Hillsdale Capital Management LLC Petitioner Vs. City Of Hillsdale Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

HILLSDALE CAPITAL MANAGEMENT 

LLC., 

 

 

Petitioner, 

 

v 

 

CITY OF HILLSDALE, 

 

 

Respondent. 

 

MTT Docket No. 26-001221 

 

Parcel Nos.: 30-006-222-101-01 

 

30-006-015-300-07 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, PC 

Attorneys For Petitioner 

1700 East Beltline Ave. NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

/ 

 

 

 

 

RESPONDENT’S APPEARANCE 

NOW COMES attorney Toby Koenig, of the law firm of Bloom Sluggett, PC, and 

hereby enters his appearance on behalf of Respondent City of Hillsdale in this matter. 

 

 

 

Dated: September 21, 2026 

Respectfully submitted by, 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

 

Toby Koenig (P72367) 

Attorneys for Respondents City of Hillsdale 

 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom 

Sluggett, PC, and that on September 21, 2026, she served a copy of Respondent’s Appearance, 

Answer to Petition and Proof of Service by e-mail and First-Class Mail upon Thomas K. Dillon 

at: tdillon@fosterswift.com and to Foster Swift Collins & Smith, PC, 1700 East Beltline Ave. 

NE, Suite 200, Grand Rapids, MI 49525. 

 

 

 

 

 

 

 

 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 

 

 Tonya Voakes

Page 2

1 

 

4937-3938-6834, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

HILLSDALE CAPITAL MANAGEMENT 

LLC., 

 

 

Petitioner, 

 

v 

 

CITY OF HILLSDALE, 

 

 

Respondent. 

 

MTT Docket No. 26-001221 

 

Parcel Nos.: 30-006-222-101-01 

 

30-006-015-300-07 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, PC 

Attorneys for Petitioner 

1700 East Beltline Ave NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

/ 

 

 

 

 

RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

Respondent City of Hillsdale, through its counsel, hereby submits the following Answer to 

Petition and Affirmative Defenses. 

1. Respondent admits the property parcel numbers as alleged in Paragraph 1. 

2. Respondent admits that the subject property is real property as alleged in Paragraph 2. 

3. Respondent admits that the parcels at issue are contiguous as alleged in Paragraph 3. 

4. There are no allegations in Paragraph 4 of the petition. 

5. There are no allegations in Paragraph 5 of the petition. 

6. Respondent admits that the subject parcels are classified as 201 Commercial Improved and 

202 Commercial Vacant. 

 

7. Respondent admits that Petitioner protested the 2026 assessment to the March Board of 

Review.

Page 3

2 

 

4937-3938-6834, v. 1 

 

8. The allegation in Paragraph 8 merely restates the allegation in Paragraph 7 and therefore 

no response is required. 

 

9. There are no allegations in Paragraph 9 of the petition. 

10. Respondent admits that the subject parcels are located in Hillsdale County and admits that 

the addresses of the subject parcels are 501 W. Carleton Rd. and 3003 W. Carleton Rd., 

Hillsdale, MI 48242. 

 

11. Respondent admits that it established the assessments for the subject property. 

12. Respondent lacks knowledge or information sufficient to form a belief as to where 

Petitioner maintains its principal legal residence or office address and therefore leaves 

Petitioner to its proofs. 

 

13. Paragraph 13 merely restates Petitioner’s claim and therefore no response is required; 

Respondent denies that the subject properties were improperly assessed, denies that there 

are issues involving uniformity, and further denies that Petitioner is entitled to any relief. 

 

14. Respondent admits that 2026 is the tax year at issue in this appeal. 

15. There are no allegations in Paragraph 15 of the petition. 

 

16. Respondent admits the values alleged in Paragraph 16 are the values established by 

Respondent’s Board of Review. 

 

17. Respondent denies that the values alleged by Petitioner in Paragraph 17 accurately reflect 

the subject property’s true cash, state equalized, and taxable values. 

 

18. Respondent admits that Petitioner alleges the values in dispute as set forth in Paragraph 18; 

however, Respondent denies that the subject property is improperly assessed and further 

denies that Petitioner is entitled to any relief. 

 

19. Paragraph 19 contains legal conclusions to which no response is required; Respondent 

otherwise denies the allegations and further denies that Petitioner is entitled to any relief. 

 

WHEREFORE, Respondent requests that the Tribunal dismiss Petitioner’s appeal with 

prejudice, and award Respondent its costs, attorney fees, and all such further and additional relief 

as this Tribunal may deem appropriate. 

