Record Finder / 26-001542-TT
Michigan

Keaton Investments LLC Petitioner Vs. City Of Gladwin Respondent

Petitioner
Keaton Investments LLC
Respondent
City Of Gladwin

Case overview

Docket number
26-001542-TT
Status
Answer Due
CaseType
ET Property
Division
ET
County
Gladwin
Judge
No judge assigned

Docket history

Line #SubjectFilerLine RefEnter Date/Post MarkFeeRelated Item
5Response to Order - AnswerNot recordedNot recorded10/16/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
4Proof of service of petition was received.Not recordedNot recorded09/28/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
3Petition has been verifiedPET108/18/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
2Notice of Docket Number ETNot recordedNot recorded08/18/2026Not recordedDownload
1A petition was received.PETNot recorded05/27/2026$600.00Download
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload

Documents

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Page 1

GRETCHEN WHITI\TER

GOVERNOR

Srrr.r or MICHIGAN

DEPARTIVENT OF LICENSING AND REGULATORY AFFAIRS

I\/ICHIGAN OFFICE OF ADI\4INISTRATIVE HEARINGS AND RULES

SUZANNE SONNEBORN

EXECUTIVE DIRECTOR

MARLON I. BROWN, DPA

ACTING DIRECTOR

Keaton lnvestments, LLC

MICHIGAN IAX TRIBUNAL

Petitioner(s)

TMOAHR Docket

26-0A1542

City Of Gladwin

Respondent(s)

PROOF OF SERVICE

Elijah Burkhardt

States that on 1ot16t2026

he/she

[Name of person servingimailing petition]

[date of service]

served a copy of the Answer 

relative to the above-captioned matter upon

[Provide name and address of the party/people being served]

Jason Conti

500 Woodward Avenue, Suite 2700

Detroit, Mlichiga n 48226

lsig nature of person who is servinglmailing copyl

Elijah Burkhardt

[Print/type name of person serving/mailing copy]

M]CHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES

MICHIGAN TAX TRIBUNAL ' 611 W. OTTAWA ST,, LANSING, MI 48933 . 517-335.9760

PO BOX 3A232, LANSING, Ml 48909 ' Other Caniers: 2407 N GRAND RIVER AVE, LANS|NG, Ml 48906

]..&& .

11. l-' 

. ;

'i,'"'i'

{,) 

L

Page 2

STATE OF MICHIGAN 

ENTIRE TAX TRIBUNAL

ANSWER

KEATON INVESTMENTS, LLC, Petitioner

v.

CITY OF GLADWIN, Respondent

MTT Docket No. 26-001542

RESPONDENT’S SEPARATE RESPONSE TO PETITIONER’S NUMBERED ALLEGATIONS

Respondent City of Gladwin responds to the numbered allegations of Petitioner’s Petition for the 2026 

Tax Year as follows:

1. Admit. Respondent admits the allegations set forth in paragraph 1 of the Petition.

2. Admit. Respondent admits the allegations set forth in paragraph 2 of the Petition.

3. Admit. Respondent admits the allegations set forth in paragraph 3 of the Petition.

4. Admit. Respondent admits the allegations set forth in paragraph 4 of the Petition.

5. Admit. Respondent admits the allegations set forth in paragraph 5 of the Petition.

6. Admit. Respondent admits the allegations set forth in paragraph 6 of the petition.

7. Admit. Respondent admits to the law MCL 205.735a(4)(a). However, no petition was filed at 2026 

March Board of Review from the allegations set forth in paragraph 7 of the petition.

8. Deny. Respondent denies paragraph 8 in its entirety, including its introductory allegation and each 

of subparagraphs (a), (b), (c), and (d). Specifically: 

8(a). Deny. Respondent denies that the assessment, state equalized value, or taxable value exceeds

amounts permitted by the Michigan Constitution or applicable statutes.

8(b). Deny. Respondent denies that the assessment, state equalized value, or taxable value

represents a percentage of true cash value higher than legally permissible.

