Kent Group 3302 Petitioner Vs. City Of Flint 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 SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

Kent Group 3302,

Petitioner,

v

 

 

City Of Flint,

Respondent.

 MTT Docket No. 26-000755

Please be advised that 26-000755 has been placed on a two-week Prehearing General 

Call commencing September 16, 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covered by the order will not be published.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. 26-000755

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 May 20, 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 May 20, 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

Page 3

MTT

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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

Kent Group 3302, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000755

City Of Flint,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has considered the file in this case and finds that Respondent was held in 

default on August 7, 2026, and the default has been timely cured. The documents 

curing the default can be reviewed through the docket search function on the Tribunal’s 

website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the 

document link next to the line item entry for the documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By: /s/ Patricia L. Halm

Entered: October 5, 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

Kent Group 3302, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000755

City Of Flint,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has considered the file in this case and finds that Respondent was held in 

default on August 7, 2026, and the default has been timely cured. The documents 

curing the default can be reviewed through the docket search function on the Tribunal’s 

website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the 

document link next to the line item entry for the documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By: /s/ Patricia L. Halm

Entered: October 5, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT Of LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

KENT GROUP3302, LLC 

 

 

 

 

Docket No. 26-000755 

 

 

Petitioner 

 

 

 

 

Parcel Nos. 41-16-351-052 

v. 

 

City of Flint 

 

 

Respondent 

 

Brian E. Etzel (P54905) 

 

 

 

 

Aneerah R. Ali (P61086) 

Attorney for the Petitioner 

 

 

 

 

Assistant City Attorney 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

City of Flint Law Department 

& PLUNKETT, P.C. 

 

 

 

 

 

1101 S. Saginaw Street, 3rd Floor 

Attorneys for the Petitioner 

 

 

 

Flint, Michigan 48502 

380 N. Old Woodward Avenue, Suite 300 

 

810-237-2091 

Birmingham, MI 48009 

 

 

 

 

aali@cityofflint.com 

248-642-0333 

bee@wwrplaw.com 

____________________________________________________________________________________ 

 

PROOF OF SERVICE 

I hereby certify that on August 11th, 2026, I served a true and correct copy of Respondent's 

Answer upon Petitioner's counsel by electronic email on August 11, 2026 at 

bee@wwrplaw.com. 

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

belief. 

Dated: _____________________ 

 

8/11/2026

Page 2

Respectfully submitted, 

CITY OF FLINT LAW DEPARTMENT 

By: ____________________________________ 

Aneerah Ali (P______) 

Assistant City Attorney 

1101 S. Saginaw Street 

Flint, Michigan 48502 

Attorney for Respondent 

 

 

61086

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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: 26-000755

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

Party Filing Document 

Respondent

Files

Document Type: Proof of Service: Misc Documents

Attachment File Name: Kent - Proof of Service

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 

KENT GROUP3302, LLC 

Docket No. 26-000755 

Petitioner 

Parcel Nos. 41-16-351-052 

v. 

City of Flint 

Respondent 

Brian E. Etzel (P54905) 

Aneerah R. Ali (P61086) 

Attorney for the Petitioner 

 

Assistant City Attorney 

WILLIAMS, WILLIAMS, RATTNER 

 

City of Flint Law Department 

& PLUNKETT, P.C. 

 

1101 S. Saginaw Street, 3rd Floor 

Attorneys for the Petitioner 

Flint, Michigan 48502 

380 N. Old Woodward Avenue, Suite 300 

810-237-2091

Birmingham, MI 48009 

aali@cityofflint.com

248-642-0333

bee@wwrplaw.com

____________________________________________________________________________________

RESPONDENT'S ANSWER 

Answer to the Entire Tribunal Property Tax Petition 

1. Admit.

2. Admit.

3. Admit.

4. Admit.

5. Admit.

6. Deny. For the tax year 2026, Respondent classified the subject property as industrial

property.

Page 2

7. Admit.

8. Deny.

9. Admit.

10. Admit.

11. Deny

12. Deny.

RESERVATION OF RIGHTS 

Respondent reserves the right to amend or supplement this Answer and to assert any additional 

defenses that may become available through further investigation, discovery, or otherwise as 

permitted by the Michigan Tax Tribunal Rules. 

