Jackson Properties LLC Petitioner Vs. City Of Jackson Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Jackson Properties LLC,

Petitioner,

v

 

 

City Of Jackson,

Respondent.

 MTT Docket No. 26-000695

Please be advised that 26-000695 has been placed on a two-week Prehearing General 

Call commencing July 01, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 26-000695

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by March 4, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

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

Statements by March 4, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 4, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

July 1, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 3, 2026

Page 3

MTT Docket No. 26-000695

Page 3 of 3

PROOF OF SERVICE

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

parties or their attorneys or authorized

Page 4

STATE OF

Page 5

MTT

Page 6

MTT

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

______________________________________________________________________________ 

 

Jackson Properties, LLC, 

 

 

 

 

Petitioner, 

 

 

MTT Docket No. 26-000695 

 

 

 

 

 

 

 

Parcel No. 2-1742.0100 

 

 

 

 

 

 

 

 

 2-1737.5000 

 

 

-vs- 

 

 

 

 

 

ANSWER TO PETITION AND 

 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

City of Jackson, 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

_____________________________________________________________________________/ 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI. 48009 

(248)642-0333 

 

JACKSON CITY ATTORNEY’S OFFICE 

By: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

____________________________________________________________________________/ 

 

RESPONDENT CITY OF JACKSON’S 

ANSWER TO PETITION 

 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and for its Answer to Petitioner’s Petition, states as follows: 

1. Respondent neither admits nor denies the allegation contained in Paragraph 1 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

2. Respondent admits the allegation contained in Paragraph 2 of Petitioner’s Petition. 

3. Respondent admits the allegations contained in Paragraph 3 of Petitioner’s Petition. 

4. Respondent admits the allegations contained in Paragraph 4 of Petitioner’s Petition.

Page 2

2 

 

5. Respondent admits the allegations contained in Paragraph 5 of Petitioner’s Petition. 

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

7. Respondent admits the allegations contained in Paragraph 7 of Petitioner’s Petition. 

8. Respondent neither admits nor denies the allegation contained in Paragraph 8 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

9. Respondent neither admits nor denies the allegation contained in Paragraph 9 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

10. Respondent neither admits nor denies the allegation contained in Paragraph 10 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

11. Respondent denies the allegations contained in Paragraph 11 of Petitioner’s Petition as 

untrue. 

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

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

WHEREFORE, Respondent requests this Honorable Tribunal dismiss Petitioner’s 

Petition in its entirety, that it assess actual costs and attorney fees against Petitioner for costs 

incurred in responding to the Petition, and further requests all other relief the Tribunal deems to 

be just and equitable. 

 

 

Respectfully submitted, 

 

 

 

 

 

 

 

DATED: June 26, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

Page 3

3 

 

 AFFIRMATIVE DEFENSES 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and states the following Affirmative Defenses alternatively and consecutively: 

1. 

The subject property’s assessed, true cash, and taxable values are levied in 

accordance with the Michigan General Property Tax Act and Michigan Constitution. 

2. 

The subject property is assessed in accordance with generally accepted assessing 

standards. 

3. 

The subject property is assessed at no more than 50% of its true cash value. 

4. 

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

5. 

Respondent reserves the right to amend its affirmative defenses through the 

conclusion of discovery. 

Respectfully submitted, 

 

 

 

DATED: June 26, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

Page 4

4 

 

CERTIFICATE OF SERVICE 

 

STATE OF MICHIGAN 

 

) 

) ss 

COUNTY OF JACKSON 

 

) 

 

The undersigned certifies under penalty of perjury that on June 26, 2026 he served copies of 

Respondent City of Jackson’s Answer to Petition and Affirmative Defenses upon the 

Petitioner by first class mail with postage fully prepaid to the following address: 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI. 48009 

(248)642-0333 

 

 

 

 

 

 

 

 

 

 

 

 

 

DATED: June 26, 2026 

 

 

 

________________________________ 

 

Matthew M. Hagerty (P66015) 

 

Office of the City Attorney

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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: 26-000695

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

Party Filing Document 

Respondent

Files

Document Type: Amended Answer

Attachment File Name: Respondent City of Jackson - Answer and Affirmative Defenses w POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

JACKSON PROPERTIES, LLC, 

Docket No. 26-000695 

Parcel Nos. 2-1742.0100 

2-1737.5000 

Petitioner, 

v. 

