Jbt Shelby LLC Petitioner Vs. Township Of Shelby Respondent

Page 1

KIRK. HUTH, LANGE 

&« BADALAMENTI. ».L.C. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

MTT Docket No. 26-001528 

vs. 

Parcel No. 23-07-36-302-006 

CHARTER TOWNSHIP OF SHELBY, 

Respondent. 

/ 

LAW OFFICE OF AARON M, FALES, P.C. 

KIRK, HUTH, LANGE & BADALAMENTI, PLC 

AARON M. FALES, (P72864) 

ROSEMARY V. DAVIS (P47336) 

Attorneys for Petitioner 

ROBERT S. HUTH, JR. (P42531) 

330 Hamilton Row, Suite 350 

Attorneys for Respondent 

Birmingham, MI 48009 

19500 Hall Road, Suite 100 

(248) 767-9840 

Clinton Township, MI 48038 

afaleslaw@gmail.com 

(586) 412-4900 

rdavis@kirkhuthlaw.com 

/ 

RESPONDENT’S ANSWER TO PETITION 

NOW COMES the Respondent, CHARTER TOWNSHIP OF SHELBY, by and through 

its attorneys, KIRK, HUTH, LANGE & BADALAMENTI, PLC, and for its Answer to Petition, 

states as follows: 

1. 

Answering Paragraph 

1, Respondent lacks knowledge or information sufficient to 

form a belief as to the truth of the allegations set forth therein and therefore leaves Petitioner to its 

strict proofs.

Page 2

KIRK. HUTH. LANGE 

&¢ BADALAMENTI, r.L.C. 

5. 

Answering Paragraph 5, Respondent lacks knowledge or information sufficient to 

form a belief as to the truth of the allegations set forth therein and therefore leaves Petitioner to its 

strict proofs. 

6. 

Answering Paragraph 6, Respondent lacks knowledge or information sufficient to 

form a belief as to the truth of the allegations set forth therein and therefore leaves Petitioner to its 

strict proofs. 

7. 

Answering Paragraph 7, Respondent denies the allegations contained therein for the 

reason they are untrue, inclusive of paragraphs (a) through (d). 

Respondent requests that the Tribunal deny the relief requested and uphold the assessment 

issued. 

Respondent reserves the right to amend this Answer to include any additional defenses or 

information that may become known to Respondent during the course of this proceeding. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss 

Petitioner’s Petition and grant any further relief that this Tribunal deems appropriate and just. 

Respectfully Submitted, 

KIRK, HUTH, LANGE & BADALAMENTI, PLC 

[s/Rosemary V. Davis 

ROSEMARY V. DAVIS (P47336) 

Attorneys for Respondent 

19500 Hall Road, Ste. 100 

Clinton Township, MI 48038

Page 3

KIRK. HUTH, LANGE &« BADALAMENTI, r.L.C. 

AFFIRMATIVE DEFENSES 

Respondent, CHARTER TOWNSHIP OF SHELBY, through its attorneys, KIRK, HUTH, 

LANGE & BADALAMENTI, PLC, files the following Affirmative Defenses: 

1. 

Petitioner has failed to allege specific and sufficient facts upon which the mode and 

method of appraising property fail to conform with mode and method applied to all other properties 

in the community. 

2. 

Petitioner has failed to show that any fact other than 50 percent was applied to the true 

cash value of the property. 

3. 

Petitioner is asking this Honorable Tribunal to make an underassessment based upon 

an arbitrary basis. 

4. 

A levy of all taxes are required to be made based upon the assessment of 50 percent 

of true cash value as ultimately determined by the process of county and state equalization. 

5. 

Respondent reserves the right to file additional affirmative defenses as may become 

apparent in this case. 

Respectfully Submitted, 

KIRK, HUTH, LANGE & BADALAMENT], PLC 

{s/[Rosemary V. Davis 

ROSEMARY V. DAVIS (P47336) 

Attorneys for Respondent 

19500 Hall Road, Ste. 100 

Clinton Township, MI 48038 

(586) 412-4900

Page 4

KIRK. HUTH, LANGE &« BADALAMENTI, p.LC. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

MTT Docket No. 26-001528 

* 

Parcel No. 23-07-36-302-006 

Respondent. 

/ 

PROOF OF SERVICE 

The undersigned certifies that on September 24, 2026, she served a copy of: 

Respondent’s Answer to Petition, Affirmative Defenses and Proof of Service 

upon: 

Aaron M. Fales, Esq. 

