Michigan

Groesbeck Cp & Mp Investments LLC, Roseville Investment Holding LLC Petitioners Vs. City Of Fraser Respondent

Petitioner: Groesbeck Cp & Mp Investments LLC, Roseville Investment Holding LLC
Respondent: City Of Fraser

Case overview

Docket number: 26-002524-TT
Status: Disposed
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
7	Consent Judgment	Not recorded	Not recorded	10/06/2026	Not recorded	Download
6	A Stipulation has been received.	Not recorded	Not recorded	09/18/2026	$50.00	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
5	Answer was received	RESP	Not recorded	09/18/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
4	Proof of service of petition was received.	PET	Not recorded	08/07/2026	Not recorded	Download
3	Petition has been verified	PET	1	06/30/2026	Not recorded	Download
2	Notice of Docket Number ET	Not recorded	Not recorded	06/30/2026	Not recorded	Download
1	A petition was received.	PET	Not recorded	04/16/2026	$600.00	Download

Documents

26-002524 CJ.pdfRead complete document text →

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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

Groesbeck CP & MP Investments LLC and

MICHIGAN TAX TRIBUNAL

Roseville Investment Holding LLC

Petitioners,

MTT Docket No. 26-002524

City of Fraser,

Presiding Judge

Respondent.

Marcus L. Abood

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

CONSENT JUDGMENT

The Tribunal has considered the file in this case and the submitted Stipulation for Entry

of Consent Judgment (Stipulation) and finds that the Stipulation meets all filing and

statutory requirements.1 As such, the Tribunal shall enter the Stipulation. Therefore,

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise

indicated.

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment

rolls for the tax years at issue shall correct or cause the assessment rolls to be

corrected to reflect the property’s true cash and taxable values as provided in this

Consent Judgment within 20 days of the entry of the Consent Judgment.2

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the

affected taxes shall collect taxes and any applicable interest or issue a refund as

required by the Consent Judgment within 28 days of the entry of the Consent

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a

proportionate share of any property tax administration fees paid and of penalty and

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated,

separately indicate the amount of the taxes, fees, penalties, and interest being

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless

otherwise indicated, bear interest from the date of payment to the date of judgment and

the judgment shall bear interest to the date of its payment. A sum determined by the

Tribunal to have been underpaid shall not bear interest for any time period prior to 28

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%,

1 See MCL 211.27a.

2 See MCL 205.755.

Page 2

MTT Docket No. 26-002524 

Page 2 of 2 

 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

(xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%, and (xx) after 

July 1, 2026, through December 31, 2026, at a rate of 7.85%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

Entered: October 6, 2026 

 

 

 

By: /s/ Marcus L. Abood 

am 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Stipulation.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Groesbeck CP & MP Investments LLC & Roseville 

Investment Holding LLC, 

 

Petitioner, 

 

vs. 

 

City of Fraser, 

 

Respondent. 

MTT Docket No. 26-002524 

_____________________________________________________________________________/ 

 

CLARK PATTAH 

Representative for Petitioner 

2207 Orchard Lake Road 

Sylvan Lake, MI 48320-1786 

(248) 939-1400 

 

 

SETH A. O’LOUGHLIN (P80257) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

_____________________________________________________________________________/ 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

 

1. 

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

 

2. 

Property Parcel No: 03-14-05-376-032 

 

3. 

The property is in Macomb County. 

 

4. 

The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

03-14-05-376-032 

$6,861,600 

 

$3,430,800 

 

$2,976,919 

 

5. 

The 2026 values for the property identified above as stipulated by the parties for 

settlement purposes are: 

 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

03-14-05-376-032 

$4,700,000 

$2,350,000 

$2,350,000

Page 2

MTT Docket No. 25-002524 

Consent Judgment, Page 2 of 2 

 

6. 

If stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or 

years (attach additional page if necessary): 

 

7. 

List separately any special terms or conditions being proposed by the parties that would 

affect the execution of this Consent Judgment including, but not limited to, the joint 

payment of the refund, the waiver of interest, etc. (attach additional page if necessary): 

 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

 

The parties hereby waive interest attributable to the reductions for all taxing 

authorities. 

 

CALCULATIONS OF THE REFUND AMOUNT SHALL BE SENT TO 

PETITIONER. 

 

 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

 //s/ Clark Pattah_____________________________________________________________ 

Clark Pattah 

 

Signature of Respondent’s authorized representative: 

_//s// Seth A. O’Loughlin_______________________________________________________ 

Seth A. O’Loughlin

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-002524

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

Party Filing Document 

Respondent

Files

Document Type: Stip for Consent Judgment

Attachment File Name: Stipulation

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Groesbeck CP & MP Investments LLC & Roseville 

Investment Holding LLC, 

 

Petitioner, 

 

vs. 