CITY OF JACKSON, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, Notice of Docket Number, and this Proof of Service, on the 

persons listed below, by the means identified below, by placing those documents in 

duly stamped, addressed envelopes, and placing the envelopes in the United States 

mail on June 16, 2026. 

PERSONS SERVED: 

Certified Mail 

First Class Mail 

Clerk 

Clerk 

Secretary of School Board 

City of Jackson 

Jackson County 

Jackson Public Schools 

1st Floor 

312 S. Jackson St. 

522 Wildwood Ave. 

161 W. Michigan Ave. 

Jackson, MI 49201 

Jackson, MI 49201 

Jackson, MI 49201 

Assessor 

Director of 

State Treasurer 

City of Jackson 

Equalization 

Michigan Department of 

9th Floor 

Jackson County 

Treasury 

161 W. Michigan Ave. 

120 W. Michigan Ave. 

Austin Building 

Jackson, MI 49201 

16th Floor 

430 W. Allegan 

Jackson, MI 49201 

Lansing, MI 

48922 

wa 

Monica Athanas

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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: 26-000695

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 - Petition Jackson

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

JACKSON PROPERTIES, LLC, 

Docket No. 26-000695 

Parcel Nos. 2-1742.0100 

2-1737.5000 

Petitioner, 

v. 

CITY OF JACKSON, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, Notice of Docket Number, and this Proof of Service, on the 

persons listed below, by the means identified below, by placing those documents in 

duly stamped, addressed envelopes, and placing the envelopes in the United States 

mail on June 16, 2026. 

PERSONS SERVED: 

Certified Mail 

First Class Mail 

Clerk 

Clerk 

Secretary of School Board 

City of Jackson 

Jackson County 

Jackson Public Schools 

1st Floor 

312 S. Jackson St. 

522 Wildwood Ave. 

161 W. Michigan Ave. 

Jackson, MI 49201 

Jackson, MI 49201 

Jackson, MI 49201 

Assessor 

Director of 

State Treasurer 

City of Jackson 

Equalization 

Michigan Department of 

9th Floor 

Jackson County 

Treasury 

161 W. Michigan Ave. 

120 W. Michigan Ave. 

Austin Building 

Jackson, MI 49201 

16th Floor 

430 W. Allegan 

Jackson, MI 49201 

Lansing, MI 

48922 

wa 

Monica Athanas

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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: 26-000695

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 - Petition Jackson

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JACKSON PROPERTIES, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 2-1742.0100 

 2-1737.5000 

 

Petitioner, 

v. 

 

CITY OF JACKSON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Jackson Properties, LLC, by and through its attorneys, Williams 

Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner Jackson Properties, LLC is a Michigan limited liability 

company with its registered office located at 2900 Union Lake Road, Ste. 102, 

Commerce Township, Michigan 48382. 

2. 

Respondent City of Jackson is a Michigan municipal corporation with 

its primary offices located at 161 W. Michigan Avenue, Jackson, Michigan 49201.

Page 2

Petition Page 2 

The Subject Properties 

3. 

Petitioner owns properties identified as Parcel No. 2-1742.0100, 

commonly known as 1089 N. Wisner, Jackson, Michigan, 49202, and Parcel No. 2-

1737.5000, commonly known as 925 N. Wisner, Jackson, Michigan, 49202. These 

parcels are physically contiguous to each other. They are referred to collectively in 

this Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Jackson County and are within the 

Jackson Public Schools school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Properties. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ 

assessments for property taxes in the amounts set forth in paragraph 1 of the 

attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties 

for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the 

attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in 

paragraph 3 of the attached Multiple Parcel Form. 

10. 

This Petition presents issues involving the Subject Properties’ valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any

Page 3

Petition Page 3 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan 

Constitution, the GPTA, and other Michigan law, (b) are based on erroneous 

principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments 

are not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Properties’ 2026 assessments to amounts that do 

not exceed Petitioner’s contentions of value set forth on the attached Multiple Parcel 

Form and granting Petitioner all other relief to which it is entitled under Michigan 

law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

Page 4

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JACKSON PROPERTIES, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 2-1742.0100 

 2-1737.5000 

 

Petitioner, 

v. 

 

CITY OF JACKSON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s 

March 2026 Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 3,623,800 

 1,811,900 

 1,811,900 

2-1737.5000 

 1,612,800 

 806,400 

 740,158 

Totals: 

 5,236,600 

 2,618,300 

 2,552,058 

 

 

2. 

