Mark L Supal, Petitioner V Township Of Lexington, Respondent
- Petitioner
- Mark L Supal
- Respondent
- Township Of Lexington
Case overview
- Docket number
- 24-004178-TT
- Status
- Disposed
- CaseType
- SC Property
- Division
- Small Claims Division
- County
- Sanilac
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 12 | Order of Dismissal | Not recorded | Not recorded | 09/25/2025 | Not recorded | Download |
| 11 | Evidence was received. | PET | Not recorded | 02/13/2025 | Not recorded | Download |
| 10 | Evidence was received. | PET | Not recorded | 02/13/2025 | Not recorded | Download |
| 9 | Evidence was received. | PET | Not recorded | 02/13/2025 | Not recorded | Download |
| 8 | Notice of Filing | Not recorded | Not recorded | 02/05/2025 | Not recorded | Download |
| 7 | Answer was received | RESP | Not recorded | 01/21/2025 | Not recorded | Download |
| 6 | Order Setting Aside P Default | Not recorded | Not recorded | 01/14/2025 | Not recorded | Download |
| 5 | Response to Order | PET | Not recorded | 12/20/2024 | Not recorded | Download |
| 4 | Order of Default of Petitioner | Not recorded | Not recorded | 12/18/2024 | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 12/18/2024 | Not recorded | Download |
| 2 | Notice of Docket Number SC | Not recorded | Not recorded | 12/18/2024 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 12/04/2024 | $125.00 | 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 Mark L Supal, MICHIGAN TAX TRIBUNAL Petitioner, SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Lexington Township, Presiding Judge Respondent. Patricia L. Halm ORDER OF DISMISSAL The Tribunal has considered the file in this case and finds that it has no authority over Petitioner’s appeal. The pleadings and accompanying documentation indicate that Petitioner is appealing the true cash and state equalized values for Parcel No. 76-150- 034-400-100-00 for the 2024 tax year. The Tribunal has no authority over that parcel under MCL 205.735a(3), however, because Petitioner failed to appeal the assessment to the March Board of Review (BOR) prior to initiating an appeal to the Tribunal. A final decision of the BOR is a prerequisite for invoking the Tribunal’s jurisdiction.1 Petitioner’s failure to complete the prerequisite step to appeal to the BOR is a failure to invoke the Tribunal’s statutory jurisdiction over this proceeding.2 In Sixarp, the Michigan Supreme Court reiterated previous appellate decisions in its reasoning that the Tribunal’s jurisdiction is statutory by nature. The Court stated: MCL 205.735a(3) “is not a notice statute, but is a jurisdictional statute that governs when and how a petitioner invokes the Tax Tribunal’s jurisdiction.” We therefore overrule Parkview3 to the extent that it incorrectly held that the protest requirement of . . . the precursor to MCL 205.735a . . . is a mere “procedural requirement for perfecting an appeal in the Tax Tribunal” and not an express limitation on the MTT’s jurisdiction. Instead, the protest requirement of MCL 205.735a(3) may only be waived by the court if necessary to remedy a constitutional due-process violation that deprived the taxpayer of their ability to invoke the right to protest.4 The Tribunal finds that the same reasoning relied upon by the Sixarp court is applicable in this case. The Legislature created a statutory jurisdiction prerequisite that a residential valuation be appealed to the March BOR prior to a petition being filed with the Tribunal. MCL 205.735a(3) controls the Tribunal’s jurisdiction over an appeal. The 1 See MCL 205.731. 2 See Sixarp, LLC v Byron Twp, __Mich __; __ NW3d __ (2025) (Docket No 166190) at 8. 3 Parkview Memorial Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (1990). 4 See Sixarp at 8. (Citations omitted).
