Magnum Equities, LLC, Petitioner Vs. City Of Saginaw, Respondent
- Petitioner
- Magnum Equities, LLC
- Respondent
- City Of Saginaw
Case overview
- Docket number
- 25-001727-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Saginaw
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 14 | Consent Judgment | Not recorded | Not recorded | 03/12/2026 | Not recorded | Download |
| 13 | Granted | PET | 12 | 03/12/2026 | Not recorded | Download |
| 12 | A Stipulation has been received. | PET | Not recorded | 03/11/2026 | $50.00 | Download |
| 11 | Prehearing General Call | Not recorded | Not recorded | 12/01/2025 | Not recorded | Download |
| 10 | Attachments to the Answer were filed | PET | Not recorded | 09/04/2025 | Not recorded | Download |
| 9 | Answer was received | Not recorded | Not recorded | 09/03/2025 | Not recorded | Download |
| 8 | ET Case Info Sheet | Not recorded | Not recorded | 09/03/2025 | Not recorded | Download |
| 7 | Answer was received | Not recorded | Not recorded | 09/03/2025 | Not recorded | Download |
| 6 | ET Case Info Sheet | Not recorded | Not recorded | 09/03/2025 | Not recorded | Download |
| 5 | Proof of service of petition was received. | PET | Not recorded | 08/26/2025 | Not recorded | Download |
| 4 | Petition has been verified | PET | 2 | 07/22/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 07/22/2025 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 05/29/2025 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 05/29/2025 | $425.00 | Download |
Documents
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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 Magnum Equities LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001727 City of Saginaw, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT The Tribunal has reviewed the Stipulation and finds that it comports with the mandates of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all attachments, terms, and conditions is GRANTED and ADOPTED, unless otherwise indicated. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax years at issue shall correct or cause the assessment rolls to be corrected to reflect the property’s true cash and taxable values as provided in this Consent Judgment within 20 days of the entry of the Consent Judgment.2 IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund as required by the Consent Judgment within 28 days of the entry of the Consent Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a proportionate share of any property tax administration fees paid and of penalty and interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless otherwise indicated, bear interest from the date of payment to the date of judgment and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, 1 See MCL 211.27a. 2 See MCL 205.755.
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MTT Docket No. 25-001727 Page 2 of 2 through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, (viii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, and (ix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. This Consent Judgment resolves all pending claims in this matter and closes this case. See docket look up for a copy of stipulation and for any possible refund paragraph. By _____________________________ Entered: March 12, 2026 jc 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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1 4926-1822-5557.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, LLC, Petitioner, MTT Docket No. 25-001727 v. CITY OF SAGINAW, Respondent. _____________________________________________/ STIPULATION FOR ENTRY OF CONSENT JUDGMENT 1. The case is pending in the X Entire Tribunal OR __ Small Claims Division. 2. Property Parcel Nos: 21-4453-00000 and 21-2612-00200 3. The values for the properties identified above as established by Respondent’s Board of Review for the tax year at issue are: Year Parcel No. True Cash Value Assessed Value Taxable Value 2025 21-4453-00000 $510,000 $255,000 $218,923 2025 21-2612-00200 $38,600 $19,300 $19,300 4. The values for the properties identified above as stipulated by the parties for settlement purposes for the tax year at issue are: Year Parcel No. True Cash Value Assessed Value Taxable Value 2025 21-4453-00000 $177,600 $88,800 $88,800 2025 21-2612-00200 $29,000 $14,500 $14,500 5. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years: NA 6. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc.:
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2 4926-1822-5557.1 IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable jointly to Petitioner named herein and its counsel, Foley & Lardner LLP, and sent in care of such counsel. Calculations of the refund amount shall also be sent to Petitioner’s counsel at the same address. FOLEY & LARDNER LLP CITY OF SAGINAW Attorneys Petitioner Attorney for Respondent By: /s/ Jason Conti By: /s/ Amy L. Lusk (with permission Jason Conti (P55617) Amy L. Lusk (P63702) 500 Woodward Avenue, Suite 2700 1315 S. Washington Avenue Detroit, Michigan 48226 Saginaw, Michigan 48601 (313) 234-7177 (989) 759-1404 Dated: March 9, 2026 Dated: March 9, 2026
