Michael Guthrie, Petitioner V City Of Northville, Respondent
- Petitioner
- Michael Guthrie
- Respondent
- City Of Northville
Case overview
- Docket number
- 26-000206-TT
- Status
- Disposed
- CaseType
- SC Property
- Division
- Small Claims Division
- County
- Oakland
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 5 | Order of Dismissal | Not recorded | Not recorded | 03/04/2026 | Not recorded | Download |
| 4 | Petition has been verified | PET | 1 | 03/04/2026 | Not recorded | Download |
| 3 | Notice of Docket Number SC | Not recorded | Not recorded | 03/04/2026 | Not recorded | Download |
| 2 | Attachments to the Petition were filed | Not recorded | Not recorded | 03/01/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 03/01/2026 | Not recorded | 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 Michael Guthrie, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000206 City Of Northville, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner failed to protest the assessment to Respondent’s March Board of Review, as required by MCL 205.735a. As such, and inasmuch as the Tribunal has no equitable power to waive or otherwise disregard statutory filing requirements and deadlines, it has no authority to hear the appeal or grant the relief requested. See Sixarp, LLC v Byron Twp, __Mich__; __NW3d__ (2025). Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending issues and closes the 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 that service must be submitted with the motion. Responses to motions for reconsideration are prohibited and there are no oral arguments unless otherwise ordered by the Tribunal.
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MTT Docket No. 26-000206 Page 2 of 6 Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If the claim is filed more than 21 days after the entry of the final decision, it is an “appeal by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the record on appeal. There is no certification fee. By:___________________________________ Patricia L. Halm, Tribunal Chair Entered: March 4, 2026 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 Michael Guthrie, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000206 City Of Northville, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner failed to protest the assessment to Respondent’s March Board of Review, as required by MCL 205.735a. As such, and inasmuch as the Tribunal has no equitable power to waive or otherwise disregard statutory filing requirements and deadlines, it has no authority to hear the appeal or grant the relief requested. See Sixarp, LLC v Byron Twp, __Mich__; __NW3d__ (2025). Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending issues and closes the 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 that service must be submitted with the motion. Responses to motions for reconsideration are prohibited and there are no oral arguments unless otherwise ordered by the Tribunal.
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MTT Docket No. 26-000206 Page 4 of 6 Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If the claim is filed more than 21 days after the entry of the final decision, it is an “appeal by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the record on appeal. There is no certification fee.
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STATE OF MICHIGAN GRETCHEN
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M
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR PROPERTY TAX APPEAL PETITION FORM VALUATION / EXEMPTION / CLASSIFICATION APPEAL MOAHR DOCKET NO. 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 held in default. Section 1: Petitioner’s Contact Information Filer Type: Individual First Name Michael M.I. Last Name/Company Name Guthrie Mailing Address (No., Street, P.O. Box or Rural Route) 429 Hill Street City or Town Northville State Michigan ZIP Code 48167 Telephone Number 2483467142 Fax Number E-mail Address mguthrie@in-formstudio.com Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information First Name M.I. Last Name Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone Number Fax Number E-mail Address Section 3: Subject Property Information How many parcels are you appealing? 1 If you are appealing more than one parcel, are they contiguous or adjoining? *If no, you must file separate appeals for each non-contiguous or non-adjoining parcel. Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 429 Hill Street
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Northville Michigan 48167 Taxing Authority (City or Township) City Of Northville (OAKLAND) County Oakland Section 4: Issues Being Appealed (check all that apply) Taxable Value Only (calculation) Section 5: Explain the Reason for this Appeal I am appealing the 2026 assessed value assigned to my property at 429 Hill Street (Parcel ID 48-42-34-406-018) because the current assessed value is significantly higher than market evidence supports for homes of similar size, condition, and location in the 48167 zip code. My home has 3,379 square feet of finished living area, yet the assessor’s implied market value of approximately $1,650,400 (based on the 2026 assessed value of $825,200 × 2), with a value of $488/sf. This exceeds market indicators for comparable homes of similar size north of 8 Mile between Beck Road and Meadowbrook Road. Comparable Sales Evidence: Recent sales in 48167 demonstrate a wide range of prices that, when adjusted for size, location, and