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MTT Docket No. 24-004178 Page 2 of 3 Tribunal has no equitable power to disregard a statutory filing deadline.5 “[S]imply because the plaintiffs' underlying claim has a constitutional dimension, and may even be meritorious, does not excuse the plaintiffs' failure to assert their claim within the applicable statutory period of limitation.”6 The Tribunal notes that the petition in this case contends that Petitioner did not receive Respondent’s notices of assessment. This contention of improper notice, if actionable, would require a determination by an applicable authority that the purported error resulted in a due-process violation. As explained above, the Tribunal lacks any equitable authority to consider a potential due-process violation. Jurisdiction as a result of a failure of a unit of government to comply with a statutory obligation, if there was any, may be vested upon the Tribunal by a judicial body only as a matter of equity.7 Lacking jurisdiction, the only appropriate action is dismissal. Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending claims in this matter and closes this case. APPEAL RIGHTS If you disagree with the final decision in this case, you may file a motion for reconsideration with the Tribunal or a claim of appeal with the Michigan Court of Appeals. A motion for reconsideration must be filed with the Tribunal with the required filing fee within 21 days from the date of entry of the final decision. Because the final decision closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing system; it must be filed by mail or personal service. The fee for the filing of such motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless the Small Claims decision relates to the valuation of property and the property had a principal residence exemption of at least 50% at the time the petition was filed or the decision relates to the grant or denial of a poverty or disabled veterans exemption and, if so, there is no filing fee. You are required to serve a copy of the motion on the opposing party by mail or personal service or by email if the opposing party agrees to electronic service, and proof demonstrating
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M
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ARCHIVED Valuation Report DB: Lexington Twp 2024 02/12/2025 10:01 AM 99,600 99,600 99,600 41,155 41,155 0 2024 Assessed MBOR S.E.V. Capped ->Taxable<- PRE/MBT 0 27,600 0 0 1,959 0 2024 New Eq. Adjustment Loss Additions Tax Adjustment Losses 72,000 72,000 72,000 39,196 5.00 2023 Assessed MBOR S.E.V. Base for Cap C.P.I. Est. TCV/Total Floor Area = 207.50 2024 Est. T.C.V. 150-034-400-100-00 = 199,203 ECF (TWPSW.SOUTHWEST SEC 20,22&23, 26-35) 0.903 => TCV: 144,174 Notes: Totals: 190,072 159,661 Comp.Shingle 672 11,868 9,969 Carports Treated Wood 448 7,571 6,360 Deck CPP 448 7,544 6,337 Porches Water Well, 200 Feet 1 11,581 9,728 1000 Gal Septic 1 5,244 4,405 Water/Sewer 3 Fixture Bath 1 5,008 4,207 Plumbing Other Additions/Adjustments Total: 141,256 118,655 1+ Story Siding Slab 960 Stories Exterior Foundation Size Cost New Depr. Cost Building Areas Phy/Ab.Phy/Func/Econ/Comb. % Good=84/100/100/100/84 Ground Area = 960 SF Floor Area = 960 SF. (11) Heating System: Forced Air w/ Ducts Cost Est. for Res. Bldg: 1 Single Family 1 STORY Cls C Blt 1995 10.00 Total Acres Total Est. Land Value = 55,029 METES AND BOUNDS RES 10.000 Acres 5,503 100 55,029 Description Frontage Depth Front Depth Rate %Adj. Reason Value * Factors * Land Value Estimates for Land Table TWPMB.TWPMB.TWP RESIDENTIAL Map #: LEXINGTON TOWNSHIP , Property Class: 401 6139 SHERIDAN LINE 76-150-034-400-100-00 2024 Est. T.C.V. SUPAL MARK & MIROSLAWA
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Valuation Report DB: Lexington Twp 2023 02/12/2025 10:05 AM 72,000 72,000 72,000 39,196 39,196 0 2023 Assessed MBOR S.E.V. Capped ->Taxable<- PRE/MBT 0 6,800 0 0 1,866 0 2023 New Eq. Adjustment Loss Additions Tax Adjustment Losses 65,200 65,200 65,200 37,330 5.00 2022 Assessed MBOR S.E.V. Base for Cap C.P.I. Est. TCV/Total Floor Area = 150.09 2023 Est. T.C.V. 150-034-400-100-00 = 144,085 ECF (TWPSW.SOUTHWEST SEC 20,22&23, 26-35) 0.766 => TCV: 113,437 Notes: Totals: 176,299 148,090 Comp.Shingle 672 11,007 9,246 Carports Treated Wood 448 7,020 5,897 Deck CPP 448 6,998 5,878 Porches Water Well, 200 Feet 1 10,743 9,024 1000 Gal Septic 1 4,864 4,086 Water/Sewer 3 Fixture Bath 1 4,646 3,903 Plumbing Other Additions/Adjustments Total: 131,021 110,056 1+ Story Siding Slab 960 Stories Exterior Foundation Size Cost New Depr. Cost Building Areas Phy/Ab.Phy/Func/Econ/Comb. % Good=84/100/100/100/84 Ground Area = 960 SF Floor Area = 960 SF. (11) Heating System: Forced Air w/ Ducts Cost Est. for Res. Bldg: 1 Single Family 1 STORY Cls C Blt 0 10.00 Total Acres Total Est. Land Value = 30,648 METES AND BOUNDS RES 10.000 Acres 3,065 100 30,648 Description Frontage Depth Front Depth Rate %Adj. Reason Value * Factors * Land Value Estimates for Land Table TWPMB.TWPMB.METES AND BOUNDS RESIDENTIAL Map #: LEXINGTON TOWNSHIP , Property Class: 401 6139 SHERIDAN LINE 76-150-034-400-100-00 2023 Est. T.C.V. SUPAL MARK & MIROSLAWA
