Geosebeck Holdings Limited Partnership, Petitioner Vs. Township Of Clinton, Respondent
- Petitioner
- Geosebeck Holdings Limited Partnership
- Respondent
- Township Of Clinton
Case overview
- Docket number
- 25-002212-TT
- Status
- Ready Sched Prehearing Date Certain
- CaseType
- ET Property
- Division
- ET
- County
- Macomb
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 13 | Proof of Service of Misc Documents was received. | PET | Not recorded | 09/08/2026 | Not recorded | Download |
| 12 | Valuation Disclosure | PET | Not recorded | 09/08/2026 | Not recorded | Download |
| 11 | A Prehearing Statement has been received. | PET | Not recorded | 09/08/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 10 | Valuation Disclosure | RESP | Not recorded | 09/08/2026 | Not recorded | Download |
| 9 | A Prehearing Statement has been received. | RESP | Not recorded | 09/08/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 8 | Prehearing General Call | Not recorded | Not recorded | 02/02/2026 | Not recorded | Download |
| 7 | Answer was received | Not recorded | Not recorded | 09/19/2025 | Not recorded | Download |
| 6 | ET Case Info Sheet | Not recorded | Not recorded | 09/19/2025 | Not recorded | Download |
| 5 | Proof of service of petition was received. | PET | Not recorded | 08/22/2025 | Not recorded | Download |
| 4 | Petition has been verified | PET | 2 | 08/15/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 08/15/2025 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 06/02/2025 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 06/02/2025 | $600.00 | Download |
Documents
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL GROESBECK HOLDINGS LIMITED PARTNERSHIP, Docket No. 25-002212 Petitioner, v. CHARTER TOWNSHIP OF CLINTON, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com PROOF OF SERVICE I certify that I am an employee of Williams, Williams, Rattner & Plunkett, P.C., and that on September 8, 2026, I served a copy of Petitioner’s Valuation Disclosure and Petitioner’s Prehearing Statement and this Proof of Service via e-mail upon:
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2 Laura M. Hallahan, Esq. Seth A. O’Loughlin, Esq. Kelsea M. Melcher, Esq. HALLAHAN & ASSOCIATES, P.C. 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com “I declare under penalty of perjury that the statements above are true to the best of my knowledge, information and belief.” /s/ John E. Scheibelhut John E. Scheibelhut
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL GROESBECK HOLDINGS LIMITED PARTNERSHIP, Docket No. 25-002212 Petitioner, v. CHARTER TOWNSHIP OF CLINTON, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com PETITIONER’S VALUATION DISCLOSURE Petitioner Groesbeck Holdings Limited Partnership, by and through its attorneys, Williams, Williams, Rattner & Plunkett, PC, submits the attached appraisal by Brandon L. Ellis, MAI as its Valuation Disclosure. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Brian E. Etzel Brian E. Etzel (P54905) Dated: September 8, 2026 Attorneys for Petitioner
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September 8, 2026 Groesbeck Holdings Limited Partnership c/o: Mr. Brian Etzel, Esq. Williams Williams Rattner & Plunkett, PC 380 N. Old Woodward Avenue, Suite 300 Birmingham, MI 48009 Re: Appraisal pertaining to: Tax Parcel # 16-11-33-126-006 34800 Groesbeck Highway Clinton Township, Michigan 48035 Dear Mr. Etzel: In accordance with your request, Value Trends has prepared a detailed analysis of the above captioned real property, for the purpose of identifying its True Cash Value, as defined on page 11 of the attached appraisal report. This appraisal is intended to function as evidence in the litigation involving an Ad Valorem dispute between the Clinton Charter Township and ownership of the subject. The intended use of the analysis and conclusions rendered are solely for the purpose of addressing the existing ad valorem dispute, and no other purpose. The analysis which accompanies this cover letter has been prepared in an Appraisal Report, as defined by USPAP (Uniform Standard of Professional Appraisal Practice) 2024 edition. One retrospective date of valuation has been included in the attached report. The date of valuation pertains to December 31, 2024, which represents tax year 2025. The appraised real estate pertains to the real property identified as 34800 Groesbeck Highway. Clinton Charter Township, Macomb County, Michigan. The real estate is a 12.084± acre site improved with a big box commercial building containing 113,950± square feet. The property is identified as Tax ID 16-11-33-126-006. The intended users of the proposed appraisal report include the client (Groesbeck Holdings Limited Partnership), the client’s legal counsel, and other representatives assigned on behalf of the client.
