Pacific Petc-Roseville, LLC Petitioner Vs. City Of Roseville Respondent

Page 1

STATE OF MICHIGAN 

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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

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

Pacific PETC-Roseville LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000971 

 

City of Roseville, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has considered the file in this case and the submitted Stipulation for Entry 

of Consent Judgment (Stipulation) and finds that the Stipulation meets all filing and 

statutory requirements.1 As such, the Tribunal shall enter the 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 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 26-000971 

Page 2 of 2 

 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

(xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%, and (xx) after 

July 1, 2026, through December 31, 2026, at a rate of 7.85%. 

 

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. 

 

 

Entered: September 29, 2026 

 

 

 

By: /s/ Jason C. Grinnell_ 

gc 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Pacific PETC-Roseville, LLC, 

Vv 

Petitioner, 

MTT Docket No. 26-000971-TT 

City Of Roseville, 

Respondent. 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

The case is pending in the Entire Tribunal. 

2. 

The property is in Macomb County. 

3. 

The values for the property identified above as established by Respondent’s Board of 

Review are: 

Year 

Parcel 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

08-14-04-276-029 

$ 1,409,800 

$704,900 

$626,486 

4. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Year 

Parcel 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

08-14-04-276-029 

$1,080,000 

$540,000 

$540,000 

S. 

This stipulation addresses only the tax year that was originally appealed, and tax years 

added through motions to amend.

Page 2

MTT Docket No. 26-000971-TT 

Entire Tribunal Stipulation, Page 2 of 2 

6. 

Refund (as applicable) is to be made payable to “Pacific PETC-Roseville, LLC” and 

mailed to the attention of: 

Pacific PETC-Roseville, LLC 

c/o Sarah Belloli, Ryan, LLC 

101 W. Big Beaver Road, Suite 945 

Troy, MI 48084 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Sarah R. Belloli, Ryan, LLC 

Date: 09/14/2026 

Signature of Respondent’s authorized representative: 

i 

77 

re 

Timothy D. Tomlinson (B48519), Tomlinson & McGrail, PLLC 

Date: 

Gt YC

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000971

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

Party Filing Document 

Joint

Files

Document Type: Stip for Consent Judgment

Attachment File Name: Pacific PETC Roseville MI PT 2026 26-000971 Joint Stipulation Consent 

Judgment 2026-09-14 FULLY EXECUTED

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PACIFIC PETC-ROSEVILLE, LLC, 

Petitioner, 

vs. 

MTT Docket No. 26-00971 

CITY OF ROSEVILLE, 

Respondent. 

Sarah R. Belloli 

Timothy D. Tomlinson (P48519) 

Matthew Dingman 

Tomlinson & McGrail, PLLC 

Ryan, LLC 

22600 Hall Rd, Ste. 102 

Representatives for Petitioner 

Clinton Township, MI 48036 

101 West Big Beaver Rd, Ste 945 

586-263-5050 

Troy, MI 48084 

ttomlinson@ttlmlaw.com 

313-230-0104 

Sarah. belloli@ryan.com 

RESPONDENT’S ANSWER TO PETITION 

NOW COMES the Respondent, City of Roseville, by and through its attorneys, 

Tomlinson & McGrail, PLLC, and in answer to Petitioner=s Petition, states as follows: 

1. 

Respondent admits paragraph 1. 

2. 

Respondent admits paragraph 2. 

3. 

Not applicable. 

4. 

Not applicable. 

5. 

Not applicable. 

6. 

Respondent admits paragraph 6. 

7. 

Respondent admits paragraph 7. 

8. 

Not applicable. 

9. 

Not applicable.

Page 2

10. 

11. 

12. 

13. 

14. 

1s. 

16. 

17. 

18. 

19. 

20. 

Respondent admits paragraph 10. 

Respondent admits paragraph 11. 

Respondent neither admits nor denies paragraph 12 being without sufficient 

information to form a reasonable belief thereto. 

Respondent denies paragraph 13 because it is untrue. 

Respondent admits paragraph 14. 

Not applicable. 

Respondent admits paragraph 16. 

Respondent denies paragraph 17 because it is untrue. 

Respondent denies paragraph 18 because it is untrue. 

Respondent denies paragraph 19 because it is untrue. 

Respondent denies paragraph 20 because it is untrue. 

A. 

Respondent denies paragraph A because it is untrue. 

B. 