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1 4926-1822-5557.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, LLC, Petitioner, MTT Docket No. 25-001727 v. CITY OF SAGINAW, Respondent. _____________________________________________/ STIPULATION FOR ENTRY OF CONSENT JUDGMENT 1. The case is pending in the X Entire Tribunal OR __ Small Claims Division. 2. Property Parcel Nos: 21-4453-00000 and 21-2612-00200 3. The values for the properties identified above as established by Respondent’s Board of Review for the tax year at issue are: Year Parcel No. True Cash Value Assessed Value Taxable Value 2025 21-4453-00000 $510,000 $255,000 $218,923 2025 21-2612-00200 $38,600 $19,300 $19,300 4. The values for the properties identified above as stipulated by the parties for settlement purposes for the tax year at issue are: Year Parcel No. True Cash Value Assessed Value Taxable Value 2025 21-4453-00000 $177,600 $88,800 $88,800 2025 21-2612-00200 $29,000 $14,500 $14,500 5. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years: NA 6. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc.:
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2 4926-1822-5557.1 IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable jointly to Petitioner named herein and its counsel, Foley & Lardner LLP, and sent in care of such counsel. Calculations of the refund amount shall also be sent to Petitioner’s counsel at the same address. FOLEY & LARDNER LLP CITY OF SAGINAW Attorneys Petitioner Attorney for Respondent By: /s/ Jason Conti By: /s/ Amy L. Lusk (with permission Jason Conti (P55617) Amy L. Lusk (P63702) 500 Woodward Avenue, Suite 2700 1315 S. Washington Avenue Detroit, Michigan 48226 Saginaw, Michigan 48601 (313) 234-7177 (989) 759-1404 Dated: March 9, 2026 Dated: March 9, 2026
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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 NOVEMBER 2 - 13, 2026 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Magnum Equities, LLC, Petitioner, v City Of Saginaw, Respondent. MTT Docket No. 25-001727 Please be advised that 25-001727 has been placed on a two-week Prehearing General Call commencing November 02, 2026. 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.
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MTT Docket No. 25-001727 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 July 6, 2026. 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 July 6, 2026. Witnesses, with the exception of rebuttal witnesses, will not be allowed to testify unless disclosed in the Prehearing Statement and the Prehearing Statement is furnished in accordance with this order except upon a finding of good cause by the Tribunal. Failure to file the Prehearing Statement may result in holding a party or parties in default. See TTR 237. IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on July 6, 2026, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. Discovery relative to the valuation disclosure prepared for purposes of litigating this case or the valuation expert that prepared that valuation disclosure is not permitted during
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MTT
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STA
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STATE OF MICHIGAN RECET =D SEPLT 3 MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, Petitioner, V. CITY OF SAGINAW, a Michigan municipal corporation Respondent. MTT DOCKET NO: 25-001727 Foley & Lardner LLP By: Jason Conti (P55617) Attorney for Petitioner 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7177 jconti@foley.com City of Saginaw By: Amy L. Lusk (P63702), City Attorney Attorney for Respondent 1315 S. Washington Avenue Saginaw, Michigan 48601 (989) 759-1404 alusk@saginaw-mi.com RESPONDENT'S ANSWER TO PETITION Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, answers Petitioner's Petition and says as follows: 1. In response to the allegations of Paragraph 1, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 2. In response to the allegations of Paragraph 2, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 3. In response to the allegations of Paragraph 3, Respondent DENIES in the manner andform stated and forthereason same are untrue. Petitionerdetermined the taxable and assessed values of the Subject Property to be significantly less than portrayed by