WHEREFORE, Respondent, City of Flint, respectfully requests that the Tribunal deny the relief 

requested by Petitioner, grant Respondent such other and further relief as the Tribunal deems just 

and appropriate. 

Respectfully submitted, 

CITY OF FLINT LAW DEPARTMENT 

By: __________________________________ 

 Aneerah Ali (P61086) 

 Assistant City Attorney City of Flint 

 Department of Law 

 1101 S. Saginaw Street Flint, Michigan 48502 

(810) 237-2091

aali@cityofflint.com

08/11/2026 

Attorney for Respondent

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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: 26-000755

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: Kent Group

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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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

Kent Group 3302,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000755

City Of Flint,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.1 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: August 7, 2026

1 “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5).

Page 2

MTT Docket No. 26-000755

Page 2 of 2

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 3

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

Kent Group 3302,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000755

City Of Flint,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this

Page 4

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

KENT GROUP 3302, LLC, 

Petitioner, 

v. 

CITY OF FLINT, 

Respondent. 

Docket No. 26-000755 

Parcel No. 41-16-351-052 

Brian E. Etzel (P54905) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

PROOF OF SERVICE OF PETITION, AMENDED PETITION 

AND NOTICE OF DOCKET NUMBER

Page 2

PROOF OF SERVICE OF PETITION, AMENDED PETITION 

AND NOTICE OF DOCKET NUMBER 

Sarah Conner states that she served copies of the Entire Tribunal Property Tax Petition, 

Amended Petition, Notice of Docket Number and this Proof of Service, on the persons listed below, 

by placing copies of those documents in a duly stamped, addressed envelope and placing the envelope 

in the United States mail on June 16, 2026. 

PERSONS SERVED: 

VIA CERTIFIED MAIL 

VIA FIRST CLASS US MAIL 

City of Flint 

Genessee County Clerk 

Flint City School District 

Office of the Assessor 

County Clerk's Office 

Secretary of the School Board 

1101 S. Saginaw Street 

324 S. Saginaw St. 

923 E. Kearsley Street 

Flint, Michigan 48502 

Flint, MI 48502 

Flint, Michigan 48503 

City of Flint 

Genessee County 

State Treasurer 

Office of the City Clerk 

Director of Equalization 

Michigan Department of Treasury 

1101 S. Saginaw Street 

324 S. Saginaw St. 

Austin Building 

Flint, Michigan 48502 

Flint, MI 48502 

430 W. Allegan 

Lansing, MI 

48922 

{ il 

/ 

Sol 

/ omen 

~~" Sarah Conner

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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: 26-000755

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: Proof of Service-Petition-Amended Petition-Noticeof Docket Number

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 ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

KENT GROUP 3302, LLC, 

 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel No. 41-16-351-052 

Petitioner, 

 

 

 

 

 

 

 

 

 

 

v. 

 

CITY OF FLINT, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

Petitioner Kent Group 3302, 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 Kent Group 3302, LLC is a Michigan limited liability company whose 

address is 10355 Capital Street, Oak Park, MI 48237. 

2. 

Respondent City of Flint is a Michigan municipal corporation with its primary 

offices located at 1101 S. Saginaw Street, Flint, MI 48502.

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 41-16-351-052 and commonly 

known as 3302 Kent Street, Flint, MI 48503 (the “Subject Property”). 

4. 

The Subject Property is located in Genesee County and is within the Flint City 

school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as residential 

improved property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s assessment 

for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,918,000 

 1,459,000 

 1,459,000 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for the 2026 

tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,000,000 

 1,000,000 

 1,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 918,000 

 459,000 

 459,000 

 

10. 