 

City of Fraser, 

 

Respondent. 

MTT Docket No. 26-002524 

 

_____________________________________________________________________________/ 

 

CLARK PATTAH 

Representative for Petitioner 

2207 Orchard Lake Road 

Sylvan Lake, MI 48320-1786 

(248) 939-1400 

 

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 City of Fraser, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1 as to the parcel number, 

address, classification, County, and school district. 

 

2. 

Respondent admits that no Board of Review protest was made. 

 

3. 

Respondent admits the allegations in Paragraph 3. 

 

4. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 4 and leaves Petitioner to its proofs.

Page 2

Entire Tribunal Property Tax Answer

Page 2 of 5

Respondent lacks the information necessary to respond to the allegations in

Paragraph 5 and leaves Petitioner to its proofs.

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal, but

denies that those issues have merit and also denies that Petitioner is entitled to any relief.

Respondent admits the allegations in Paragraph 7.

The 2026 values for the property identified above as established by Respondent’s

Board of Review are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2026

$6,861,600

$3,430,800

$2,976,919

Respondent contends that the 2026 values for the property identified above are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2026

$6,861,600

$3,430,800

$2,976,919

10.

The values in dispute for the property identified above are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2026

$8,875,600

$4,437,800

$4,162,953

11.

Petitioner is not entitled to the relief requested in Paragraph 11, including all

subparagraphs, for the reason that Petitioner’s amounts do not reflect the accurate valuations for

this property. Furthermore, 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 principals, and the values

and Respondent’s mode of assessment are non-discriminatory and constitutional.

WHEREFORE, Respondent City of Fraser 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.

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Seth O’Loughlin______________ 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 18, 2026 

 

 

 

(248) 731-3089 

 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent City of Fraser asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 

(1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question.

Page 4

Entire Tribunal Property Tax Answer

Page 4 of 5

Petitioner has failed to show that any factor other than fifty percent (50%) was

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts

to support its allegations that the property’s taxable value is improper.

Petitioner asks the Tribunal to grant it preference by application of a self-chosen

method of assessment contrary to the intent, purpose and law of this State.

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by

application of a method of assessment different from that employed in the assessment of other

properties in Respondent’s taxing unit.

Petitioner, in essence, seeks by petition to challenge the process of county and

state equalization as to which it has no legal standing and cannot maintain a cause of action.

10.

Any decrease in the value of Petitioner’s property was a result of its own

intentional acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise

equitable tax burden.

11.

Respondent has properly and lawfully assessed Petitioner’s property and

established its taxable value in accordance with statutory and constitutional requirements.

12.

Petitioner has failed to pursue its appeal in a timely fashion.

13.

Respondent reserves the right to raise additional affirmative defenses as the same

may become known to it

Page 5

Enti

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-002524

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Fraser (MACOMB)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Halahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302-2073

Telephone Number

2487313090

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

lhallahan@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Laura M. Hallahan

/s/

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26-002524.pdfRead complete document text →

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Page 1

RECEIVED 

AUG 10 2026 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Groesbeck CP & MP Investments LLC & Roseville 

Investment Holding LLC, 

Petitioner, 

MTT Docket No. 26-002524 

vs. 

City of Fraser, 

Respondent. 

/ 

PROOF OF SERVICE 

(Property Tax Petition) 

On the date below 

I sent by certified mail, return receipt requested. a copy of the Petition to: 

City Assessor 

City Clerk 

City of Fraser 

City of Fraser 

33000 Garfield Rd 

33000 Garfield Rd 

Fraser, M1 48026 

Fraser, MI 48026 

On the date below 1 sent by first cluss mail a copy of the Petition to: 

Equalization Director 

County Clerk 

Macomb County 

Macomb County 

1 

S. Main, 6th Floor 

120 N. Main 

Mount Clemens, M1 48043 

Mount Clemens, MI 48043 

Secretary, Board of Education 

State Treasurer 

Fraser Public Schools 

Department of Treasury 

33466 Garfield Rd 

430 W. Allegan Street 

Fraser, MI 48026 

Lansing, MI 48922 

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

Celik

Page 2

RECEIVED 

APR 2 9 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAI 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

Roseville Investment Holding, LLC & 

Groesbeck CP & MP Investments, LLC 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

Docket No. 26- 002524 

\ 

Parcel No. 

