LLC principal offices are located at 150 Great
Neck Road, Suite 304 Great Neck, NY 11021
2. Respondent Charter Township of Flint, is the entity responsible under statute
collection of Michigan ad valorem real property taxes imposed by thePage 3
205.735(3), and/or was responsible for the payment of ad valorem real property taxes for the property, in Respondent, Charter Township of Flint at 4600 Miller Road and designated by Respondent as the captioned parcel (hereinafter, the "subject property"). 4. At issue in this matter are ad valorem real property taxes for the subject property assessed by Respondent as of December 31, 2025, tax day for the 2026 tax year (the "year in issue"). 5. The subject property consists of land, land improvements, building improvements and is located within Charter Township of Flint, Genesee County, Michigan, and the Swartz Creek Community School District. 6. The subject property is real property. The parcel is classified by Respondent for tax purposes as 201. 7. The present appeal involves a combination of the matter types (valuation; assessment; taxable value; uniformity and exemption) specified in TTR 792.10227 (3)(©)(iid)- 8. For the year in issue, Respondent assigned on the Notice of Assessment state equalized, assessed, and taxable values to the subject property as follows: Year 1.D. Number(s) True Cash SEV AV Tax. Value Value $5,750,200 $2,875,100 | $2,875,100 $2,875,1002026 | 07-28-100-014 cash value for the subject property for the year otal assessment-indicated
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methodologies support Petitioner’s contention of a total true cash value set forth below of $1,250,000. Year LD. Number(s) True Cash SEV AV Tax. Value Value 2026 07-28-100-014 $1,250,000 $625,000 $625,000 $625,000 12. As set forth below, a total of $4,500,200 in true cash value, $2,250,100 in state equalized, assessed value, and $2,250,100 in taxable value is in controversy for tax year 2026 subject to alterations in cash value contentions that may be necessary as this matter progresses. Year LD. Number(s) True Cash SEV AV Tax. Value Value 2026 07-28-100-014 $4,500,200 $2,250,100 | $2,250,100 | $2,250,100 13. The assessment issued by Respondent for the subject propeity for the year in issue is unlawful and invalid because the assessment, as equalized, exceeds 50% of the propertyroperty's cash value contrary to applicablep p provisions of statute and constitution, infer alia, Const of 1963, art 9, §3 and MCL 211.27a(1). 14. The assessment issue by Respondent for the subject property for the year at issue is unlawful and invalid because it overstates the value as of December 31, 2025, the relevant tax day. 15. The assessment issued by Respondent for the subject property for the year in issue is unlawful and invalid because the valuation methodology used by Respondent to
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16. To the extent that Respondent has relied upon market data to achieve the assessment imposed for the 2026 tax year, Respondent's analysis of the selling prices of allegedly comparable properties is flawed; a properly-conducted study of the market for properties akin to the subject property at its location will reveal that the subject property's 2026 cash value is that identified by Petitioner in this Petition. 17. The taxable value issued by Respondent for the subject property for the year in issue is unlawful and invalid because it is the result of Respondent’s improper “uncapping” of the taxable value in violation of MCL §211.27a, “The General Property Tax Act.” 18. The assessment issued by Respondent for the subject property for the year in issue is unlawful and invalid because the valuation methodology used by Respondent to compute the assessment for the subject property fails to account for all factors limiting value including, but not limited to, the inability of the property to produce positive cash flow sufficient to support the cumulative assessment-indicated cash value for tax year 2026. 19. The assessment issued by Respondent for the subject property for the 2026 tax year is unlawful and invalid because the valuation methodology used by Respondent to compute the assessment for the subject real property at issue is not supported by the law or facts. 20. The assessment issued by Respondent for the subject property for the year in
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of assessment established and in effect for comparably-situated and
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(C) To the
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2355
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