This Petition presents issues involving the Subject Property’s valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),

Page 3

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the 

GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based 

on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment is not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth 

in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under 

Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 6, 2026 

 

 

Attorneys for Petitioner

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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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

KENT GROUP 3302

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

10355 Capital Street

City or Town

Oak Park

State

Michigan

ZIP Code

48237

Telephone Number

248-642-0333

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

beetzel@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

E

Last Name

Etzel

Firm Name (if any)

Williams Williams Rattner & Plunkett PC

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

380 N. Old Woodward Ave., Ste. 300

City or Town

Birmingham

State

22

ZIP Code

48009

Telephone Number

2486420333

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

BEEtzel@wwrplaw.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]

3302 Kent Street

Flint

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

48503

Taxing Authority (City or Township)

City Of Flint (GENESEE) 

County

Genesee

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:

41-16-351-052

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:

1459000

Current Taxable Value as established by the Board of Review:

1459000

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

2000000

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

1000000

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

1000000

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

ORLENE HAWKS

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/ Brian E. Etzel

Payment Information

Amount:

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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

Kent Group 3302, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000755

City Of Flint, 

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 8, 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

Brian E Etzel

Williams Williams Rattner & Plunkett PC

380 N. Old Woodward Ave., Ste. 300

Birmingham , MI 48009

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

KENT GROUP 3302, LLC, 

 

 

 

Docket No. 26-000755 

 

 

 

 

 

 

 

 

Parcel No. 41-16-351-052 

Petitioner, 

 

 

 

 

 

 

 

 

 

 

v. 

 

CITY OF FLINT, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AMENDED ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

Petitioner Kent Group 3302, LLC, by and through its attorneys, Williams, Williams, 

Rattner & Plunkett, PC, states as follows for its Amended Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner Kent Group 3302, LLC is a Michigan limited liability company whose 

address is 10355 Capital Street, Oak Park, MI 48237. 

2. 

Respondent City of Flint is a Michigan municipal corporation with its primary 

offices located at 1101 S. Saginaw Street, Flint, MI 48502.

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 41-16-351-052 and commonly 

known as 3302 Kent Street, Flint, MI 48503 (the “Subject Property”). 

4. 

The Subject Property is located in Genesee County and is within the Flint City 

school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as commercial 

improved property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s assessment 

for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,918,000 

 1,459,000 

 1,459,000 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for the 2026 

tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,000,000 

 1,000,000 

 1,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 918,000 

 459,000 

 459,000 

 

10. 

This Petition presents issues involving the Subject Property’s valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),

Page 3

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the 

GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based 

on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment is not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth 

in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under 

Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 7, 2026 

 

 

Attorneys for Petitioner

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Page 1

1 of 1

Docket #: 26-000755

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

KENT GROUP 3302, LLC, 

 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel No. 41-16-351-052 

Petitioner, 

 

 

 

 

 

 

 

 

 

 

v. 

 

CITY OF FLINT, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

Petitioner Kent Group 3302, 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 Kent Group 3302, LLC is a Michigan limited liability company whose 

address is 10355 Capital Street, Oak Park, MI 48237. 

2. 

Respondent City of Flint is a Michigan municipal corporation with its primary 

offices located at 1101 S. Saginaw Street, Flint, MI 48502.

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 41-16-351-052 and commonly 

known as 3302 Kent Street, Flint, MI 48503 (the “Subject Property”). 

4. 

The Subject Property is located in Genesee County and is within the Flint City 

school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as residential 

improved property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s assessment 

for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,918,000 

 1,459,000 

 1,459,000 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for the 2026 

tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,000,000 

 1,000,000 

 1,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 918,000 

 459,000 

 459,000 

 

10. 

This Petition presents issues involving the Subject Property’s valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),

Page 3

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the 

GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based 

on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment is not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth 

in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under 

Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 6, 2026 

 

 

Attorneys for Petitioner

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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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

KENT GROUP 3302

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

10355 Capital Street

City or Town

Oak Park

State

Michigan

ZIP Code

48237

Telephone Number

248-642-0333

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

beetzel@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

E

Last Name

Etzel

Firm Name (if any)

Williams Williams Rattner & Plunkett PC

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

380 N. Old Woodward Ave., Ste. 300

City or Town

Birmingham

State

22

ZIP Code

48009

Telephone Number

2486420333

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

BEEtzel@wwrplaw.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]

3302 Kent Street

Flint

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

48503

Taxing Authority (City or Township)

City Of Flint (GENESEE) 

County

Genesee

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:

41-16-351-052

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:

1459000

Current Taxable Value as established by the Board of Review:

1459000

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

2000000

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

1000000

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

1000000

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

ORLENE HAWKS

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/ Brian E. Etzel

Payment Information

Amount:

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