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Etzel letter Page 2 September 8, 2026 The appraisal report is not intended for other uses such as financing, the soliciting of potential purchasers, estate planning, or any other purpose. Other than for use by these parties, this appraisal may not be reproduced in all, in part, or utilized by any other entity, without the written authorization of Brandon L. Ellis, MAI the appraiser signing this report. This letter of transmittal is attached to, and accompanied by my appraisal report. The legal description of the subject will be found beginning on page sixteen (16), whereas the property description begins on page thirty-seven (37). The opinions of value rendered are based on a thorough analysis of the pertinent factors which were considered to impact the subject's valuation. The accompanying report describes, in detail, the methods utilized in the appraisal and contains data gathered during the market investigations. This appraisal report is subject to the Restrictions, Certifications, and Limiting Conditions contained in the addendum and all other assumptions which may be stated elsewhere within the
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Etzel
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Petitioner: GROESBECK HOLDINGS LIMITED PARTNERSHIP, v MTT Docket No. 25-002212 Respondent: CHARTER TOWNSHIP OF CLINTON X PETITIONER’S PREHEARING STATEMENT __ RESPONDENT’S PREHEARING STATEMENT Petitioner’s Representative: Brian E. Etzel (P54905) Respondent’s Representative: Laura M. Hallahan (P42101), Seth A. O’Loughlin (P80257) & Kelsea M. Melcher (P85821) 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: Paracel Number: 16-11-33-126-006 Tax Year True Cash Value Assessed Value Taxable Value 2025 $3,419,000 $1,709,500 $1,172,647 B. Petitioner’s contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue: Paracel Number: 16-11-33-126-006 Tax Year True Cash Value Assessed Value Taxable Value 2025 $1,000,000 $500,000 $500,000 C. Amounts in dispute for the tax year(s) at issue: Paracel Number: 16-11-33-126-006 Tax Year True Cash Value Assessed Value Taxable Value 2025 $2,419,000 $1,209,500 $672,647
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MTT Docket No. 25-002212 Page 2 of 4 2 II. TAX INFORMATION: A. Have taxes been paid for each property for each tax year at issue? X Yes __ 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): None. B. Classification of each property for each tax year at issue (by parcel number): General Commercial Use. C. Current use of each property for each tax year at issue, if different than above (by parcel number): N/A 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): N/A 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?): Petitioner’s valuation of the Property’s TCV, AV, and TV as of December 31, 2024. F. If non-uniformity of assessment is alleged, what evidence will you rely upon in support of your contentions? N/A IV. ISSUES TO BE LITIGATED: A. Factual Issues: TCV, AV, and TV of Petitioner’s Property as of December 31, 2024.