03-14-05-376-032 

City of Fraser, 

Respondent. 

/ 

raninfosd606 2601G172-1 

04/20/2% 

5 

Chkft: 

1108 

Ant: $600.00 

PROPERTY TAX PETITION 

. 

or 

- 

-OTHEN 

SIT 

(Entire Tribunal, 2026 Tax Year) 

D 

ROSEQILLE THUESTHENT HOLDING LLC 

Petitioner, by and through its attorneys, Clark Pattah, contends: 

Ls 

The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

| 03-14-05-376-032 

Address 

31240 Groesbeck Hwy 

Classification 

201 Comm 

| Use 

Retail 

County 

Macomb 

| Sch Dist | Fraser 

2. 

N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[J March, 

[J July, 

[J December 

Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4, 

Petitioner 

is 

a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 

2207 Orchard Lake Road, 

Sylvan Lake, MI 48320-1786. 

6. 

This appeal involves issues related to: 

EY 

the subject property’s true cash and taxable values

Page 3

Petition 

9. 

10. 

11. 

The tax year at issue is 2026. 

The values! established by Respondent’s Board of Review for the subject property are: 

Parcel Number 

TCV 

SEV 

TV 

03-14-05-376-032 

6,861,600 

3,430,800 

2,976,919 

Petitioner contends that the values' for the subject property are: 

Parcel Number 

TCV 

SEV 

Tv 

03-14-05-376-032 

3,580,000 

1,790,000 

1,790,000 

The values! in dispute are. 

Parcel Number 

TCV 

SEV 

TV 

03-14-05-376-032 

3,281,600 

1,640,800 

1,186,919 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(2) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

©) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioners property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

and 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

constitutional rights of uniformity, equal protection and due process of law. 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds atibutable 

to the reductions, with interest, as provided by the Tax Tribunal Act.

Page 4

Petition 

Dated: April 15, 2026 

Filing Fee: $600 

(A 

Clark Pattah 

Representative for Petitioner 

2207 Orchard Lake Road 

Sylvan Lake, MI 48320-1786 

clark@pattahdevelopment.com 

(248) 939-1400

Page 5

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Grosebeck Cp - MP Investments LLC.pdfRead complete document text →

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Page 1

RECEIVED 

APR 2 2 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

Roseville Investment Holding, LLC & 

Groesbeck CP & MP Investments, LLC 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

Docket No. 

26- 

v 

Parcel No. 

03-14-05-376-032 

City of Fraser, 

Respondent. 

/ 

Trannfo:d606 26114171 04/20/% 

Chit: 

1108 

Ant: $600.00 

PROPERTY TAX PETITION 

7." 

v 

(Entire Tribunal, 2026 Tax Year) ID: 

ROGEVILLE TNVESTHENT HOLDING LLC 

Petitioner, by and through its attorneys, Clark Pattah, contends: 

1. 

The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

| 03-14-05-376-032 

Address 

31240 Groesbeck Hwy 

Classification 

201 Comm 

Use 

Retail 

County 

Macomb 

| Sch Dist | Fraser 

2. 

N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[0 March, 

[J July, 

[J December 

Board of Review. 

3: 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner is 

a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 

2207 Orchard Lake Road, 

Sylvan Lake, MI 48320-1786. 

6. 

This appeal involves issues related to:

Page 2

Petition 

10. 

11. 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

The tax year at issue is 2026. 

The values’ established by Respondent’s Board of Review for the subject property are: 

Parcel Number 

TCV 

SEV 

TV 

03-14-05-376-032 

6,861,600 

3,430,800 

2,976,919 

Petitioner contends that the values’ for the subject property are: 

Parcel Number 

TCV 

SEV 

TV 

03-14-05-376-032 

3,580,000 

1,790,000 

1,790,000 

The values! in dispute are. 

Parcel Number 

TCV 

SEV 

TV 

03-14-05-376-032 

3,281,600 

1,640,800 

1,186,919 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioners property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioner’s property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

and 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

constitutional rights of uniformity, equal protection and due process of law. 

to the reductions, with interest, as provided by the Tax Tribunal Act.

Page 3

Petition 

Dated: April 15,2026 

Filing Fee: $600 

£4 

Clark Pattah 

Representative for Petitioner 

2207 Orchard Lake Road 

Sylvan Lake, MI 48320-1786 

clark@pattahdevelopment.com 

(248) 939-1400

Page 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

Groesbeck CP & MP Investments LLC,Roseville Investment Holding LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

MTT Docket No.: 26-002524

City Of Fraser,

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: June 30, 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