 

AFFIRMATIVE DEFENSES 

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

Page 4

3 

 

4937-3938-6834, v. 1 

2. Petitioner’s claims against Respondent are barred because the valuation methods used 

by Respondent comply with the Constitution, state law, and prevailing State Tax Commission 

procedures. 

 

3. Respondent’s assessment reflects 50% of the subject property’s true cash value, and 

the values on the roll, including the taxable value, comply with the GPTA. 

 

4. Petitioner has failed to allege facts to support standing to bring this appeal or that it is 

a proper party-in-interest. 

 

5. Petitioner has failed to allege facts to support its allegation that the taxable value of the 

subject property is improper. 

 

6. 

Respondent reserves the right to assert additional affirmative defenses as they may 

become known through discovery. 

 

 

 

 

 

 

 

 

 

Dated: September 21,

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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. 26-001221

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Hillsdale (HILLSDALE)

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

Toby

M.I.

Last Name

Koenig

Firm Name (if any)

Bloom Sluggett PC

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

161 Ottawa Ave NW

Suite 400

City or Town

Grand Rapids

State

 Michigan

ZIP Code

49503

Telephone Number

(616) 965-9343

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

toby@bloomsluggett.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Toby Koenig

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

______________________________________________________________________________ 

 

HILLSDALE CAPITAL MANAGEMENT LLC., 

MTT Docket No. 26-001221 

 

 

 

Petitioner, 

 

 

 

 

PPNS: 30-006-222-101-01 

 

 

 

 

 

 

 

 

 

 30-006-015-300-07 

v. 

 

CITY OF HILLSDALE, 

 

 

 

Respondent. 

______________________________________________________________________________ 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, PC 

Attorneys for Petitioner 

1700 East Beltline Ave. NE, Ste. 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

______________________________________________________________________________ 

 

PROOF OF SERVICE FOR ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

Jaclyn R. Folkema, being first duly sworn, deposes and says that she is employed by Foster Swift 

Collins & Smith, PC, and that on August 24, 2026, she served a copy of the Petition and Notice of Docket 

Number relative to the above-captioned case upon the following: 

1. City of Hillsdale Assessor (via certified mail): 

Kimberly Thomas, 97 N. Broad Street, Hillsdale, MI 49242 

 

2. City of Hillsdale Clerk (via certified mail): 

Katy Price, 97 N. Broad Street, Hillsdale, MI 49242 

 

3. Hillsdale County Equalization Director (via first class mail): 

Nicolas Wheeler, 33 McCollum Street, Room 223, Hillsdale, MI 49242 

 

4. Hillsdale County Clerk (via first class mail): 

Abe Dean, 29 N. Howell Street, Room 1, Hillsdale, MI 49242 

 

5. Hillsdale Community School District – School Board Secretary (via first class mail): 

Rebecca Portteus, 30 S. Norwood Avenue, Hillsdale, MI 49242 

 

6. State of Michigan Treasurer (via first class mail): 

Michigan Department of Treasury, 430 W. Allegan Street, Lansing, MI 48922 

 

 

Dated: August 24, 2026 

 

 

/s/ Jaclyn R. Folkema 

 

 

 

 

 

 

 

 

Jaclyn R. Folkema 

90679:00001:202997799-1

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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: 26-001221

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: POS - Entire Tribunal Prop. Tax Petition - Hillsdale Capital v City of 

Hillsdale

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

HILLSDALE CAPITAL MANAGEMENT 

LLC, 

 

 

Petitioner, 

 

v 

 

CITY OF HILLSDALE, 

 

 

Respondent. 

 

 

MTT DOCKET NO. 26-_________ 

 

PPNs: 30-006-222-101-01 & 

 30-006-015-300-07 

 

 

 

 

 

Thomas K. Dillon (P81136) 

FOSTER, SWIFT, COLLINS & SMITH, P.C. 

Attorneys for Petitioner 

1700 East Beltline, N.E., Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

 

 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

 

Petitioner, by and through its attorneys, Foster Swift Collins & Smith, P.C., for its Entire 

Tribunal Property Tax Petition, states as follows: 

1. 

Property Parcel Nos.: 30-006-222-101-01 & 30-006-015-300-07. 

2. 

The property identified above is Real Property. 

3. 

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

contiguous? Yes. 

4. 

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

appeal? N/A.

Page 2

5. 

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

statements filed by parcel number (attach additional page if necessary): N/A. 

6. 

The property identified above is classified as: 201 Commercial Improved and 202 

Commercial Vacant. 

7. 