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MTT Docket No. 25-002212 Page 3 of 4 3 B. Legal Issues: Same as the factual issue. V. DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE EVIDENCE? ___ Yes X No A. If yes, state all necessary amendments (a motion may be required to amend the pleadings): N/A VI. ARE THERE CONSOLIDATION ISSUES? ___ Yes X No A. If yes, state the cases, by docket number, that should be consolidated with this case (a motion may be required to consolidate the cases): N/A VII. PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY ISSUES, IF ANY: A. Motions: No motions unless necessary in response to Respondent’s valuation disclosure. B. Discovery: Petitioner requests the opportunity to pursue limited post-valuation discovery. VIII. WITNESSES - IDENTIFY THE NAME AND ADDRESS OF ANY PERSON WHO MAY TESTIFY AND PROVIDE A GENERAL SUMMARY OF THE SUBJECT AREA OF THE TESTIMONY OF EACH PERSON IDENTIFIED: A. Brandon L. Ellis, MAI, Vice President, Value Trends, Inc. will testify regarding his opinion of value for the subject property as of the relevant date of value and any other relevant topic within his knowledge. Mr. Ellis can be reached c/o Brian E. Etzel, 380 North Old Woodward Ave., Suite 300, Birmingham, MI 48009. B. David Tisdale, David M. Tisdale & Co. (c/o Brian E. Etzel, 380 North Old Woodward Ave., Suite 300, Birmingham, MI 48009), will testify regarding the operation, use,
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MTT
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 MICHIGAN TAX TRIBUNAL Docket Number: 25-002212 Is this case currently pending in the Small Claims Division? No Party Filing Document Petitioner Files Document Type: Prehearing Statement Attachment File Name: Petitioner - Prehearing Statement Document Type: Valuation Disclosure Attachment File Name: Petitioner - Valuation Disclosure Document Type: Proof of Service: Misc Documents Attachment File Name: Petitioner - Proof of Service - Valuation Disclosure and Prehearing Statement Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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September 8, 2026 Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 Re: Groesbeck Holdings Limited Partnership v Clinton Charter Township MTT Docket No. 25-002212 To whom it may concern: The following is a valuation disclosure for parcel no. 16-11-33-126-006 presenting the true cash value of the fee simple interest in said parcel as of December 31, 2024. It is my opinion that the true cash value of the fee simple interest as of the relevant tax date is as follows: Parcel Number Tax Year True Cash Value 16-11-33-126-006 2025 $3,419,000 _/s/ Alicia Bernabei_________ Alicia Bernabei MMAO, MCPPE Clinton Charter Township Page 1 of 7
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Printed on 08/26/2025 Parcel Number: 16-11-33-126-006 Jurisdiction: CHARTER TOWNSHIP OF CLINTO County: Macomb Grantor Grantee Sale Price Sale Date Inst. Type Terms of Sale Liber & Page Verified By Prcnt. Trans. GROESBECK - FIFTEEN LLC GROESBECK HOLDINGS LTD PA 10 11/23/2009 WD 16-LC PAYOFF 20066/923 DEED GROESBECK FIFTEEN LLC GROESBECK HOLDINGS LP 4,400,000 02/16/2006 PTA 20-MULTI PARCEL SALE REF PROPERTY TRANSFER 100.00 Property Address 34800 GROESBECK HWY Owner's Name/Address GROESBECK HOLDINGS LTD PARTNERSHIP VACANT BLDG 34800 GROESBECK CLINTON TOWNSHIP, MI 48035 Taxpayer's Name/Address GROESBECK HOLDINGS LTD PARTNERSHIP DAVID M TISDALE & CO 5657 W MAPLE RD STE A WEST BLOOMFIELD, MI 48322-3706 Tax Description *BALANCE OF LEGAL ON FILE 50-11-33-126-006 D463B5B2, B5C2 B5D3A & B5D3C & 464B2C1 76S T2N R13E SEC 33 COMM AT N 1/4 POST SEC 33; TH N 89 DEG 40' 40" W 660.70 FT; TH S 0 DEG 39' W 470.38 FT TO POBEG; TH S 0 DEG 39' W 505.54 FT; TH N 89 DEG 20' W 184.17 FT; TH S 31 DEG 20' 22" W 574.93 FT; TH N 58 DEG 39' 30" W 499.11 FT; TH N 31 DEG 20' 22" E 880.0 FT; TH S 87 DEG 53' 46" E 457.81 FT TO POB. CONTAINS 12.084 AC. Comments/Influences Class: COMMERCIAL-IMPROV Zoning: B-3 Building Permit(s) Date Number Status School: FRASER PUBLIC SCHOOLS SCREEN WALL 05/10/2022 P22B0495 ISSUED P.R.E. 0% ELECTRICAL 01/24/2022 P22E0046 ISSUED MAP #: 011-033-017-00 MECHANICAL 11/08/2018 P18M1695 FINALED 2025 Est TCV 3,418,986 TCV/TFA: 30.00 ELECTRICAL 10/17/2018 P18E0715 ISSUED X Improved Vacant Public