Law Office of Aaron M. Fales, P.C. 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

via First Class Mail, with postage prepaid thereon. 

I declare that the above information is true to the best of my information, knowledge and 

belief. 

[s/Carol Wilson 

Carol Wilson

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 - Respondent

MTT DOCKET NO. 26-001528

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Shelby (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

Rosemary

M.I.

V.

Last Name

Davis

Firm Name (if any)

Kirk, Huth, Lange & Badalamenti PLC

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

19500 Hall Road

Ste. 100

City or Town

Clinton Township

State

 Michigan

ZIP Code

48038

Telephone Number

586-412-4900

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

rdavis@kirkhuthlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Rosemary V. Davis

/s/

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 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

v. 

MTT Docket # 26-001528 

TOWNSHIP OF SHELBY, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

} 

} ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on September IS 

, 2026 he served a 

copy of Petitioner's Petition on the parties named on the attached list. 

el 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

SHELBY TWP. - MACOMB 

52700 VAN DYKE 

SHELBY TWP., MI 48316 

ASSESSOR 

SHELBY TWP. - MACOMB 

52700 VAN DYKE 

SHELBY TWP., MI 48316 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

- 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

UTICA COMMUNITY SCHOOLS 

11303 GREENDALE DRIVE 

STERLING HEIGHTS, MI 48312-2925 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, Mi 48922

Page 3

STATE OF MICHIGAN 

GRETGHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

JBT Shelby LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001528 

Township Of Shelby, 

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 205.7354, 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), “[{lhe 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 Tribunals rules. 

By: Tribunal Clerk 

Entered: August 14, 2026 

PROOF OF SERVICE 

| 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

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

MTT Docket #26- 001528 

vs. 

Parcel No. 23-07-36-302-006 

SHELBY TOWNSHIP, 

Respondent. 

/ 

PETITION 

JBT SHELBY LLC ("Petitioner"}, through its attorneys, Law Office of Aaron M. 

Fales, P.C., says: 

I. 

Petitioner's principal office address 

is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. 

Petitioner is a party in interest with respect to property 

faxes on real property tax parcel no. 23-07-36-302-006 ("Petitioner's Property"), at 

45660 Schoenherr, Shelby Twp., Ml. 

2. 

Respondent, Shelby Township assesses and collects property taxes 

on Petitioner's Property. 

3. 

In 2026, Respondent determined the taxable value of Petitioner's 

Property fo be $374,300 and assessed Petitioner's Property at $374,300 resulting in 

a state equalized value of the same amount based on the tenative equalization

Page 5

Petitioner's 

Property 

was 

originally 

designed 

to 

be 

used 

for 

commercial 

purposes. 

5. 

This matter involves issues relating to: (a) valuation, {b) assessment, 

(c) taxable value, and {d} uniformity. 

6. 

At this time, Petitioner believes, as 

it relates to taxable value, that 

there is a dispute relative fo the value of a loss. 

7. 

The 2026 assessment, including state equalized value and taxable 

value, 

imposed 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

(a) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

(lb) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable value, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes; 

(c) 

The 

assessment, 

including 

taxable 

value 

and/or 

state 

equalized value, are based upon an erroneous determination of the true cash 

value of that portion of Petitioner's Property that is taxable under Michigan law,

Page 6

discriminate against Petitioner and deny Petitioner 

its constitutional 

rights 

to 

uniformity, equal protection and due process of law. 

WHEREFORE, 

Petitioner requests 

that 

the 

Tax Tribunal 

enter 

an Order 

reducing 

the 

2026 

taxable 

value 

of 

Petitioner's 

Property 

from 

$374,300 

to 

$125,000, 

and 

reducing 

the 

2026 

assessed 

and 

state 

equdlized 

values 

of 

Petitioner's Property from $374,300 to $125,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

Respectfully submitted, 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

Pd 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, Mi 48009 

(248) 767-9840 

By: 

Dated: May 27, 2026

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001528

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: 26 - Shelby POS

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 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

vs. 

SHELBY TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 23-07-36-302-006 

 

PETITION 

 

 

JBT SHELBY LLC (“Petitioner”), through its attorneys, Law Office of Aaron M. 

Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 23-07-36-302-006 ("Petitioner's Property"), at 

45660 Schoenherr, Shelby Twp., MI. 

 

2. 