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

Respondent’s _X_ March __ July __ December Board of Review. 

8. 

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

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

assessments at issue (attach additional page if necessary): Protest was made to Respondent’s 

March Board of Review. 

9. 

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

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

involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s 

authority over the assessment or assessments at issue (attach additional page if necessary): N/A. 

10. 

The property or properties at issue are located in Hillsdale County. The property’s 

address is: 501 W Carleton Rd & 3003 W. Carleton Rd., Hillsdale, MI 48242. 

11. 

The assessment or assessments at issue were established by the: City of Hillsdale. 

12. 

Petitioner’s legal residence or principal office address is: 195 W. Bacon St., 

Hillsdale, MI 49242. 

13. 

This appeal involves issues relating to: 

a. 

The property’s true cash and taxable values; and 

b. 

The uniformity of the property’s assessment. 

14. 

The tax year(s) at issue are: 2026.

Page 3

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which the Petitioner relies to invoke the Tribunal’s authority over the prior tax year or 

years (attach additional page if necessary): N/A. 

16. 

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

of Review are: 

Tax Year 

Parcel No. 

True Cash Value 

State 

Equalized 

Value 

Taxable Value 

2026 

30-006-222-101-01 

$1,265,000 

$632,500 

$568,547 

2026 

30-006-015-300-07 

$249,600 

$124,800 

$124,800 

 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

Parcel No. 

True Cash Value 

State 

Equalized 

Value 

Taxable Value 

2026 

30-006-222-101-01 

$850,000 

$425,000 

$425,000 

2026 

30-006-015-300-07 

$150,000 

$75,000 

$75,000 

 

18. 

The values in dispute for the property identified above are: 

Tax Year 

Parcel No. 

True Cash Value 

State 

Equalized 

Value 

Taxable Value 

2026 

30-006-222-101-01 

$415,000 

$207,500 

 

$143,547 

2026 

30-006-015-300-07 

$99,600 

$49,800 

$49,800 

 

19. 

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:

Page 4

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. 

 

WHEREFORE, Petitioner respectfully requests that this 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 to the reductions, with interest, as provided by the Tax 

Tribunal Act. 

Respectfully submitted, 

 

 

 

 

 

FOSTER SWIFT COLLINS & SMITH, PC 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

Dated: May 21, 2026 

 

By: 

___________________________________ 

 

 

 

 

 

 

Thomas K. Dillon (P81136) 

 

 

 

 

 

 

1700 E. Beltline Ave. NE, Suite 200 

 

 

 

 

 

 

Grand Rapids, MI 49525 

 

 

 

 

 

 

(616) 726-2258 

 

Filing Fee: $425 

 

90679:00001:202623514-1

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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 - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Hillsdale Capital Management LLC

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

195 W. Bacon St.

City or Town

Hillsdale

State

Michigan

ZIP Code

49242

Telephone Number

616-726-2258

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

tdillon@fosterswift.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Thomas

M.I.

Last Name

Dillon

Firm Name (if any)

Foster Swift Collins & Smith PC

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

1700 E. Beltline Ave. NE

Suite 200

City or Town

Grand Rapids

State

Michigan

ZIP Code

49525

Telephone Number

(616) 726-2258

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

tdillon@fosterswift.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

2

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

501 W. Carleton Rd. and 3003 W. Carleton Rd.

Hillsdale

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48242

Taxing Authority (City or Township)

City Of Hillsdale (HILLSDALE) 

County

Hillsdale

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.)

Yes

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

30-006-222-101-01

Classification of Property: Real (check one)

Commercial (check one)

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

632500

Current Taxable Value as established by the Board of Review:

568547

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

850000

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

425000

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

425000

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

30-006-015-300-07

Classification of Property: Real (check one)

Commercial (check one)

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

124800

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

124800

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

150000

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

75000

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

75000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Thomas K. Dillon

Payment Information

Amount: 425

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052186408132

Supporting Waiver Documents:

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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

Hillsdale Capital Management LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001221

City Of Hillsdale, 

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 29, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

HILLSDALE CAPITAL MANAGEMENT 

LLC, 

 

 

Petitioner, 

 

v 

 

CITY OF HILLSDALE, 

 

 

Respondent. 

 

 

MTT DOCKET NO. 26-_________ 

 

PPNs: 30-006-222-101-01 & 

 30-006-015-300-07 

 

 

 

 

 

Thomas K. Dillon (P81136) 

FOSTER, SWIFT, COLLINS & SMITH, P.C. 