Improvements Dirt Road Gravel Road Paved Road Storm Sewer Sidewalk Water Sewer Electric Gas Curb Street Lights Standard Utilities Underground Utils. Topography of Site Level Rolling Low High Landscaped Swamp Wooded Pond Waterfront Ravine Wetland Flood Plain Who When What Land Value Estimates for Land Table COM4.COM4-S GRATIOT/S GROESBECK * Factors * Description Frontage Depth Front Depth Rate %Adj. Reason Value COM4-S GRATIOT/S GRO SITE 524,811 SqFt 5.15000 85 SIZE(-15%) 12+ / 12.05 Total Acres Total Est. Land Value = 2,297,360 Year Land Value Building Value Assessed Value Board of Review Tribunal/ Other Taxable Value 2025 1,148,700 560,800 1,709,500 1,172,647C 2024 1,148,700 498,600 1,647,300 1,137,388C 2023 1,115,200 404,000 1,519,200 1,083,227C 2022 1,026,000 446,700 1,472,700 1,031,645C Page 2 of 7
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Commercial/Industrial Building/Section 1 of 1 Parcel Number: 16-11-33-126-006 Printed on 08/26/2025 Desc. of Bldg/Section K-MART Calculator Occupancy Stores - Discount Class: C Floor Area: 113,950 Gross Bldg Area: 113,950 Stories Above Grd: 1 Average Sty Hght: 20 Bsmnt Wall Hght: 0 Depr. Table : 3% Effective Age : 42 Physical %Good : 35 Func. %Good : 100 Economic %Good : 30 1970 Year Built 0 Remodeled 20 Overall Bldg Height Comments: Construction Cost Fa High Fa Above Ave. Fa Ave. Tr Low ** ** Calculator Cost Data ** ** Quality: Average Heat#1: Package Heating & Cooling 96% Heat#2: Space Heaters, Radiant 4% Ave. SqFt/Story: 113950 Ave. Perimeter: 1518 Has Elevators: False *** Basement Info *** Area: Perimeter: Type: Utility Heat: No Heating or Cooling * Mezzanine Info * Area #1: Type #1: Open Area #2: Type #2: Office * Sprinkler Info * Area: 113950 Type: Average Cost Estimates for Commercial/Industrial Building/Section: 1 Built 1970 Description of Occupancy: K-MART Costs are taken
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Va
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Petitioner: Groesbeck Holdings Limited Partnership Respondent: Clinton Charter Township MTT Docket No. 25-002212 Petitioner’s Prehearing Statement RESPONDENT’S PREHEARING STATEMENT Petitioner’s representative: Brian E. Etzel (P54905) Williams, Williams, Rattner & Plunkett, P.C. 380 N. Old Woodward Avenue, Suite 300 Birmingham, MI 48009 (248) 642-0333 Respondent’s representative: Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) Hallahan & Associates, P.C. 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302 (248) 731-3089 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 Year TCV AV TV 16-11-33-126-006 2025 $3,419,000 $1,709,500 $1,172,647 B. Respondent’s contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue: Parcel Number Year TCV SEV TV 16-11-33-126-006 2025 $3,419,000 $1,709,500 $1,172,647 C. Petitioner’s contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue (per Petitioner’s Petition and Motions to Amend, if applicable): Parcel Number Year TCV SEV TV 16-11-33-126-006 2025 $1,600,000 $800,000 $800,000
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MTT Docket No. 25-002212 Respondent’s Prehearing Statement, Page 2 of 5 D. Amounts in dispute for the tax year(s) at issue: Parcel Number Year TCV SEV TV 16-11-33-126-006 2025 $1,819,000 $909,500 $372,647 II. TAX INFORMATION: A. Have taxes been paid for each property for each tax year at issue? ☒ Yes ☐ 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): Respondent is unaware of any additions or losses to the subject property. B. Classification of each property for each tax year at issue (by parcel number): 16-11-33-126-006 2025 Commercial-Improved C. Current use of each property for each tax year at issue, if different than above (by parcel number): Not applicable. 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. 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?): Respondent contends that it lawfully and uniformly assessed the subject property. F. If non-uniformity of assessment is alleged, what evidence will you rely upon in support of your contents? Respondent contends that it lawfully and uniformly assessed the subject property. G. Affirmative Defenses (if any): Respondent incorporates by reference the affirmative defenses contained in its Answer to the Petition and its Answer to Petitioner’s Motion to Amend (if applicable).