Respondent denies paragraph B because it is untrue. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss 

the Petition, affirm the values as determined by Respondent, and award costs and attorney fees 

wrongfully incurred in having to defend this matter. 

By: {"} Overnight 

Courie 

[3 Hand Dejidered 

Mail 

Respectfully submitted, 

TOMLINSON & McGRAIL, PLLC 

/s/Timothy D. Tomlinson 

CERTIFICATE OF SERVICE 

Timothy D. Tomlinson (P48519) 

~4 cartfiies that the foregoing inci 

VE 

22600 Hall Rd, Ste. 102 

Clinton Township, MI 48036 

586-263-5050 

ttomlinson@ttlmlaw.com 

Dated: August 27, 2026

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PACIFIC PETC-ROSEVILLE, LLC, 

Petitioner, 

vs. 

MTT Docket No. 26-00971 

CITY OF ROSEVILLE, 

Respondent. 

Sarah R. Belloli 

Timothy D. Tomlinson (P48519) 

Matthew Dingman 

Tomlinson & McGrail, PLLC 

Ryan, LLC 

22600 Hall Rd, Ste. 102 

Representatives for Petitioner 

Clinton Township, MI 48036 

101 West Big Beaver Rd, Ste 945 

586-263-5050 

Troy, MI 48084 

ttomlinson@ttimlaw.com 

313-230-0104 

Sarah.belloli@ryan.com 

RESPONDENT’S AFFIRMATIVE DEFENSES 

NOW COMES the Respondent, City of Roseville, by and through its attorneys, York, 

Dolan & Tomlinson, P.C., and for its Affirmative Defenses, states as follows: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of 

law, discrimination, the application of wrong principles or illegality on the part of 

the Respondent. 

3. 

Petitioner fails to allege that the mode and method of appraising its property 

failed to conform to the mode and method applied in the case of all of the 

properties in the Respondent’s taxing unit for the year in question.

Page 4

10. 

Petitioner fails to allege specific and sufficient facts to establish the true cash 

value, assessed value and taxable value of its property. 

Petitioner fails to allege specific and sufficient facts to support its allegation that 

the assessed value of its property, as equalized, is at a factor other than 50% and 

also fails to allege specific and sufficient facts to support is allegations that that 

the property’s taxable value is improper. 

Petitioner fails to show that any rate other than 50% after equalization was 

applied to the true cash value of its property, as well as to the properties of all 

others to arrive at the respective equalized assessments. 

Petitioner, in essence, asks that this Honorable Tribunal grant it an illegal 

preference by application of a method of assessment different from that employed 

in the assessment of other properties in the Respondent’s taxing unit. 

Petitioner, in essence, seeks by Petition to challenge the process of county and 

state equalization as to the which it has no legal standing and cannot maintain a 

cause of action. 

Any decrease in the value of Petitioners property was a result of its own 

intentional acts and/or negligence and cannot be allowed to reduce Petitioner’s 

otherwise equitable tax burden. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in accordance with statutory and constitutional 

requirements.

Page 5

11. 

Respondent reserves the right to add to these Affirmative Defenses any new 

Affirmative Defenses that discovery reveals. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss 

the Petition, affirm the values as determined by Respondent, and award costs and attorney fees 

wrongfully incurred in having to defend this matter. 

Respectfully submitted, 

TOMLINSON & McGRAIL, PLLC 

/s/Timothy D. Tomlinson 

Timothy D. Tomlinson (P48519) 

22600 Hall Rd, Ste. 102

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000971

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Roseville (MACOMB)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Timothy

M.I.

D

Last Name

Tomlinson

Firm Name (if any)

Tomlinson & McGrail, PLLC

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

22600 Hall Road

Suite 102

City or Town

Clinton Township

State

 Michigan

ZIP Code

48036

Telephone Number

5862635050

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

ttomlinson@ttlmlaw.com

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

Timothy D. Tomlinson

/s/

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Page 1

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Tel. (313) 230-0104 

RREEN 

ED 

July 13, 2026 

JUL 15 2026 

State of Michigan Treasurer 

Treasury Building, 430 West Allegan Street 

Lansing, MI 48922 

MICHIGAN TAX TRIBUNAL 

Re: Pacific PETC-Roseville, LLC v City of Roseville 

MTT Docket No.: 26-000971 

Dear Chief Clerk: 

Petitioner hereby serves all parties provided for in Michigan Tax Tribunal Rule 221 with its petition in 

this matter. Pursuant to the rule, the petition notes the docket number assigned by the Tribunal and is 

served within 45-days of the issuance of the notice of docket number. 