Respondent, Shelby Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

 In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $374,300 and assessed Petitioner's Property at $374,300 resulting in 

a state equalized value of the same amount based on the tenative equalization 

factor. 

 

4. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is a commercial property. Petitioner believes that

Page 2

Petitioner's Property was originally designed to be used for commercial 

purposes. 

 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, 

(c) taxable value, and (d) uniformity. 

 

6. 

At this time, Petitioner believes, as it relates to taxable value, that 

there is a dispute relative to the value of a loss. 

 

7. 

The 2026 assessment, including state equalized value and taxable 

value, imposed on Petitioner's Property, and the taxes to be levied and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

 

 

(a) 

The assessment, including state equalized value and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or 

taxable value, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes; 

 

 

(c) 

The assessment, including taxable value and/or state 

equalized value, 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 assessment, including state equalized value and/or 

taxable value, and the mode of assessment adopted by Respondent,

Page 3

discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection and due process of law. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2026 taxable value of Petitioner's Property from $374,300 to 

$125,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $374,300 to $125,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 27, 2026 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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

JBT Shelby LLC

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

43900 Garfield

Suite 203

City or Town

Clinton Twp.

State

Michigan

ZIP Code

48038

Telephone Number

2487679840

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

afaleslaw@gmail.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Aaron

M.I.

Last Name

Fales

Firm Name (if any)

Law Office of Aaron M Fales, P.C.

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

330 Hamilton Row

Suite 350

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-767-9840

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

afaleslaw@gmail.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

45660 Schoenherr

Shelby Twp.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48315

Taxing Authority (City or Township)

Township Of Shelby (MACOMB) 

County

Macomb

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

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

N/A

 

 

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:

23-07-36-302-006

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:

374300

Current Taxable Value as established by the Board of Review:

374300

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

250000

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

125000

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

125000

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ Aaron Fales

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787051554

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.

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

JBT Shelby LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001528

Township Of Shelby, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: August 14, 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

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 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

JBT SHELBY LLC, 

Petitioner, 

vs. 

SHELBY TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #26- 

Parcel No. 23-07-36-302-006 

 

PETITION 

 

 

JBT SHELBY LLC (“Petitioner”), through its attorneys, Law Office of Aaron M. 

Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 23-07-36-302-006 ("Petitioner's Property"), at 

45660 Schoenherr, Shelby Twp., MI. 

 

2. 

Respondent, Shelby Township assesses and collects property taxes 

on Petitioner's Property. 

 

3. 

 In 2026, Respondent determined the taxable value of Petitioner's 

Property to be $374,300 and assessed Petitioner's Property at $374,300 resulting in 

a state equalized value of the same amount based on the tenative equalization 

factor. 

 

4. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is a commercial property. Petitioner believes that

Page 2

Petitioner's Property was originally designed to be used for commercial 

purposes. 

 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, 

(c) taxable value, and (d) uniformity. 

 

6. 

At this time, Petitioner believes, as it relates to taxable value, that 

there is a dispute relative to the value of a loss. 

 

7. 

The 2026 assessment, including state equalized value and taxable 

value, imposed on Petitioner's Property, and the taxes to be levied and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

 

 

(a) 

The assessment, including state equalized value and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or 

taxable value, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes; 

 

 

(c) 

The assessment, including taxable value and/or state 

equalized value, 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 assessment, including state equalized value and/or 

taxable value, and the mode of assessment adopted by Respondent,

Page 3

discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection and due process of law. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2026 taxable value of Petitioner's Property from $374,300 to 

$125,000, and reducing the 2026 assessed and state equalized values of 

Petitioner's Property from $374,300 to $125,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 27, 2026 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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

JBT Shelby LLC

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

43900 Garfield

Suite 203

City or Town

Clinton Twp.

State

Michigan

ZIP Code

48038

Telephone Number

2487679840

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

afaleslaw@gmail.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Aaron

M.I.

Last Name

Fales

Firm Name (if any)

Law Office of Aaron M Fales, P.C.

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

330 Hamilton Row

Suite 350

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-767-9840

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

afaleslaw@gmail.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

45660 Schoenherr

Shelby Twp.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48315

Taxing Authority (City or Township)

Township Of Shelby (MACOMB) 

County

Macomb

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

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

N/A

 

 

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:

23-07-36-302-006

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:

374300

Current Taxable Value as established by the Board of Review:

374300

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

250000

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

125000

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

125000

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ Aaron Fales

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787051554

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.