Page 3

8{c}. Deny. Respondent denies that the assessment rests on an erroneous determination of true cash

value or the application of improper valuation principles.

8{d}. Deny. Respondent denies that its assessment practiees discriminate against Petitioner or violate

Petitionefs rights to uniformity, equal protection, or due process.

Response to request for relief. Respondent opposes Petitioner's request to reduce the 2026 taxable

value and state equalized value from $61 't ,600 to $100,000, and opposes the requested refunds,

interest, and cosls. Respondent requests that the Tribunal deny the requested relief.

Respondent / authorized representative:

Signature:

aat , lrl/tf 2 a7 L

Page 4

________________________________________________________________ 

______________________________________________________________ 

______________________________________________________________ 

________________________________________________________________ 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

LANSING 

______________________, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MTT Docket No. _____________ 

______________________, 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX ANSWER 

1. 

___Admit ___Deny. If denied, state the parcel number for the property identified 

on the Entire Tribunal Property Tax Petition for the tax year or years at issue: 

(If more than one parcel is at issue, attach a completed Multiple Parcel Answer 

Form addressing all other parcels at issue.) 

2. 

___Admit ____Deny. If denied, the property identified on the Entire Tribunal 

Property Tax Petition is ___ real ___ personal. 

3. 

___Admit ___Deny. If denied, identify the contiguous and non-contiguous 

parcels by parcel number (attach additional page if necessary): 

4. 

___Admit ___Deny. If denied, identify the parcel or parcels of personal property 

that are not located on a parcel of real property under appeal by parcel number 

(attach additional page if necessary): 

5. 

___Admit ___Deny. 

a. If denied, state when the personal property statements were filed, if at all: 

b. On what date did the March Board of Review commence: 

6. 

___Admit ___Deny. If denied, state the classification of the property identified 

on the Entire Tribunal Property Tax Petition for the tax year or years at issue: 

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 

KEATON INVESTMENTS, LLC

26-001542

City Of Gladwin

Page 5

________________________________________________________________ 

MTT Docket No. ______________ 

Page 2 of 4 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

___Admit ___Deny. If denied, list the separate facts upon which Respondent 

relies in support of the denial (attach additional page if necessary): 

___Admit ___Deny ___Neither Admit Nor Deny. If denied, list the separate 

facts upon which Respondent relies in support of the denial (attach additional 

page if necessary): 

___Admit ___Deny ___Neither Admit Nor Deny. If denied, state the facts upon 

which Respondent relies in support of the denial (attach additional page if 

necessary): 

___Admit ___Deny. If denied, in what County are the property or properties 

located in and what is the address of the property or properties: 

___Admit ___Deny. If denied, what is the applicable local governmental unit:

Page 6

MTT

Page 7

IvITT

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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: 26-001542

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

Party Filing Document 

Respondent

Files

Document Type: Response to Order - Answer

Attachment File Name: answer Final

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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2026-09-28 Keaton-Gladwin proof of service of petition 26-1542.pdfRead complete document text →
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Page 1

4821-7154-3112.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

KEATON INVESTMENTS, LLC, 

 

 

 

MTT Docket No. 26-001542 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

v 

 

CITY OF GLADWIN, 

 

 

 

Respondent. 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

__________________________________________/ 

 

PROOF OF SERVICE 

 

On September 28, 2026, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for the 2026 Tax Year, Notice of Docket Number, and this Proof of Service on: 

County Clerk 

401 West Cedar Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

Equalization Director 

555 West Cedar Avenue 

Suite C 

Gladwin, Michigan 48624 

via U.S. mail

School Board Secretary 

401 N. Bowery Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

via U.S. mail

 

City Clerk 

1000 West Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail 

 

Assessor 

City of Gladwin 

1000 W. Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail

Page 2

2 

4821-7154-3112.1 

 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: /s/ Jason Conti (P55617) 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