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4. In response to the allegations of Paragraph 4, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner fo its proofs. 5. In response to the allegations of Paragraph 5, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 6. In response to the allegations of Paragraph 6, Respondent DENIES in the manner and for stated and for the reason same are untrue. Respondentasserts there is no actionable dispute at issue. 7. In response to the allegations of Paragraph 7, Respondent DENIES in the manner and form stated and for the reason same are untrue. Neither Petitioner, northe prior owner of the Subject Property, timely filed an appeal of the tax assessment with the local Board of Review. Petitioner did not even acquire ownership of the Subject Property until June 18, 2025, and lacks standing to bring this action. 8. In response to the allegations of Paragraph 8, Respondent DENIES in the manner and form stated and for the reason same are untrue. a. In response to the allegations of Paragraph 8a, Respondent DENIES in the manner and form stated and for the reason same are untrue. b. In response fo the allegations of Paragraph 8b, Respondent DENIES in the manner and form stated and for the reason same are untrue. c. In response fo the allegations of Paragraph 8c, Respondent DENIES in the manner and form stated and for the reason same are untrue. d. In response to the allegations of Paragraph 8d, Respondent DENIES in the manner and form stated and for the reason same are untrue. Wherefore, Respondentrequests that the Tax Tribunal deny Petitioner's request for relief. Respectfully submitted, Dated: September 3, 2025 By: Is] Amy, £. funk, Amy L. Lusk (P63702), City Attorney City of Saginaw Attorney for Respondent 1315 8. Washington Avenue Saginaw, Michigan 48601
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RESPONDENT'S AFFIRMATIVE DEFENSES Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, hereby asserts the following as Affirmative Defenses: 1. Petitioner failed to exhaust its administrative remedies. 2. Petitioner failed to state a claim against Respondent upon which relief could be granted. 3. The Tribunal lacks subject matter jurisdiction over the case. 4. The Tribunal lacks personal jurisdiction over the parties. 5. Petitioner has failed to file this case in the proper venue. 6. Pelitioner has failed to mitigate its alleged damages. 7. Respondent was not properly served. 8. Petitioner's claims are barred, in whole or in part, by waiver, estoppel, laches, and/or unclean hands. 9. Respondent is entitled to governmental immunity. 10. Petitioner's claims are barred, in whole or in part, by the applicable statute of limitations. 11. Petitioner's claims are barred, in whole or in part, because they are moot. 12. Petitioner lacks standing to appeal the tax assessment. 13.Respondentreserves the right to alter, amend, add, modify, or delete any or all of its
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STATE OF
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C
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, Petitioner, MTT DOCKET NO: 25-001727 V. CITY OF SAGINAW, a Michigan municipal corporation Respondent. Foley & Lardner LLP City of Saginaw By: Jason Conti (P55617) By: Amy L. Lusk (P63702), City Attorney Attorney for Petitioner Attorney for Respondent 500 Woodward Avenue, Suite 2700 1315 S. Washington Avenue Detroit, Michigan 48226 Saginaw, Michigan 48601 (313) 234-7177 (989) 759-1404 jconti@foley.com alusk@saginaw-mi.com RESPONDENT’S ANSWER TO PETITION Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, answers Petitioner’s Petition and says as follows: 1. In response to the allegations of Paragraph 1, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 2. In response to the allegations of Paragraph 2, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 3. In response to the allegations of Paragraph 3, Respondent DENIES in the manner and form stated and for the reason same are untrue. Petitioner determined the taxable and assessed values of the Subject Property to be significantly less than portrayed by Petitioner and are as follows: Parcel No. Assessed Value Taxable Value 21-4453-00000 $255,000 $218,923 21-2612-00200 $19,300 $19,300
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4. In response to the allegations of Paragraph 4, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 5. In response to the allegations of Paragraph 5, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 6. In response to the allegations of Paragraph 6, Respondent DENIES in the manner and for stated and for the reason same are untrue. Respondent asserts there is no actionable dispute at issue. 7. In response to the allegations of Paragraph 7, Respondent DENIES in the manner and form stated and for the reason same are untrue. Neither Petitioner, nor the prior owner of the Subject Property, timely filed an appeal of the tax assessment with the local Board of Review. Petitioner did not even acquire ownership of the Subject Property until June 18, 2025, and lacks standing to bring this action. 