Attorneys for Petitioner 

1700 East Beltline, N.E., Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

 

 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

 

Petitioner, by and through its attorneys, Foster Swift Collins & Smith, P.C., for its Entire 

Tribunal Property Tax Petition, states as follows: 

1. 

Property Parcel Nos.: 30-006-222-101-01 & 30-006-015-300-07. 

2. 

The property identified above is Real Property. 

3. 

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

contiguous? Yes. 

4. 

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

appeal? N/A.

Page 2

5. 

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

statements filed by parcel number (attach additional page if necessary): N/A. 

6. 

The property identified above is classified as: 201 Commercial Improved and 202 

Commercial Vacant. 

7. 

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

Respondent’s _X_ March __ July __ December Board of Review. 

8. 

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

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

assessments at issue (attach additional page if necessary): Protest was made to Respondent’s 

March Board of Review. 

9. 

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

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

involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s 

authority over the assessment or assessments at issue (attach additional page if necessary): N/A. 

10. 

The property or properties at issue are located in Hillsdale County. The property’s 

address is: 501 W Carleton Rd & 3003 W. Carleton Rd., Hillsdale, MI 48242. 

11. 

The assessment or assessments at issue were established by the: City of Hillsdale. 

12. 

Petitioner’s legal residence or principal office address is: 195 W. Bacon St., 

Hillsdale, MI 49242. 

13. 

This appeal involves issues relating to: 

a. 

The property’s true cash and taxable values; and 

b. 

The uniformity of the property’s assessment. 

14. 

The tax year(s) at issue are: 2026.

Page 3

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which the Petitioner relies to invoke the Tribunal’s authority over the prior tax year or 

years (attach additional page if necessary): N/A. 

16. 

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

of Review are: 

Tax Year 

Parcel No. 

True Cash Value 

State 

Equalized 

Value 

Taxable Value 

2026 

30-006-222-101-01 

$1,265,000 

$632,500 

$568,547 

2026 

30-006-015-300-07 

$249,600 

$124,800 

$124,800 

 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

Parcel No. 

True Cash Value 

State 

Equalized 

Value 

Taxable Value 

2026 

30-006-222-101-01 

$850,000 

$425,000 

$425,000 

2026 

30-006-015-300-07 

$150,000 

$75,000 

$75,000 

 

18. 

The values in dispute for the property identified above are: 

Tax Year 

Parcel No. 

True Cash Value 

State 

Equalized 

Value 

Taxable Value 

2026 

30-006-222-101-01 

$415,000 

$207,500 

 

$143,547 

2026 

30-006-015-300-07 

$99,600 

$49,800 

$49,800 

 

19. 

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:

Page 4

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. 

 

WHEREFORE, Petitioner respectfully requests that this 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 to the reductions, with interest, as provided by the Tax 

Tribunal Act. 

Respectfully submitted, 

 

 

 

 

 

FOSTER SWIFT COLLINS & SMITH, PC 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

Dated: May 21, 2026 

 

By: 

___________________________________ 

 

 

 

 

 

 

Thomas K. Dillon (P81136) 

 

 

 

 

 

 

1700 E. Beltline Ave. NE, Suite 200 

 

 

 

 

 

 

Grand Rapids, MI 49525 

 

 

 

 

 

 

(616) 726-2258 

 

Filing Fee: $425 

 

90679:00001:202623514-1

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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 - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Hillsdale Capital Management LLC

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

195 W. Bacon St.

City or Town

Hillsdale

State

Michigan

ZIP Code

49242

Telephone Number

616-726-2258

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

tdillon@fosterswift.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Thomas

M.I.

Last Name

Dillon

Firm Name (if any)

Foster Swift Collins & Smith PC

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

1700 E. Beltline Ave. NE

Suite 200

City or Town

Grand Rapids

State

Michigan

ZIP Code

49525

Telephone Number

(616) 726-2258

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

tdillon@fosterswift.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

2

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

501 W. Carleton Rd. and 3003 W. Carleton Rd.

Hillsdale

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48242

Taxing Authority (City or Township)

City Of Hillsdale (HILLSDALE) 

County

Hillsdale

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.)

Yes

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

30-006-222-101-01

Classification of Property: Real (check one)

Commercial (check one)

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

632500

Current Taxable Value as established by the Board of Review:

568547

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

850000

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

425000

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

425000

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

30-006-015-300-07

Classification of Property: Real (check one)

Commercial (check one)

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

124800

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

124800

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

150000

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

75000

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

75000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Thomas K. Dillon

Payment Information

Amount: 425

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052186408132

Supporting Waiver Documents:

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.