condition, suggest that the assessor’s valuation may overstate fair market value: • 49825 9 Mile Rd, Northville MI 48167 sold in mid-2025 for $1,650,000 with ~4,572 sq ft (~$361 per sq ft). This home is larger and newer than mine, and a value of ~$361/sq ft should not be extrapolated to my home without adjustments for age, lot, finishes, and condition. • 900 Andover Dr (~3,494 sq ft) sold in mid-2025 for $779,900 (~$223 per sq ft). • 39502 Danielle Dr (~3,026 sq ft) sold for $676,000 (~$223/sq ft). • 21929 Heatheridge Ln (~3,046 sq ft) sold for $621,000 (~$204/sq ft). • 655 Randolph St Unit 103 (~3,619 sq ft) sold for $1,180,000 (~$326/sq ft). Based on these recent 2025 sales, homes close in size to mine generally show price per square foot outcomes lower than the assessor’s implied value, even for premium homes, especially after accounting for location differences and site characteristics. Market Trends & Neighborhood Context: In the 48167 area, the median sales price for homes in the past year has been approximately $540,000, with a typical average home size of about 2,389 sq ft, reflecting the broader market baseline. Conclusion: Given the inconsistency between the current assessed value and actual market evidence from comparable sales, I respectfully request that the assessor reconsider the valuation, adjust the assessed value downward to reflect a more accurate market value based on these comparables, and verify that square footage and property characteristics used for assessment are correct. Section 6: Jurisdictional Issues Year(s) you are appealing: 2025, 2026 Did you protest the assessment at a Board of Review (BOR)? No If Yes, check which BOR you attended AND upload the BOR decision: If No, check the applicable reason(s): Not required to attend Did you request a Poverty Exemption at the BOR? If Yes, check which BOR considered your application AND upload the BOR decision: March July December If No, explain why:
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Section 7: Valuation Information *Use the multiple parcel form for additional, contiguous parcels. Parcel Identification Number: 48-42-34-406-018 Classification of Property: Personal Residential Current Assessed Value (also known as State Equalized Value) as established by the BOR: 825200 Current Taxable Value as established by the BOR: 580881 What do you believe is the fair market value (also known as True Cash Value)? 1050000 Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 525000 If you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 388500 Section 8: Classification Information *Only the MI Dep’t of Treasury may appeal this issue to the Tribunal* Parcel Identification 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 Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition? Yes Are
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STAT
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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 Michael Guthrie, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000206 City Of Northville, 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 281. 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: March 4, 2026 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 Michael Guthrie, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 26-000206 City Of Northville, 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 281. 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: March 4, 2026 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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te THIS IS NOT A TAX BILL L-4400 Notice of Assessment, Taxable Valuation, and Property Classification m8 end ow sty of Pte Ac 208. Boe 11 24 and So 211 346, un mario. Thes 1 # messed assesment rion 1 bo ued by ha local ansmsncr PARCEL IDENTIFICATION CITY OF NORTHVILLE R ¥ 215 W MAIN ST PARCEL NUMBE 48-22-34-406-018 PROPERTY ADDRESS NORTHVILLE, MI 48167 429 HILL NORTHVILLE, MI 48167 SCHOOL DISTRICT CODE: 82390 OWNERS NAME AND ADORE SS/PERSON NAMED ON ASSESSMENT pais EXEMPTIONS CRSSNTORS BOLT 016) TS 1 ane % Exempt As "Homeowners Principal Residence” oui fg ree % Exompt As "Qualified Agricul! Proparty” NORTHVILLE, MI 48167-1107 % Exempt As "MBT Industrial Personal™ 0% LLL RU UC CT eer % Exompt As "MBT Commercial Personal” 0% Exompt As “Disabled Veteran of ClYes [X No Surviving Spouse™ Exempt As "Qualified Forest Property” [1] Yes [X] No Exampt As "Development Property” [J Yes No LEGAL DESCRIPTION TIN, REE, SEC 34 OAKWOOD SUB E 172 OF LOTS 77 & 78, ALSO 1/2 OF VAC STREET LOC MID-WAY BETWEEN CARPENTER ST & NOVI ST WHICH RUNS NORTH & SOUTH FROM HILL ST TO MAPLEWOOD ST ADJ TO SAME 6-21-84 FR 014 & 015 7-1-19 COR ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 401 Res|dential PRIOR YEAR'S CLASSIFICATION 401 Residential CHANGE FROM PRIOR AMOUNT CURRENT TENTATIVE PRIOR YEAR TO YEAR 2025 YEAR 205 | CURRENT YEAR 1_ TAXABLE VALUE 565.610 2 ASSESSED VALUE 762,800 3_TENTATIVE EQUALIZATION FACTOR 1000 ‘ sari Seis $5 Avenir A ines 4 STATE EQUALIZED VALUE (SEV) 762,800 [ 825,200] 5 WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [Yes 6. Assessor Change Reason(s): Market Adjustment The 2026 Inflation rate Multiplier is. 1.027 Questions regarding the Notice of Assessment, Taxable Valuation. and Property Classification may be directed to the Following Nara Teorons Namba: mad AdGress. BENJAMIN GRIFFIN (248) 305-2704 BGRIFFIN@CI NORTHVILLE MI US March Board of Review Appeal Information. The Board of Review will meet at the following dates and times. THE MARCH BOARD OF REVIEW WILL MEET THE FOLLOWING DATES FOR THE ORGANIZATIONAL MEETING AND FOR APPEALS TUESDAY, MARCH 3,2026 900 AM ORGANIZATIONAL MEETING (NO APPEALS) TUESDAY, MARCH 10, 2026 900AM TO 1200PM AND 100PM TO S500 PM THURSDAY, MARCH 12, 2026 300PM TO 500PM ANDGOOPM TOSO00PM MAIL-IN PETITIONS MUST BE RECEIVED BY MARCH 12. 2026 BEFORE 4 00 PM [TIS REQUESTED THAT APPOINTMENTS BE SCHEDULED PRIOR TO TUESDAY, MARCH 11, 2026 248-449-9901