8. In response to the allegations of Paragraph 8, Respondent DENIES in the manner and form stated and for the reason same are untrue. a. In response to the allegations of Paragraph 8a, Respondent DENIES in the manner and form stated and for the reason same are untrue. b. In response to the allegations of Paragraph 8b, Respondent DENIES in the manner and form stated and for the reason same are untrue. c. In response to the allegations of Paragraph 8c, Respondent DENIES in the manner and form stated and for the reason same are untrue. d. In response to the allegations of Paragraph 8d, Respondent DENIES in the manner and form stated and for the reason same are untrue. Wherefore, Respondent requests that the Tax Tribunal deny Petitioner’s request for relief. Respectfully submitted, Dated: September 3, 2025 By: /s/ Amy L. Lusk Amy L. Lusk (P63702), City Attorney City of Saginaw Attorney for Respondent 1315 S. Washington Avenue Saginaw, Michigan 48601
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RESPONDENT’S AFFIRMATIVE DEFENSES Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, hereby asserts the following as Affirmative Defenses: 1. Petitioner failed to exhaust its administrative remedies. 2. Petitioner failed to state a claim against Respondent upon which relief could be granted. 3. The Tribunal lacks subject matter jurisdiction over the case. 4. The Tribunal lacks personal jurisdiction over the parties. 5. Petitioner has failed to file this case in the proper venue. 6. Petitioner has failed to mitigate its alleged damages. 7. Respondent was not properly served. 8. Petitioner’s claims are barred, in whole or in part, by waiver, estoppel, laches, and/or unclean hands. 9. Respondent is entitled to governmental immunity. 10. Petitioner’s claims are barred, in whole or in part, by the
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STATE OF
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Entire Tribunal Case Information Sheet - Respondent MOAHR DOCKET NO. 25-001727 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government City Of Saginaw (SAGINAW) Local Unit of Government/First Name Amy M.I. Last Name Lusk Home Address (No., Street, P.O. Box or Rural Route) City of Saginaw City or Town Saginaw State Michigan ZIP Code 48601 Telephone Number 989-759-1404 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) alusk@saginaw-mi.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Amy M.I. L. Last Name Lusk Firm Name (if any) City of Saginaw Address (No., Street, P.O. Box or Rural Route) 1315 S. Washington Avenue City or Town Saginaw State Michigan ZIP Code 48601 Telephone Number 9897591404 Fax Number 9897591607 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) alusk@saginaw-mi.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Amy L. Lusk /s/
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, Petitioner, MTT DOCKET NO: 25-001727 V. CITY OF SAGINAW, a Michigan municipal corporation Respondent. Foley & Lardner LLP City of Saginaw By: Jason Conti (P55617) By: Amy L. Lusk (P63702), City Attorney Attorney for Petitioner Attorney for Respondent 500 Woodward Avenue, Suite 2700 1315 S. Washington Avenue Detroit, Michigan 48226 Saginaw, Michigan 48601 (313) 234-7177 (989) 759-1404 jconti@foley.com alusk@saginaw-mi.com RESPONDENT’S ANSWER TO PETITION Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, answers Petitioner’s Petition and says as follows: 1. In response to the allegations of Paragraph 1, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 2. In response to the allegations of Paragraph 2, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 3. In response to the allegations of Paragraph 3, Respondent DENIES in the manner and form stated and for the reason same are untrue. Petitioner determined the taxable and assessed values of the Subject Property to be significantly less than portrayed by Petitioner and are as follows: Parcel No. Assessed Value Taxable Value 21-4453-00000 $255,000 $218,923 21-2612-00200 $19,300 $19,300
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4. In response to the allegations of Paragraph 4, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 5. In response to the allegations of Paragraph 5, Respondent NEITHER ADMITS NOR DENIES and leaves Petitioner to its proofs. 6. In response to the allegations of Paragraph 6, Respondent DENIES in the manner and for stated and for the reason same are untrue. Respondent asserts there is no actionable dispute at issue. 7. In response to the allegations of Paragraph 7, Respondent DENIES in the manner and form stated and for the reason same are untrue. Neither Petitioner, nor the prior owner of the Subject Property, timely filed an appeal of the tax assessment with the local Board of Review. Petitioner did not even acquire ownership of the Subject Property until June 18, 2025, and lacks standing to bring this action. 8. In response to the allegations of Paragraph 8, Respondent DENIES in the manner and form stated and for the reason same are untrue. a. In response to the allegations of Paragraph 8a, Respondent DENIES in the manner and form stated and for the reason same are untrue. b. In response to the allegations of Paragraph 8b, Respondent DENIES in the manner and form stated and for the reason same are untrue. c. In response to the allegations of Paragraph 8c, Respondent DENIES in the manner and form stated and for the reason same are untrue. d. In response to the allegations of Paragraph 8d, Respondent DENIES in the manner and form stated and for the reason same are untrue. Wherefore, Respondent requests that the Tax Tribunal deny Petitioner’s request for relief. Respectfully submitted, Dated: September 3, 2025 By: /s/ Amy L. Lusk Amy L. Lusk (P63702), City Attorney City of Saginaw Attorney for Respondent 1315 S. Washington Avenue Saginaw, Michigan 48601