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MTT Docket No. 25-002212 Respondent’s Prehearing Statement, Page 3 of 5 IV. ISSUES TO BE LITIGATED: A. Factual Issues: - What is the true cash value of the subject property as of December 31, 2024? B. Legal Issues: - What is the lawful assessed and taxable value of the subject property for the 2025 tax year? V. DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE EVIDENCE? ☐ Yes ☒ No A. If yes, state all necessary amendments (a motion may be required to amend the pleadings): Not applicable. VI. ARE THERE CONSOLIDATION ISSUES? ☐ Yes ☒ No A. If yes, state the cases, by docket number, that should be consolidated with this case (a motion may be required to consolidate the cases): Not applicable. VII. PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY ISSUES, IF ANY: A. Motions: None at this time. B. Discovery:
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MT
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 MICHIGAN TAX TRIBUNAL Docket Number: 25-002212 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Prehearing Statement Attachment File Name: R's PHS_Groesbeck_FINAL Document Type: Valuation Disclosure Attachment File Name: R's VD_Groesbeck_FINAL Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N GRAND RIVER AVE, LANSING, MI 48906 NOTICE OF JANUARY 4 - 15, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Geosebeck Holdings Limited Partnership, Petitioner, v Township Of Clinton, Respondent. MTT Docket No. 25-002212 Please be advised that 25-002212 has been placed on a two-week Prehearing General Call commencing January 04, 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.
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MTT Docket No. 25-002212 Page 2 of 3 Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s website for more information. IT IS ORDERED that the parties shall: a. If no valuation disclosure is required, notify the Tribunal and the opposing parties in writing within 21 days of entry of this order that no valuation disclosure is being filed. The notice shall indicate the reason or reasons why no valuation disclosure is required (i.e., exemption claim, etc.). b. If a valuation disclosure is required, file and exchange their valuation disclosures by September 8, 2026. Valuation disclosures will not be admitted into evidence unless disclosed and furnished in accordance with this order (even though admissible) except upon a finding of good cause by the Tribunal. IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing Statements by September 8, 2026. Witnesses, with the exception of rebuttal witnesses, will not be allowed to testify unless disclosed in the Prehearing Statement and the Prehearing Statement is furnished in accordance with this order except upon a finding of good cause by the Tribunal. Failure to file the Prehearing Statement may result in holding a party or parties in default. See TTR 237. IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on September 8, 2026, which means all discovery
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MT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL GROESBECK HOLDINGS LIMITED PARTNERSHIP, Petitioner, v CHARTER TOWNSHIP OF CLINTON, Respondent. Docket No. 25-002212 Parcel No. 16-11-33-126-006 _____________________________________________________________________________/ BRIAN E. ETZEL (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, P.C. Attorney for Petitioner 380 N. Old Woodward Avenue, Suite 300 (248) 642-0333 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ ANSWER TO PETITION AND AFFIRMATIVE DEFENSES ANSWER Respondent, Charter Township of Clinton, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: The Parties 1. Respondent lacks the information and knowledge necessary to respond to the truth of the assertions set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 2. Respondent admits the allegations in Paragraph 2.
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Entire Tribunal Property Tax Answer Page 2 of 5 The Subject Property 3. Respondent admits the allegations in Paragraph 3 as to parcel number and address. As to the remainder of the allegations set forth, Respondent lacks the information and knowledge necessary to respond to the truth of said allegations and, therefore, leaves Petitioner to its proofs. 4. Respondent admits the allegations in Paragraph 4. 5. Respondent admits the allegations in Paragraph 5. The 2025 Assessment 6. Respondent admits the allegations in Paragraph 6. 7. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 $3,419,000 $1,709,500 $1,172,647 8. Respondent contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 $3,419,000 $1,709,500 $1,172,647 9. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 $0 $0 $0 10. Respondent acknowledges Petitioner’s beliefs as the issues relevant to this appeal but denies said issues have merit. Respondent further denies Petitioner has the right to raise issues not identified in its Petition at a later date. Moreover, Respondent denies Petitioner is entitled to any relief. 11. Respondent denies the allegations in Paragraph 11, including subsections (a)-(d), for the reason that the same are untrue. The assessed, state equalized, and/or taxable values do not exceed permitted amounts; do not exceed the percentage for true cash value permitted by law; were correctly determined and are based upon correct application of proper principles; and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 12. Respondent admits the subject property was uniformly assessed. Respondent denies that the subject property’s values were in any way overestimated.