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This document will serve as evidence for Michigan Tax Tribunal docket 24-004178 and will discuss the 2023 and 2024 Valuation Reports for 6139 Sheridan Line in Lexington Twp., property tax ID 150-034-400-100-00. The home Is 960 sq ft and is 32 years old. Looking at the data from the assessor, there are items that concern the petitioner. Typically, the building cost should include such obvious items as plumbing but for comparison’s sake, individual costs of items will be compared as shown in Table 1 below. Besides differences in costs, there is a difference in the Economic Condition Factor (ECF) and big difference in the land value determined by the assessor. Table1 Assessor’s Calcs ($) 2024 Assessor’s Calcs ($) 2023 My Calcs ($) for 2024 Building Cost (960 sq ft) 141,256 131,921 134,400 ($140/sq ft) Plumbing 5,008 4,646 2500 Septic System 5,244 4,864 3,800 Well (100 ft not 200 ft) 11,581 10,743 4,500 (used $45 per ft) Porch? Slab (measures 34 x 13 as stated) (448 sq ft) 7,544 6,998 2,240 (5 per sq ft) Deck (measures 24 x 14) (336 sq ft not 448 sq ft) 7,571 7,020 5,040 (15 per sq ft) Carport (measures 20 x 13) (260 not 672 sq ft) 11,868 ($17 per sq ft) 11,007 4,590 Totals: 190,072 176,299 157,070 Depreciation Cost (84%) 159,661 148,090 131,938 ECF 0.903 0.766 0.863 (study nearest) TCV 144,174 113,437 113,863 Land Value 55,029 30,648 30,648 (per 2023) + 3% for and updated value of 31,567 Total TCV 199,203 144,085 145,430 AV (half of the total TCV 99,600 72,000 72,715 Notes: Data taken from Angie’s List and Google AI searches Info from Angie.com https://www.angi.com/articles/concrete-slab-cost.htm Building Costs: In January 2025, the cost to build a house in Michigan ranges from $130 to $220 per square foot, depending on the home's size, style, and other factors. Septic System: The cost of a septic system in Michigan can range from $3,500 to $20,000 Well: Drilling a residential water well costs $25 to $65 per foot Concrete: The average cost for a concrete slab typically ranges between $4.34 and $7.73 per square foot. Deck: In Michigan, the cost to build a deck can range from $15 to $20 per square foot for pressure-treated wood. Carport: The average carport cost is $6,238, but a carport that's big enough to provide cover for a single car can cost as little as $300. The carport in question is simply an extension of the home’s roof rafters. Cost to Clear Land in Michigan: The cost to clear land in 2025 per acre is $1500 to $2100 for lightly forested lots and $3300 to $5600 for highly wooded land. Therefore, on average, 10 acres will cost $20,000 to clear.
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Explanation of ECF Used The value used by the petitioner for the ECF is based off a report published on the Lexington Township’s website (https://www.lexingtontownship.org/taxes/). The report is titled Lexington Township Old M-51 Lots ECF Study 2024. The property in question is parcel 150-034-400-100-00. Upon viewing the report, the petition could not find any analysis of section 34 (a one square mile section) where the property is situated. Looking at the Valuation Report, the property was thrown into a collection of sections 20, 22, 23 and 26-35 which are not near the property. The relevant sections that should have studies are shown in Figure 1 below. The only section close is 26 which includes very expensive and desirable golf course homes. Below are the homes used in the study area for section 26 and the final calculated ECF value of 0.863. This is the value used in the petitioner’s analysis. Lexington Township Old M-51 Lots ECF Study 2024 Explanation of Land Value On average, land value increases by around 2-3 percent per year. In 2023 the land value of the 10 acres was $30,648 as shown in the Valuation Report for 2023. If you add in an increase of 3%, the 2024 value should be $31,567 and not $55,029. The land has no agriculture value or potential for development as it is land locked. The jump in land value to $55,029 from $30,648 in the course of one-year computes to an increase of 80% which is over exaggerated. Based on the petitioner’s analysis above, please consider the AV of the property for 2024-25 to be close to $72,715 as shown in Table 1 above. 26 35 33 27 34 28 Golf Course Worth Twp
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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 Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. NOTICE OF FILING TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. Unless Respondent was defaulted, this case is ready to be scheduled for a Small Claims hearing and will be scheduled in the normal course of scheduling. You will receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email address in the petition or other documentation. The Notice of Hearing will inform you of the date, time, and location of your hearing (note that your hearing will likely be conducted by telephone). Please read the Notice of Hearing as it includes important information. EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy to the opposing party at least 21 days before the hearing date even if the documents had been submitted to the local Board of Review or the Michigan Department of Treasury. If the documents are not timely submitted to the Tribunal and served on the opposing party, the documents may be excluded. Documents may be filed with the Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the opposing party by mail or by e-mail, if the parties agree to service by e-mail. Alternate Dispute Resolution Options INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this case through an informal settlement conference. An informal settlement conference is a meeting between the parties and/or their representatives to discuss the issues in a case in an effort to settle the case. This process may be an alternative to a hearing with a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent Judgment. Visit the Tribunal’s ADR webpage for more information. MEDIATION: Parties have the option of handling this case through mediation. Mediation is a voluntary process where a mediator facilitates communication between the parties, assists in identifying issues, and helps explore solutions to promote a mutually acceptable settlement. This process may be an alternative to a hearing with a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent Judgment. Visit the Tribunal’s ADR webpage for more information.