If you have any questions regarding the enclosed pleading, please do not hesitate to contact our office 

directly at (313) 230-0104. 

Respectfully, 

Sarah R. Belloli 

Ryan, LLC 

cc: 

State of Michigan Treasurer 

Roseville Community Schools 

Macomb County Equalization Director 

Macomb County Clerk 

CITY OF ROSEVILLE Assessor 

CITY OF ROSEVILLE Clerk 

Enclosures

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

Pacific PETC-Roseville, LLC, 

MTT Docket No.: 26-000971 

Petitioner, 

v 

City of Roseville, 

Respondent. 

Proof of Service 

Joan Kleiner, being duly sworn, deposes and says that on July 13, 2026, she served a copy of the Petition with noted 

docket number relative to the above-captioned matter upon the following parties as required by the Tribunal’s 

service rules: 

VIA CERTIFIED MAIL 

CITY OF ROSEVILLE Assessor: 

City of Roseville Assessor, 29777 Gratiot Ave, Roseville, MI 48066 

CITY OF ROSEVILLE Clerk: 

City of Roseville Clerk, 29777 Gratiot Ave, Roseville, MI 48066 

VIA FIRST-CLASS MAIL 

Macomb County Equalization Director: 

Macomb County Equalization Director, 

1 S Main St, Mount Clemens, MI 48043 

Macomb County Clerk: 

Macomb County Clerk, 

1 S Main St, Mount Clemens, MI 48043 

Roseville Community Schools —— School Board Secretary: 

Roseville Community Schools, 18975 Church St, Roseville, MI 48066 

‘Treasurer of the State of Michigan: 

State of Michigan Treasurer, Treasury Building, 430 West Allegan Street, Lansing, MI 48922 

With proper postage affixed thereto. Proof of service submitted within 45 days after issuance of the notice of docket number as 

required by the Tribunal’s service rules. 

/s/ Joan Kleiner 

Joan Kleiner 

July 13, 2026

Page 3

101 West Big Beaver Road 

Suite 945 

Ryan )) 

Troy, Michigan 48084 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

R €Ceiveq 

JL 15 ggg 

LAR

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.

Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND 

REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

Pacific PETC-Roseville, LLC, 

Petitioner(s) 

v 

City of Roseville, 

Respondent(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

26- 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. Property Parcel No: 08-14-04-276-029 

2. The property identified above is ☑ real ☐ personal. 

3. If more than one parcel of real property is under appeal, are the properties 

contiguous? ☐ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.) 

N/A 

4. Are all of the parcels of personal property located on a parcel of real property under 

appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not 

located on a parcel of real property under appeal.) 

N/A 

5. If parcels of personal property are under appeal, when were the personal property statements filed by 

parcel number (attach additional page if necessary): 

N/A 

6. The property identified above is classified as 201 Commercial-Improved 

7. If the assessment or assessments at issue were protested, the protest was made to 

Respondent’s ☐ March ☐ July ☐ December Board of Review. 

No protest to the Board of Review was required. 

 

 

 

 

 

 

 

 

 

 

 

 

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

Page 2

MTT Docket No. 26- 

Page 2 of 4 

8. If a protest was required and no protest was made, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach 

additional page if necessary): 

N/A 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or 

classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate 

and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

N/A 

10. The property or properties at issue are located in Macomb County. The property’s address is: 

32074 Gratiot Ave, Roseville, MI 48066 

11. The assessment or assessments at issue were established by the (applicable local governmental unit): 

City of Roseville 

12. Petitioner’s legal residence or principal office address is: 

PO Box 25991, Los Angeles, CA 90025 

13. This appeal involves issues relating to the (check all that are applicable): 

☑ the property or properties’ true cash and taxable values 

☐ the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or 

loss? ☐ Yes ☐ No 

☐ uniformity of the property or properties’ assessment 

☐ the property or the properties’ exemption from ad valorem taxation under MCL ______ 

14. The tax year(s) at issue are: 2026

Page 3

MTT Docket No. 26- 

Page 3 of 4 

15. If more than the current tax year is being appealed, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page 

if necessary): 

N/A 

16. The values for the property identified above as established by Respondent’s Board of Review are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$1,409,800 

$704,900 

$626,486 

17. Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$1,000,000 

$500,000 

$500,000 

18. The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$409,800 

$204,900 

$126,486 

19. Petitioner requests the following relief (attach additional page if necessary): 

Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026 

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set 

forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess 

of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just 

and equitable. 