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Entire Tribunal Property Tax Answer Page 3 of 5 Conclusion and Relief Requested 13. Respondent acknowledges the relief requested by Petitioner in the final paragraph of its Petition but denies that Petitioner is entitled to said relief for the reasons stated above. WHEREFORE, Respondent, Charter Township of Clinton, requests the Tribunal dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. HALLAHAN & ASSOCIATES, P.C. /s/Laura M. Hallahan______________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph
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Enti
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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. 25-002212 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Township Of Clinton (MACOMB) Local Unit of Government/First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State Michigan ZIP Code Telephone Number Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) Section 2: Attorney/Authorized Representative’s Contact Information First Name Laura M.I. M Last Name Hallahan Firm Name (if any) Hallahan & Associates, P.C. Address (No., Street, P.O. Box or Rural Route) 1750 S. Telegraph Road, Suite 202 City or Town Bloomfield Hills State Michigan ZIP Code 48302 Telephone Number 248-731-3087 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) MTT@hallahanlaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Kelsea M. Melcher /s/
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GROESBECK HOLDINGS LIMITED PARTNERSHIP, MTT Docket No. 25-002212 Petitioner, v. CHARTER TOWNSHP OF CLINTON, Respondent. PROOF OF SERVICE FOR PETITION AND NOTICE OF DOCKET NUMBER 01 999 131.DOCX STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneysfor Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com
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PROOF OF SERVICE FOR PETITION AND NOTICE OF DOCKET NUMBER Sarah Conner states that she served copies of the Entire Tribunal Property Tax Petition, Notice of Docket Number and this Proof of Service, on the persons listed below, by placing copies of those documents in a duly stamped, addressed envelope and placing the envelope in the United States mail on August 22, 2025. PERSONS SERVED: VIA US FIRST CLASS MAIL VIA CERTIFIED MAIL 01 999 131.DOCX Clinton Township Clerk 40700 Romeo Plank Road Clinton Township, MI 48038 Macomb County Equalization Director 1 S. Main, 6th Fl. Mt. Clemens, MI 48043 Macomb County Clerk 120 N. Main Mt. Clemens, MI 48043 Secretary of School Board Fraser Public School District 33466 Garfield Fraser, MI 48026 Clinton Township Assessor 40700 Romeo Plank Road Clinton Township, MI 48038 State Treasurer Michigan Department of Treasury Austin Building 430 W. Allegan Lansing, MI 48922 - ' Sarah Conner
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL GROESBECK HOLDINGS LIMITED PARTNERSHIP, Petitioner, Docket No. 25- Parcel No. 16-11-33-126-006 v. CHARTER TOWNSHIP OF CLINTON, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com ENTIRE TRIBUNAL PROPERTY TAX PETITION Petitioner GROESBECK HOLDINGS LIMITED PARTNERSHIP, by and through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. The Parties 1. Petitioner GROESBECK HOLDINGS LIMITED PARTNERSHIP is a Domestic limited partnership with its office at which records are kept located at 263 Pine Ridge, Bloomfield Hills, Michigan 48304. 2. Respondent the Charter Township of Clinton is a Michigan charter township with its principal offices located at 40700 Romeo Plank Road, Clinton Township, Michigan 48038.