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MTT Docket No. 24-004178 Page 2 of 6 If you have any questions, please contact the Tribunal by phone at (517) 335-9760 or email taxtrib@michigan.gov. By: Tribunal Clerk Entered: February 5, 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. NOTICE OF FILING TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. Unless Respondent was defaulted, this case is ready to be scheduled for a Small Claims hearing and will be scheduled in the normal course of scheduling. You will receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email address in the petition or other documentation. The Notice of Hearing will inform you of the date, time, and location of your hearing (note that your hearing will likely be conducted by telephone). Please read the Notice of Hearing as it includes important information. EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy to the opposing party at least 21 days before the hearing date even if the documents had been submitted to the local Board of Review or the Michigan Department of Treasury. If the documents are not timely submitted to the Tribunal and served on the opposing party, the documents may be excluded. Documents may be filed with the Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the opposing party by mail or by e-mail, if the parties agree to service by
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MTT Docket
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STA
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RECEIVED
JAN 3-0 2025
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON |. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
PROPERTY TAX APPEAL ANSWER FORM
VALUATION / EXEMPTION / CLASSIFICATION APPEAL
MTT DOCKET NO. 24-004178
Section 1: Respondent’s Contact Information
First Name:
Mt:
Last Name/Company Name/Unit of Government:
Lexington Township
Home Address (No., Street, P.O. Box or Rural Route):
County:
.
7227 Huron Ave, Ste 200
Sanilac
City or Town:
State:
ZIP Code:
Lexington
MI
48450
Telephone Number:
Fax Number:
810 359-5500
E-mail Address {do not enter unless you want MTT to send all correspondence via email):
assessormail@gmail.com
Section 2: Respondent’s Attorney/Authorized Representative’s Contact Information
First Name:
Last Name:
Arthur
Ww
Schlichting
rene Lexington Twp Assessor
Address (No., Street, P.O. Box or Rural Route):
City or Town:
State:
ZIP Code:
Telephone Number;
Fax Number:
E-mail Address (do not enter unless you want MTT to send all correspondence via email):
Section 3: Subject Property Information
Does the subject property have a Principal Residence Exemption of §0% or more?
[| Yes
[0%] No
Are the parcels listed by Petitioner contiguous or adjoining?
if not, list which parcels adjoin one another.
ves
[No
Not ApplicablePage 2
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
Section 4: Explain Your Answer to this Appeal
Petitioner has no standing.
The Assessment Change Notice was received timely by petitioner. The copy of the
Notice submitted by petitioner in response to default is the Notice mailed to petitioner on
February 26, 2024.
This format of Notice only exists as mailed by Lexington Township's Mailing
contractor, there are no second copies and the township cannot produce the Notice in
this format. There is no possible way to receive this Notice except by the February 2024
mailing of the Notice as required prior to the 2024 March Board of Review.
The True Cash Value is correct per statute.
Section 5: Jurisdictional Issues
IF PETITIONER IS APPEALING THE TRUE CASH AND/OR TAXABLE VALUES
Did Petitioner protest the assessment at a Board of Review (BOR)? [I] Yes
No
If yes, check which BOR Petitioner attended: 0 March
[I] July
[Ml] December
If no, was the Notice of Assessment properly sent to Petitioner prior to the March BOR?