20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach 

additional page if necessary): 

A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash 

value in violation of the applicable statutory and constitutional limitations. 

B. The assessment is based on improper or inaccurate valuation methodology, including but not 

limited to the use of non-representative data, failure to account for relevant property characteristics, 

and/or application of incorrect assumptions. As a result, the assessment is not uniform with 

comparable properties and results in an excessive and unlawful tax burden.

Page 4

MTT Docket No. 26- 

Page 4 of 4 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Sarah R. Belloli 

Email Address: 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

Mailing Address: 

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Telephone Number:

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Pacific PETC-Roseville, LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

Ryan LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

32074 Gratiot Ave

Roseville

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48066

Taxing Authority (City or Township)

City Of Roseville (MACOMB) 

County

Macomb

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

08-14-04-276-029

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

704900

Current Taxable Value as established by the Board of Review:

626486

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

1000000

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

500000

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

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Sarah R. Belloli

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051285024010

Supporting Waiver Documents:

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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

Pacific PETC-Roseville, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000971

City Of Roseville, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: June 24, 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

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.

Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND 

REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

Pacific PETC-Roseville, LLC, 

Petitioner(s) 

v 

City of Roseville, 

Respondent(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

26- 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. Property Parcel No: 08-14-04-276-029 

2. The property identified above is ☑ real ☐ personal. 

3. If more than one parcel of real property is under appeal, are the properties 

contiguous? ☐ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.) 

N/A 

4. Are all of the parcels of personal property located on a parcel of real property under 

appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not 

located on a parcel of real property under appeal.) 

N/A 

5. If parcels of personal property are under appeal, when were the personal property statements filed by 

parcel number (attach additional page if necessary): 

N/A 

6. The property identified above is classified as 201 Commercial-Improved 

7. If the assessment or assessments at issue were protested, the protest was made to 

Respondent’s ☐ March ☐ July ☐ December Board of Review. 

No protest to the Board of Review was required. 

 

 

 

 

 

 

 

 

 

 

 

 

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

Page 2

MTT Docket No. 26- 

Page 2 of 4 

8. If a protest was required and no protest was made, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach 

additional page if necessary): 

N/A 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or 

classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate 

and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

N/A 

10. The property or properties at issue are located in Macomb County. The property’s address is: 

32074 Gratiot Ave, Roseville, MI 48066 

11. The assessment or assessments at issue were established by the (applicable local governmental unit): 

City of Roseville 

12. Petitioner’s legal residence or principal office address is: 

PO Box 25991, Los Angeles, CA 90025 

13. This appeal involves issues relating to the (check all that are applicable): 

☑ the property or properties’ true cash and taxable values 

☐ the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or 

loss? ☐ Yes ☐ No 

☐ uniformity of the property or properties’ assessment 

☐ the property or the properties’ exemption from ad valorem taxation under MCL ______ 

14. The tax year(s) at issue are: 2026

Page 3

MTT Docket No. 26- 

Page 3 of 4 

15. If more than the current tax year is being appealed, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page 

if necessary): 

N/A 

16. The values for the property identified above as established by Respondent’s Board of Review are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$1,409,800 

$704,900 

$626,486 

17. Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$1,000,000 

$500,000 

$500,000 

18. The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$409,800 

$204,900 

$126,486 

19. Petitioner requests the following relief (attach additional page if necessary): 

Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026 

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set 

forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess 

of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just 

and equitable. 

20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach 

additional page if necessary): 

A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash 

value in violation of the applicable statutory and constitutional limitations. 

B. The assessment is based on improper or inaccurate valuation methodology, including but not 

limited to the use of non-representative data, failure to account for relevant property characteristics, 

and/or application of incorrect assumptions. As a result, the assessment is not uniform with 

comparable properties and results in an excessive and unlawful tax burden.

Page 4

MTT Docket No. 26- 

Page 4 of 4 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Sarah R. Belloli 

Email Address: 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

Mailing Address: 

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Telephone Number:

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.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Pacific PETC-Roseville, LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

Ryan LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

32074 Gratiot Ave

Roseville

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48066

Taxing Authority (City or Township)

City Of Roseville (MACOMB) 

County

Macomb

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

08-14-04-276-029

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

704900

Current Taxable Value as established by the Board of Review:

626486

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

1000000

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

500000

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

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Sarah R. Belloli

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051285024010

Supporting Waiver Documents:

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