Petitioner contends that lawful 2026 assessments for the Subject 

Properties cannot exceed the following amounts: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 2,800,000 

 1,400,000 

 1,400,000 

2-1737.5000 

 1,200,000 

 600,000 

 600,000 

Totals: 

 4,000,000 

 2,000,000 

 2,000,000

Page 5

Multiple Parcel Form Page 2 

 

 

3. 

The amounts in dispute for the 2026 tax year are therefore as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 823,800 

 411,900 

 411,900 

2-1737.5000 

 412,800 

 206,400 

 140,158 

Totals: 

 1,236,600 

 618,300 

 552,058

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

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

Jackson Properties LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000695

City Of Jackson, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: June 2, 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

Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JACKSON PROPERTIES, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 2-1742.0100 

 2-1737.5000 

 

Petitioner, 

v. 

 

CITY OF JACKSON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Jackson Properties, LLC, by and through its attorneys, Williams 

Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner Jackson Properties, LLC is a Michigan limited liability 

company with its registered office located at 2900 Union Lake Road, Ste. 102, 

Commerce Township, Michigan 48382. 

2. 

Respondent City of Jackson is a Michigan municipal corporation with 

its primary offices located at 161 W. Michigan Avenue, Jackson, Michigan 49201.

Page 2

Petition Page 2 

The Subject Properties 

3. 

Petitioner owns properties identified as Parcel No. 2-1742.0100, 

commonly known as 1089 N. Wisner, Jackson, Michigan, 49202, and Parcel No. 2-

1737.5000, commonly known as 925 N. Wisner, Jackson, Michigan, 49202. These 

parcels are physically contiguous to each other. They are referred to collectively in 

this Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Jackson County and are within the 

Jackson Public Schools school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Properties. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ 

assessments for property taxes in the amounts set forth in paragraph 1 of the 

attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties 

for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the 

attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in 

paragraph 3 of the attached Multiple Parcel Form. 

10. 

This Petition presents issues involving the Subject Properties’ valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any

Page 3

Petition Page 3 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan 

Constitution, the GPTA, and other Michigan law, (b) are based on erroneous 

principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments 

are not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Properties’ 2026 assessments to amounts that do 

not exceed Petitioner’s contentions of value set forth on the attached Multiple Parcel 

Form and granting Petitioner all other relief to which it is entitled under Michigan 

law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

Page 4

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JACKSON PROPERTIES, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 2-1742.0100 

 2-1737.5000 

 

Petitioner, 

v. 

 

CITY OF JACKSON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s 

March 2026 Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 3,623,800 

 1,811,900 

 1,811,900 

2-1737.5000 

 1,612,800 

 806,400 

 740,158 

Totals: 

 5,236,600 

 2,618,300 

 2,552,058 

 

 

2. 

Petitioner contends that lawful 2026 assessments for the Subject 

Properties cannot exceed the following amounts: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 2,800,000 

 1,400,000 

 1,400,000 

2-1737.5000 

 1,200,000 

 600,000 

 600,000 

Totals: 

 4,000,000 

 2,000,000 

 2,000,000

Page 5

Multiple Parcel Form Page 2 

 

 

3. 

The amounts in dispute for the 2026 tax year are therefore as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

2-1742.0100 

 823,800 

 411,900 

 411,900 

2-1737.5000 

 412,800 

 206,400 

 140,158 

Totals: 

 1,236,600 

 618,300 

 552,058

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

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

JACKSON PROPERTIES, LLC

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

2900 Union Lake Road, Ste. 102

City or Town

Commerce Township

State

Michigan

ZIP Code

48382

Telephone Number

248-642-0333

Fax Number

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

jpesick@wwrplaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

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)

jpesick@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?2

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

1089 N. Wisner

Jackson

Michigan

49202

Taxing Authority (City or Township)

City Of Jackson (JACKSON)

County

Jackson

If you are appealing more than one parcel, are they contiguous or adjoining? Yes

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Page 2

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:

2-1742.0100

Classification of Property: Real 

Commercial

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

1811900

Current Taxable Value as established by the Board of Review:

1811900

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

2800000

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

1400000

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

Parcel Number:

2-1737.5000

Classification of Property: Real 

Commercial

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

806400

Current Taxable Value as established by the Board of Review:

740158

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

1200000

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

600000

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

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:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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? 

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 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/ Jerome P. Pesick

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.