Yes
0 No
*Submit a copy of the Notice of Assessment with the Answer,
If the July or December BOR revised the assessment(s) at issue, did it have authority? O Yes
M No
If yes, cite the Board's authority.
Was the assessment{(s) at issue established as the result of a clerical error or mutual mistake of fact? 1] Yes
No
if yes, explain
Is Petitioner appealing from a State Tax Commission Order?
J Yes
No
If so, what is the issue date?
IF PETITIONER IS APPEALING THE UNCAPPING OF TAXABLE VALUEPage 3
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
Did Petitioner request a Poverty Exemption at
a BOR? 0 Yes
0 No
If Yes, check which BOR Petitioner attended: [_] March
[J July
[7] December
List the date the BOR denied Petitioner's Poverty Exemption;
IF PETITIONER IS APPEALING THE DENIAL OF AN EXEMPTION
OTHER THAN POVERTY, PRINCIPAL RESIDENCE, OR QUALIFIED AGRIGULTURAL EXEMPTIONS
Did Petitioner request the exemption at a BOR? [I] Yes
OJ No
If Yes, check which BOR Petitioner attended: |] March
[J July
[7] December
Tax Year(s) denied:
List the date the exemption was denied:
What statutory section did Petitioner request the subject property be exempt?
IF PETITIONER IS APPEALING THE CLASSIFICATION OF PROPERTY
What do you believe the classification should be;
Real
Personal
(check one)
0
Agricultural
Commercial
Industrial
Residential
Timber-Cutover
Developmental
Utility
(check one)
Section 6: Valuation Info rmation se the multiple parcel form for additional, contiguous parcels.
Parcel identification Number:
150-034-400-100-00
Classification of Property:
Real
Personal
(check one)
Agricultural
Commercial
industrial
Residential
Timber-Cutover
Developmental
~~ Utility
(check one)
Current Assessed Value {also known as State Y= Value) as established by the BOR:
$99,600
Current Taxable Value as established by the BOR:
$41,155
What do you belleve is the fair market value (also known as True Cash Value)?
$200,000
Multiply the True Cash Value by .5 and enter here. This Is your contention of Assessed Valle.
$100,000
Ifyou believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.
Signature srequigd” >Page 4
STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Mark L Supal, MICHIGAN TAX TRIBUNAL Petitioner, SMALL
Page 5
Hidi
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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 Mark L Supal, MICHIGAN TAX TRIBUNAL Petitioner, SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Lexington Township, Presiding Judge Respondent. Patricia L. Halm ORDER SETTING ASIDE PETITIONER’S DEFAULT On December 20, 2024, Petitioner filed a response to the Tribunal’s December 18, 2024, Order of Default. The response includes a letter to the Tribunal and the subject property’s 2024 Notice of Assessment. The Tribunal has considered the response and the case file and finds that Petitioner was placed in default because they did not submit a copy of the notice giving rise to the appeal. However, the petition indicates that Petitioner did not appeal the assessment to Respondent’s March Board of Review (BOR) and also indicates that Petitioner did not receive the assessment notice. Petitioner timely responded to the Order of Default and has now included the subject assessment notice. The Tribunal finds that Petitioner did not appeal the assessment to the March BOR prior to commencing the Tribunal appeal as required by statute.1 Petitioner contends they did not receive the notice, and as a result, allowing the case to proceed to hearing to make findings of fact with respect to the Tribunal’s jurisdiction over this case is appropriate.2 As such, the Tribunal finds good cause to grant the motion and set aside the default. Therefore, IT IS ORDERED that Petitioner’s Default is SET ASIDE. Entered: January 14, 2025 By _____________________________ bw 1 MCL 205.735a(3). 2 See Oak Park Crown Pointe, LLC v City of Oak Park, unpublished per curiam opinion of the Michigan Court of Appeals, issued December 12, 2019 (Docket No. 345819).