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RESPONDENT’S AFFIRMATIVE DEFENSES Respondent, City of Saginaw, by and through its attorney, Amy L. Lusk, hereby asserts the following as Affirmative Defenses: 1. Petitioner failed to exhaust its administrative remedies. 2. Petitioner failed to state a claim against Respondent upon which relief could be granted. 3. The Tribunal lacks subject matter jurisdiction over the case. 4. The Tribunal lacks personal jurisdiction over the parties. 5. Petitioner has failed to file this case in the proper venue. 6. Petitioner has failed to mitigate its alleged damages. 7. Respondent was not properly served. 8. Petitioner’s claims are barred, in whole or in part, by waiver, estoppel, laches, and/or unclean hands. 9. Respondent is entitled to governmental immunity. 10. Petitioner’s claims are barred, in whole or in part, by the
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STATE OF
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Entire Tribunal Case Information Sheet - Respondent MOAHR DOCKET NO. 25-001727 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government City Of Saginaw (SAGINAW) Local Unit of Government/First Name Amy M.I. Last Name Lusk Home Address (No., Street, P.O. Box or Rural Route) City of Saginaw City or Town Saginaw State Michigan ZIP Code 48601 Telephone Number 989-759-1404 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) alusk@saginaw-mi.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Amy M.I. L. Last Name Lusk Firm Name (if any) City of Saginaw Address (No., Street, P.O. Box or Rural Route) 1315 S. Washington Avenue City or Town Saginaw State Michigan ZIP Code 48601 Telephone Number 9897591404 Fax Number 9897591607 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) alusk@saginaw-mi.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Amy L. Lusk /s/
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4827-3213-0670.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, LLC, MTT Docket No. 25-001727 Parcel Nos. 21-4453-00000 Petitioner, 21-2612-00200 v CITY OF SAGINAW, 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 August 25, 2025, I caused to be served, via the methods listed below, a copy of Petitioner’s Petition for 2025 Tax Year, Notice of Docket Number, and this Proof of Service on: Saginaw County Clerk 111 S. Michigan Avenue Saginaw, Michigan 48602 via U.S. mail Saginaw County Equalization Director 111 S. Michigan Avenue Saginaw, Michigan 48602 via U.S. mail Saginaw Public Schools Secretary 550 Millard Street Saginaw, Michigan 48607 via U.S. mail State Treasurer Michigan Dep’t of Treasury Treasury Building 430 W. Allegan Street Lansing, Michigan 48922 via U.S. mail Saginaw City Clerk 1315 S. Washington Avenue Saginaw, Michigan 48601 via Certified Mail City of Saginaw Assessor 1315 South Washington Ave. Saginaw, Michigan 48601 via Certified Mail
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2 4827-3213-0670.1 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
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1 4898-6618-0422.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, LLC, MTT Docket No. _____________ Parcel Nos. 21-4453-00000 Petitioner, 21-2612-00200 V CITY OF SAGINAW, Respondent. ________________________________________/ PETITION FOR THE 2025 TAX YEAR MAGNUM EQUITIES, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, 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 contiguous real property tax parcel nos. 21-4453-00000 and 21-2612-00200 (collectively, the “Subject Property”), also known as 3405-19 E Genesee, Saginaw, Michigan. 2. Respondent City of Saginaw (“Respondent”) assesses and collects property taxes on the Subject Property. 3. In 2025, Respondent determined the taxable and assessed values of the Subject Property to be as follows (which will result in a state equalized value in the same amount based upon the tentative equalization factor): Parcel No. AV TV 21-4453-00000 $300,000 $300,000 21-2612-00200 $30,000 $30,000
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2 4898-6618-0422.1 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. 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, 2025. 8. The 2025 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.