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Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR PROPERTY TAX APPEAL PETITION FORM VALUATION / EXEMPTION / CLASSIFICATION APPEAL MOAHR DOCKET NO. 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 held in default. Section 1: Petitioner’s Contact Information Filer Type: Individual First Name Michael M.I. Last Name/Company Name Guthrie Mailing Address (No., Street, P.O. Box or Rural Route) 429 Hill Street City or Town Northville State Michigan ZIP Code 48167 Telephone Number 2483467142 Fax Number E-mail Address mguthrie@in-formstudio.com Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information First Name M.I. Last Name Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone Number Fax Number E-mail Address Section 3: Subject Property Information How many parcels are you appealing? 1 If you are appealing more than one parcel, are they contiguous or adjoining? *If no, you must file separate appeals for each non-contiguous or non-adjoining parcel. Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 429 Hill Street
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Northville Michigan 48167 Taxing Authority (City or Township) City Of Northville (OAKLAND) County Oakland Section 4: Issues Being Appealed (check all that apply) Taxable Value Only (calculation) Section 5: Explain the Reason for this Appeal I am appealing the 2026 assessed value assigned to my property at 429 Hill Street (Parcel ID 48-42-34-406-018) because the current assessed value is significantly higher than market evidence supports for homes of similar size, condition, and location in the 48167 zip code. My home has 3,379 square feet of finished living area, yet the assessor’s implied market value of approximately $1,650,400 (based on the 2026 assessed value of $825,200 × 2), with a value of $488/sf. This exceeds market indicators for comparable homes of similar size north of 8 Mile between Beck Road and Meadowbrook Road. Comparable Sales Evidence: Recent sales in 48167 demonstrate a wide range of prices that, when adjusted for size, location, and condition, suggest that the assessor’s valuation may overstate fair market value: • 49825 9 Mile Rd, Northville MI 48167 sold in mid-2025 for $1,650,000 with ~4,572 sq ft (~$361 per sq ft). This home is larger and newer than mine, and a value of ~$361/sq ft should not be extrapolated to my home without adjustments for age, lot, finishes, and condition. • 900 Andover Dr (~3,494 sq ft) sold in mid-2025 for $779,900 (~$223 per sq ft). • 39502 Danielle Dr (~3,026 sq ft) sold for $676,000 (~$223/sq ft). • 21929 Heatheridge Ln (~3,046 sq ft) sold for $621,000 (~$204/sq ft). • 655 Randolph St Unit 103 (~3,619 sq ft) sold for $1,180,000 (~$326/sq ft). Based on these recent 2025 sales, homes close in size to mine generally show price per square foot outcomes lower than the assessor’s implied value, even for premium homes, especially after accounting for location differences and site characteristics. Market Trends & Neighborhood Context: In the 48167 area, the median sales price for homes in the past year has been approximately $540,000, with a typical average home size of about 2,389 sq ft, reflecting the broader market baseline. Conclusion: Given the inconsistency between the current assessed value and actual market evidence from comparable sales, I respectfully request that the assessor reconsider the valuation, adjust the assessed value downward to reflect a more accurate market value based on these comparables, and verify that square footage and property characteristics used for assessment are correct. Section 6: Jurisdictional Issues Year(s) you are appealing: 2025, 2026 Did you protest the assessment at a Board of Review (BOR)? No If Yes, check which BOR you attended AND upload the BOR decision: If No, check the applicable reason(s): Not required to attend Did you request a Poverty Exemption at the BOR? If Yes, check which BOR considered your application AND upload the BOR decision: March July December If No, explain why:
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Section 7: Valuation Information *Use the multiple parcel form for additional, contiguous parcels. Parcel Identification Number: 48-42-34-406-018 Classification of Property: Personal Residential Current Assessed Value (also known as State Equalized Value) as established by the BOR: 825200 Current Taxable Value as established by the BOR: 580881 What do you believe is the fair market value (also known as True Cash Value)? 1050000 Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 525000 If you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 388500 Section 8: Classification Information *Only the MI Dep’t of Treasury may appeal this issue to the Tribunal* Parcel Identification 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 Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition? Yes Are
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STAT
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.