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MTT Docket No. 24-004178 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
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RECEIVED DEC 27 2024 MICHIGAN TAX TRIBUNAL December 19, 2024 Michigan Tax Tribunal 611 W Ottawa St. Lansing, Michigan 48933 To Whom It May Concern: The is regarding MTT Docket No. 24-0041 78 | received a Notice of Action entered on December 18, 2024, that states | did not send a copy of the notice giving rise to an appeal. | called the Tribunal, and they informed me to send a document such as a Notice of Assessment which | am including in this letter. Thank you Mark Supal 961 S. Renaud Grosse Pointe Woods, MI 48236 (313) 938-4172 marksupal@yahoo.com Sincerely, Mark Supal Dd pn
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of action taken by Board of Review, uncapping notice, PRE denial notice, final assessment notice, etc.), as required by TTR 277. As such, Petitioner must submit the notice within 14 days of the entry of this Order. Therefore, IT IS ORDERED that Petitioner 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. 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). ) DRT By: . allie Ff « Nal Entered: December 18, 2024 Patricia L. Halm, Tribunal Chair
Page 3
Hitigon Depadmant of Treasury. THIS IS NOT A TAX BILL L-4400 Notice of Assessment, Taxable Valuation, and Property Classification a This form is issued under the autharity of A. 206 of 1893, Sec. 211.24 (¢) and Sec.211.34c, as amended. This is a model assessment notice lo be used by the local assessor. FROM PARCEL IDENTIFICATION LEXINGTON TWP ASSESSOR PARCEL NUMBER: = ud n= w 7227 HURON AVE STE 200 76-150-034-400-100-00 LEXINGTON, M! 48450 PROPERTY ADDRESS: 6139 SHERIDAN LINE y OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: PRINCIPAL RESIDENCE EXEMPTION “ _ " - or ok x *+AUTOS¥ALL FOR AADC 481 % Exempt As "Homeowners Principal Residence™ 00% SUPAL MARK & MIROSLAWA % Exempt &s “Qualified Agricultural Properfy™ 00% 961 S RENAUD RD ; GROSSE POINTE WOODS, MI 48236-1735 % Exempt As "MBT Industrial Personai™: 00% giginiau mu uig im alfa l splihjilo 9% Exempt As "MBT Commercial Personal”: 00% 1 Hirt nie re es Exempt As "Qualified Farest Property" a Yes No Exempt As "Development Property”: [J Yes No LEGAL DESCRIPTION: “T10N RIGE SEC 34 THE E 330 FT OF W 1650 FT OF $ 1/2'OF SE 1/4 10.0000 A. ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 401 (RESIDENTIAL-IMPROVED) PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 401 (RESIDENTIALAMPROVED) PRIOR pad TENTATIVE AMOUNT PRIOR LAR TO - 3 YEAR: 2024 CURRENT YEAR 1. TAXABLE VALUE: 39,196 41,155 1,959 2. ASSESSED VALUE: 72,000 99,600 27.600 3, TENTATIVE EQUALIZATION FACTOR: 1.000 E 4. STATE EQUALIZED VALUE (SEV): 72,000 99,600 27,600 5. There WAS or WAS NOT a transfer of ownership on this property in2023 WAS NOT 6. Assessor Change Reason(s): The 2024 inflation rate Multiplier is: 1.05 Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the Following: Name: Phone: Email Address: ASSESSOR ARTHUR SCHLICHTING 810-359-5500 ASSESSORMAIL@GMAIL.COM Warch Board of Review Appeal Information. The Board of Review will meet at the following dates and times:
Page 4
CH) Suped | y 96) S Keraal - 2024 PM i -- ie Grosse fre Whdy MT wil : 982.2 1] ict igan Jax Tribunal Lans 2 NL F5709 AED ET TIRES He ye fo desage bad boa | Pg dage pss 1 f
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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 Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of action taken by Board of Review, uncapping notice, PRE denial notice, final assessment notice, etc.), as required by TTR 277. As such, Petitioner must submit the notice within 14 days of the entry of this Order. Therefore, IT IS ORDERED that Petitioner 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.i 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:_______________________________ Entered: December 18, 2024 Patricia L. Halm, Tribunal Chair
Page 2
MTT Docket No. 24-004178 Page 2 of 4 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk i “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 219(5)
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 Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of action taken by Board of Review, uncapping notice, PRE denial notice, final assessment notice, etc.), as required by TTR 277. As such, Petitioner must submit the notice within 14 days of the entry of this Order. Therefore, IT IS ORDERED that Petitioner 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.ii 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:_______________________________ Entered: December 18, 2024 Patricia L. Halm, Tribunal Chair
Page 4
MTT Docket No. 24-004178 Page 4 of 4 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk ii “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
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Page 1
RECEIVED
DEC 102024
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON |. BROWN, DPA
GOVERNOR
DIRECTOR
PROPERTY TAX APPEAL PETITION FORM
VALUATION / EXEMPTION / CLASSIFICATION APPEAL
Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or
Non-Property tax disputes.
Pursuant
to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal
(e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. if you do not
submit this document, you may be hetd in default.