Page 3

4821-7154-3112.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

KEATON INVESTMENTS, LLC, 

 

 

 

MTT Docket No. 26-001542 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

v 

 

CITY OF GLADWIN, 

 

 

 

Respondent. 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

__________________________________________/ 

 

PROOF OF SERVICE 

 

On September 28, 2026, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for the 2026 Tax Year, Notice of Docket Number, and this Proof of Service on: 

County Clerk 

401 West Cedar Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

Equalization Director 

555 West Cedar Avenue 

Suite C 

Gladwin, Michigan 48624 

via U.S. mail

School Board Secretary 

401 N. Bowery Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

via U.S. mail

 

City Clerk 

1000 West Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail 

 

Assessor 

City of Gladwin 

1000 W. Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail

Page 4

2 

4821-7154-3112.1 

 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: /s/ Jason Conti (P55617) 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

Page 5

4821-7154-3112.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

KEATON INVESTMENTS, LLC, 

 

 

 

MTT Docket No. 26-001542 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

v 

 

CITY OF GLADWIN, 

 

 

 

Respondent. 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

__________________________________________/ 

 

PROOF OF SERVICE 

 

On September 28, 2026, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for the 2026 Tax Year, Notice of Docket Number, and this Proof of Service on: 

County Clerk 

401 West Cedar Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

Equalization Director 

555 West Cedar Avenue 

Suite C 

Gladwin, Michigan 48624 

via U.S. mail

School Board Secretary 

401 N. Bowery Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

via U.S. mail

 

City Clerk 

1000 West Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail 

 

Assessor 

City of Gladwin 

1000 W. Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail

Page 6

2 

4821-7154-3112.1 

 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: /s/ Jason Conti (P55617) 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

Page 7

4821-7154-3112.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

KEATON INVESTMENTS, LLC, 

 

 

 

MTT Docket No. 26-001542 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

v 

 

CITY OF GLADWIN, 

 

 

 

Respondent. 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

__________________________________________/ 

 

PROOF OF SERVICE 

 

On September 28, 2026, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for the 2026 Tax Year, Notice of Docket Number, and this Proof of Service on: 

County Clerk 

401 West Cedar Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

Equalization Director 

555 West Cedar Avenue 

Suite C 

Gladwin, Michigan 48624 

via U.S. mail

School Board Secretary 

401 N. Bowery Avenue 

Gladwin, Michigan 48624 

 via U.S. mail 

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

via U.S. mail

 

City Clerk 

1000 West Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail 

 

Assessor 

City of Gladwin 

1000 W. Cedar Avenue 

Gladwin, Michigan 48624 

 via Certified Mail

Page 8

2 

4821-7154-3112.1 

 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: /s/ Jason Conti (P55617) 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

Page 9

4821-7154-3112.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

KEATON INVESTMENTS, LLC, 

 

 

 

MTT Docket No. 26-001542

Page 10

2

Page 11

4

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001542

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: 2026-09-28 Keaton-Gladwin proof of service of petition 26-1542

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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2026-05-27 Keaton Investments LLC petition.pdfRead complete document text →
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Page 1

1 

4901-0916-1902.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

KEATON INVESTMENTS, LLC, 

 

 

MTT Docket No. ___________ 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

 

 

 

 

v 

 

CITY OF GLADWIN, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2026 TAX YEAR 

 

 

KEATON INVESTMENTS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, files this 

Petition For The 2026 Tax Year, and states: 

 

1. 

Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, 

Michigan, 48075. Petitioner is a party in interest with respect to property taxes on real property tax parcel 

no. 170-060-001-003-10 (the “Subject Property”), also known as 120 E Cedar Avenue, Galdwin, Michigan. 

 

2. 

Respondent City of Gladwin (“Respondent”) assesses and collects property taxes on the 

Subject Property. 

 

3. 

In 2026, Respondent determined the taxable value of the Subject Property to be $611,600, 

and the assessed value of the Subject Property to be $611,600, which will result in a state equalized value 

in the same amount based upon the tentative equalization factor. 