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2 The Subject Property 3. Petitioner owns property identified as Parcel No. 16-11-33-126-006 and commonly known as 34800 Groesbeck Highway, Clinton Township, Michigan 48035 (the “Subject Property”). 4. The Subject Property is located in Macomb County and is within the Fraser Public School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2025 Assessment 6. For the 2025 tax year, Respondent classified the Subject Property as commercial real property. 7. For the 2025 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value $3,419,000 $1,709,500 $1,172,647 8. Petitioner contends that a lawful assessment of the Subject Property for the 2025 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value $1,600,000 $800,000 $800,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value $1,819,000 $909,500 $372,647 10. This Petition presents issues involving the Subject Property’s valuation for assessment purposes. Petitioner does not believe that this Petition presents any issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),
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3 defines those terms, but reserves its right to assert issues involving losses should information supporting such issues become available. 11. The Subject Property’s 2025 assessment (a) violates the Michigan Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 12. Petitioner does not assert that the Subject Property’s 2025 assessment is not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Property’s values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Property’s 2025 assessment to be consistent with the values set forth in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Brian E. Etzel Brian E. Etzel (P54905) Dated: June 2, 2025 Attorneys for Petitioner
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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 Geosebeck Holdings Limited Partnership, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002212 Township Of Clinton, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: __Tribunal Clerk________ Entered: August 15, 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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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL GROESBECK HOLDINGS LIMITED PARTNERSHIP, Petitioner, Docket No. 25- Parcel No. 16-11-33-126-006 v. CHARTER TOWNSHIP OF CLINTON, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com ENTIRE TRIBUNAL PROPERTY TAX PETITION Petitioner GROESBECK HOLDINGS LIMITED PARTNERSHIP, by and through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. The Parties 1. Petitioner GROESBECK HOLDINGS LIMITED PARTNERSHIP is a Domestic limited partnership with its office at which records are kept located at 263 Pine Ridge, Bloomfield Hills, Michigan 48304. 2. Respondent the Charter Township of Clinton is a Michigan charter township with its principal offices located at 40700 Romeo Plank Road, Clinton Township, Michigan 48038.
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2 The Subject Property 3. Petitioner owns property identified as Parcel No. 16-11-33-126-006 and commonly known as 34800 Groesbeck Highway, Clinton Township, Michigan 48035 (the “Subject Property”). 4. The Subject Property is located in Macomb County and is within the Fraser Public School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2025 Assessment 6. For the 2025 tax year, Respondent classified the Subject Property as commercial real property. 7. For the 2025 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value $3,419,000 $1,709,500 $1,172,647 8. Petitioner contends that a lawful assessment of the Subject Property for the 2025 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value $1,600,000 $800,000 $800,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value $1,819,000 $909,500 $372,647 10. This Petition presents issues involving the Subject Property’s valuation for assessment purposes. Petitioner does not believe that this Petition presents any issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),
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3 defines those terms, but reserves its right to assert issues involving losses should information supporting such issues become available. 11. The Subject Property’s 2025 assessment (a) violates the Michigan Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 12. Petitioner does not assert that the Subject Property’s 2025 assessment is not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Property’s values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Property’s 2025 assessment to be consistent with the values set forth in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Brian E. Etzel Brian E. Etzel (P54905) Dated: June 2, 2025 Attorneys for Petitioner
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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 GROESBECK HOLDINGS LIMITED PARTNERSHIP Home Address (No., Street, P.O. Box or Rural Route) 263 Pine Ridge City or Town Bloomfield Hills State Michigan ZIP Code 48304 Telephone Number 248-642-0333 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) beetzel@wwrplaw.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Brian M.I. E Last Name Etzel Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 380 N Old Woodward Ave Suite 300 City or Town Birmingham State Michigan ZIP Code 48009 Telephone Number 248-642-0333 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) beetzel@wwrplaw.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] 34800 Groesbeck Highway Clinton Township Michigan 48035 Taxing Authority (City or Township) Township Of Clinton (MACOMB) County Macomb If you are appealing more than one parcel, are they contiguous or adjoining? (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Section 7: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values Section 8: Valuation Information for Each Parcel under Appeal Parcel Number: 16-11-33-126-006 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 1709500 Current Taxable Value as established by the Board of Review: 1172647 What do you believe is the fair market value (also known as True Cash Value)? 1600000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 800000 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?
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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
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