Section 1: Petitioner's Contact Information
First Name
MA
Last Name/Company Name
Mark
L
Supal
Mailing Address (No., Street, P.O. Box or Rural Route}
961 S. Renaud
City or Town
State
ZIP Code
Grosse Pointe Woods
Mi
48236
Telephone Number
Fax Number
3139384172
E-mail Address {do not enter unless you want MTT to send all correspondence via e-mail}
marksupal@yahoo.com
Section 2: Petitioner's Attorney/Authorized Representative’s Contact Information
First Name
[TKN
Last Name
Firm Name {if any)
Address (No., Street, P.O. Box or Rural Route)
City or Town
State
2iP Code
Telephone Number
Fax Number
E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)
Section 3: Subject Property Information
How many
if you are appealing more than one parcel, are they contiguous or adjoining?
parcetsare you | [7] vest
[gf No
appealing?
*If yas, use a multiple parcel form for information regarding any contiguous parcels.
non-contiguous or non-adjoining parcel or you will be defaulted.Page 2
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
DIRECTOR
Section 4: Issues Being Appealed (check al that apply)
{@ True Cash and Taxable Value
[3 Poverty Exemption
{J Taxable Value Only (calculation)
[J Disabled Veterans Exemption
[J Uncapping of Taxable Value
{1 Eligible Manufacturing Personal Property (ESA)
[1 Exemption from Taxation {other than the denial of a
{3 Classification
Principat Residence or Qualified Agricultural Exemption)
Section 5: Explain the Reason for this Appeal
Right along over the past years the assessed value and corresponding state equalized
value have crept up consistently by roughly 10%. This year, 2024, the assessed value
and corresponding state equalized value have gone up by over 38%. The AV and
corresponding SEV rose from $72,000 to $99,600. The past year has not been a
gangbuster year for real estate in Croswell Michigan where the property is located. And
I do realize that increases in the AV and SEV do not affect the property taxes
| pay. But,
a sale of the property is drastically affected by the increases and it concerns me. It
doesn't make sense that there is such a big jump in AV and SEV in the one year, 2024,
and
| want to make sure that any increases are reasonable and fair.
Section 6: Jurisdictional Issues
Year(s) you are appealing:
2024
Did you protest the assessment at a Board of Review (BOR)? [I] Yes
No
1f Yes, check which BOR you attended AND attach the BOR decision; [W] March
0 July
i] December
if No, check the applicable reason(s):
{7 Not required to attend
4 Assessment Change Notice was not received by Petitioner
0 Appealing a purported Clerical Ervor or Mutual Mistake of Fact (if yes, Include explanation in Section 6)
[| Appealing within 36 days of State Tax Commission Order
| Appealing within 35 days of receipt of Notice of UncapplingPage 3
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
DIRECTOR
Section 7: Valuation Information suse the multiple parce! form for additional, contiguous parcels.
Parcel identification Number:
76-150-034-400-100-00
Classification of Property:
Real
Personal
{check one)
Agricultural
Commercial
Industrial
Residential
Timber-Cutover
Developmental
Utility
(check one}
Current Assessed Value {afso known as State Equalized Value) as established by the BOR:
99,600
Current Taxable Value as established by the BOR:
41,155
What do you believe is the fair market value (also known as True Cash Value)?
82,310
Multiply the True Cash Value by .8 and enter here. This is your contention of Assessed Value.
41,155
you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value,
| have no contention with the TV. My contention is with the AV and corresponding SEV
Section 8: Classification Information only the Mi Dep't of Treasury may appeat this Issue to the Tribunal*
Parcel Identification Number:
76-150-034-400-100-00
Current Classification of Property as established by Board of Review:
Real
Personal
{check one)
Agricuttural
Commercial
Industrial a
Timber-Cutover
Developmental
Utifity
(check one)Page 4
Cirrm
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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 Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket number has been assigned to that petition. The assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with the Tribunal’s rules. The docket number needs to be included on all documents submitted in this case. Respondent shall file an answer to the petition within 28 days of the issuance of a copy of this Notice to Respondent. Tribunal answer forms are available on our website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer form. Failure to file the answer within the 28-day time frame may result in the placement of Respondent in default, as provided by TTR 279. Further, an electronic copy of the petition can be reviewed by utilizing the Docket Lookup Search on the Tribunal’s website. By: __Tribunal Clerk_____ Entered: December 18, 2024 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 provide 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 Mark L Supal, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-004178 Township Of Lexington, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket number has been assigned to that petition. The assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with the Tribunal’s rules. The docket number needs to be included on all documents submitted in this case. Respondent shall file an answer to the petition within 28 days of the issuance of a copy of this Notice to Respondent. Tribunal answer forms are available on our website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer form. Failure to file the answer within the 28-day time frame may result in the placement of Respondent in default, as provided by TTR 279. Further, an electronic copy of the petition can be reviewed by utilizing the Docket Lookup Search on the Tribunal’s website. By: __Tribunal Clerk_____ Entered: December 18, 2024 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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Read document text excerpt
Page 1
RECEIVED
DEC 102024
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON |. BROWN, DPA
GOVERNOR
DIRECTOR
PROPERTY TAX APPEAL PETITION FORM
VALUATION / EXEMPTION / CLASSIFICATION APPEAL
Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or
Non-Property tax disputes.