 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject 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.

Page 2

2 

4901-0916-1902.1 

 

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. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March, 2026. 

 

8. 

The 2026 assessment, including state equalized value and taxable value, imposed on the 

Subject 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 the Subject 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 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 the Subject Property from $611,600 to $100,000, and reducing the 2026 state equalized value of 

the Subject Property from $611,600 to $100,000, and requiring Respondent to pay Petitioner the refunds 

attributable to such reductions, plus interest and costs.

Page 3

3 

4901-0916-1902.1 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 27, 2026

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EntireTribunalCaseISPetition.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

Keaton Investments, LLC

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

24500 Northwestern Hwy.

Suite 100

City or Town

Southfield

State

Michigan

ZIP Code

48075

Telephone Number

3132347177

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

jconti@foley.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

Last Name

Conti

Firm Name (if any)

Foley & Lardner LLP

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

500 Woodward Avenue

Suite 2700

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3132347177

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

jconti@foley.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]

120 E Cedar Avenue

Gladwin

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48624

Taxing Authority (City or Township)

City Of Gladwin (GLADWIN) 

County

Gladwin

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:

170-060-001-003-10

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:

611600

Current Taxable Value as established by the Board of Review:

611600

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

200000

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

100000

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

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/ /S/ JASON CONTI

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787070355

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-08-18_06-15-10.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Keaton Investments LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001542

City Of Gladwin, 

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 18, 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

Page 2

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

Keaton Investments LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001542

City Of Gladwin, 

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 18, 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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2026-05-27 Keaton Investments LLC petition.pdfRead complete document text →
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Page 1

1 

4901-0916-1902.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

KEATON INVESTMENTS, LLC, 

 

 

MTT Docket No. ___________ 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

 

 

 

 

v 

 

CITY OF GLADWIN, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2026 TAX YEAR 

 

 

KEATON INVESTMENTS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, files this 

Petition For The 2026 Tax Year, and states: 

 

1. 

Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, 

Michigan, 48075. Petitioner is a party in interest with respect to property taxes on real property tax parcel 

no. 170-060-001-003-10 (the “Subject Property”), also known as 120 E Cedar Avenue, Galdwin, Michigan. 

 

2. 

Respondent City of Gladwin (“Respondent”) assesses and collects property taxes on the 

Subject Property. 

 

3. 

In 2026, Respondent determined the taxable value of the Subject Property to be $611,600, 

and the assessed value of the Subject Property to be $611,600, which will result in a state equalized value 

in the same amount based upon the tentative equalization factor. 

 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject 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.

Page 2

2 

4901-0916-1902.1 

 

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. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March, 2026. 

 

8. 

The 2026 assessment, including state equalized value and taxable value, imposed on the 

Subject 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 the Subject 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 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 the Subject Property from $611,600 to $100,000, and reducing the 2026 state equalized value of 

the Subject Property from $611,600 to $100,000, and requiring Respondent to pay Petitioner the refunds 

attributable to such reductions, plus interest and costs.

Page 3

3 

4901-0916-1902.1 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 27, 2026

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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

Keaton Investments, LLC

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

24500 Northwestern Hwy.

Suite 100

City or Town

Southfield

State

Michigan

ZIP Code

48075

Telephone Number

3132347177

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

jconti@foley.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

Last Name

Conti

Firm Name (if any)

Foley & Lardner LLP

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

500 Woodward Avenue

Suite 2700

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3132347177

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

jconti@foley.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]

120 E Cedar Avenue

Gladwin

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48624

Taxing Authority (City or Township)

City Of Gladwin (GLADWIN) 

County

Gladwin

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:

170-060-001-003-10

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:

611600

Current Taxable Value as established by the Board of Review:

611600

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

200000

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

100000

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

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/ /S/ JASON CONTI

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787070355

Supporting Waiver Documents:

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