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3 4898-6618-0422.1 WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2024 taxable values and state equalized values of the Subject Property as follows: Parcel No. AV TV 21-4453-00000 $100,000 $100,000 21-2612-00200 $5,000 $5,000 and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. 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 29, 2025
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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 Magnum Equities, LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-001727 City Of Saginaw, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: __Tribunal Clerk________ Entered: July 22, 2025 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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1 4898-6618-0422.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL MAGNUM EQUITIES, LLC, MTT Docket No. _____________ Parcel Nos. 21-4453-00000 Petitioner, 21-2612-00200 V CITY OF SAGINAW, Respondent. ________________________________________/ PETITION FOR THE 2025 TAX YEAR MAGNUM EQUITIES, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, 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 contiguous real property tax parcel nos. 21-4453-00000 and 21-2612-00200 (collectively, the “Subject Property”), also known as 3405-19 E Genesee, Saginaw, Michigan. 2. Respondent City of Saginaw (“Respondent”) assesses and collects property taxes on the Subject Property. 3. In 2025, Respondent determined the taxable and assessed values of the Subject Property to be as follows (which will result in a state equalized value in the same amount based upon the tentative equalization factor): Parcel No. AV TV 21-4453-00000 $300,000 $300,000 21-2612-00200 $30,000 $30,000
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2 4898-6618-0422.1 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. 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, 2025. 8. The 2025 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.
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3 4898-6618-0422.1 WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2024 taxable values and state equalized values of the Subject Property as follows: Parcel No. AV TV 21-4453-00000 $100,000 $100,000 21-2612-00200 $5,000 $5,000 and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. 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 29, 2025
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Entire Tribunal Case Information Sheet - Petitioner MOAHR DOCKET NO. Section 1: Petitioner’s Contact Information Filer type: Organization First Name/Company Name M.I. Last Name Magnum Equities, 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 Fax Number 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 Ave, Ste 2700 City or Town Detroit State Michigan ZIP Code 48226 Telephone Number 313-234-7177 Fax Number 313-234-2800 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jconti@foley.com Section 5: Issue Please designate one: Valuation – Fill out Sections 4, 5, & 6 below Section 6: Subject Property Information How many parcels are you appealing?2 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 3405-19 E. Genesee Saginaw Michigan Taxing Authority (City or Township) County Of Saginaw (SAGINAW) County Saginaw If you are appealing more than one parcel, are they contiguous or adjoining? Yes (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Section 7: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values Section 8: Valuation Information for Each Parcel under Appeal Parcel Number: 21-4453-00000 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 300000 Current Taxable Value as established by the Board of Review: 300000 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. Parcel Number: 21-2612-00200 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 30000 Current Taxable Value as established by the Board of Review: 30000 What do you believe is the fair market value (also known as True Cash Value)? 10000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 5000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Section 9: Assessment Information Type of Tax Assessment(s): Assessment Number(s): Check all that is being appealed: Check what action prompted this appeal: If “other,” please explain: Section 10: Special Assessment Information Type of Special Assessment:
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Did you protest the special assessment at the hearing held to confirm the special assessment roll? If Yes, what was the date of the hearing held to confirm the special assessment roll? If No, please explain: Section 11: Classification Information Parcel Number: Current Classification of Property as established by Board of Review: What do you believe is the property’s classification? If improved property, how is the property currently being used? If improved property, for what use was the property designed? Fee Information The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being
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