Pursuant
to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal
(e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. if you do not
submit this document, you may be hetd in default.
Section 1: Petitioner's Contact Information
First Name
MA
Last Name/Company Name
Mark
L
Supal
Mailing Address (No., Street, P.O. Box or Rural Route}
961 S. Renaud
City or Town
State
ZIP Code
Grosse Pointe Woods
Mi
48236
Telephone Number
Fax Number
3139384172
E-mail Address {do not enter unless you want MTT to send all correspondence via e-mail}
marksupal@yahoo.com
Section 2: Petitioner's Attorney/Authorized Representative’s Contact Information
First Name
[TKN
Last Name
Firm Name {if any)
Address (No., Street, P.O. Box or Rural Route)
City or Town
State
2iP Code
Telephone Number
Fax Number
E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)
Section 3: Subject Property Information
How many
if you are appealing more than one parcel, are they contiguous or adjoining?
parcetsare you | [7] vest
[gf No
appealing?
*If yas, use a multiple parcel form for information regarding any contiguous parcels.
non-contiguous or non-adjoining parcel or you will be defaulted.Page 2
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
DIRECTOR
Section 4: Issues Being Appealed (check al that apply)
{@ True Cash and Taxable Value
[3 Poverty Exemption
{J Taxable Value Only (calculation)
[J Disabled Veterans Exemption
[J Uncapping of Taxable Value
{1 Eligible Manufacturing Personal Property (ESA)
[1 Exemption from Taxation {other than the denial of a
{3 Classification
Principat Residence or Qualified Agricultural Exemption)
Section 5: Explain the Reason for this Appeal
Right along over the past years the assessed value and corresponding state equalized
value have crept up consistently by roughly 10%. This year, 2024, the assessed value
and corresponding state equalized value have gone up by over 38%. The AV and
corresponding SEV rose from $72,000 to $99,600. The past year has not been a
gangbuster year for real estate in Croswell Michigan where the property is located. And
I do realize that increases in the AV and SEV do not affect the property taxes
| pay. But,
a sale of the property is drastically affected by the increases and it concerns me. It
doesn't make sense that there is such a big jump in AV and SEV in the one year, 2024,
and
| want to make sure that any increases are reasonable and fair.
Section 6: Jurisdictional Issues
Year(s) you are appealing:
2024
Did you protest the assessment at a Board of Review (BOR)? [I] Yes
No
1f Yes, check which BOR you attended AND attach the BOR decision; [W] March
0 July
i] December
if No, check the applicable reason(s):
{7 Not required to attend
4 Assessment Change Notice was not received by Petitioner
0 Appealing a purported Clerical Ervor or Mutual Mistake of Fact (if yes, Include explanation in Section 6)
[| Appealing within 36 days of State Tax Commission Order
| Appealing within 35 days of receipt of Notice of UncapplingPage 3
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
DIRECTOR
Section 7: Valuation Information suse the multiple parce! form for additional, contiguous parcels.
Parcel identification Number:
76-150-034-400-100-00
Classification of Property:
Real
Personal
{check one)
Agricultural
Commercial
Industrial
Residential
Timber-Cutover
Developmental
Utility
(check one}
Current Assessed Value {afso known as State Equalized Value) as established by the BOR:
99,600
Current Taxable Value as established by the BOR:
41,155
What do you believe is the fair market value (also known as True Cash Value)?
82,310
Multiply the True Cash Value by .8 and enter here. This is your contention of Assessed Value.
41,155
you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value,
| have no contention with the TV. My contention is with the AV and corresponding SEV
Section 8: Classification Information only the Mi Dep't of Treasury may appeat this Issue to the Tribunal*
Parcel Identification Number:
76-150-034-400-100-00
Current Classification of Property as established by Board of Review:
Real
Personal
{check one)
Agricuttural
Commercial
Industrial a
Timber-Cutover
Developmental
Utifity
(check one)Page 4
Cirrm
These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.