Pmg Jsj Partners LLC Petitioner Vs. City Of Muskegon Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

PMG JSJ Partners LLC,

Petitioner,

v

 

 

City Of Muskegon,

Respondent.

 MTT Docket No. 26-001004

Please be advised that 26-001004 has been placed on a two-week Prehearing General 

Call commencing July 01, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 26-001004

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by March 4, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by March 4, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 4, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

July 1, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 3, 2026

Page 3

MTT Docket No. 26-001004

Page 3 of 3

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 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

PMG JSJ

Page 5

MTT

Page 6

MTT

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

[8] fof 

Visit601 Terrace Street, Muskegon, M1 48440 

Ey ED 

PA R M F N T B R 

Mail PO Box 786, Muskegon, 

MI 43443-0786 

Web www.parmenterlaw.com 

JUN 

1 5 207 “ 

[41] 

d 

2 = 

MICHIGAN TAX TRIBUNAL 

June 12, 2026 

Michigan Tax Tribunal 

SENT VIA FIRST-CLASS MAIL 

P.0. Box 30232 

Lansing, MI 48909 

Re: 

PMG JS] PARTNERS LLC v CITY OF MUSKEGON 

MTT Docket No. 26-001004 

Dear Clerk: 

Enclosed for filing please find: 

1. 

Answer to Petition; 

2. 

Affirmative Defenses; and 

3. 

Proof of Service 

Should you have any questions or require additional information please do not hesitate to 

contact our office. 

Thank you. 

Very truly yours, 

J cop le Osten) 

Taylor Anderson 

Legal Assistant 

= - 

Direct P: (231) 722-5428 

== 

Direct F: (231) 722-5528 

Email: taylor@parmenterlaw.com 

Enclosures

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

& kk 

PMG JSJ PARTNERS LLC, 

MTT Docket No. 26-001004 

Petitioner, 

Parcel No. 24-230-003-0008-00 

v 

CITY OF MUSKEGON, 

Respondent. 

/ 

Jackie J. Cook (P68781) 

Brennen J. Gorman (P80958) 

HONIGMAN LLP 

PARMENTER LAW 

Attorneys 

for Petitioner 

Attorneys for Respondent 

2290 First National Building 

601 Terrace Street, PO Box 786 

660 Woodward Avenue 

Muskegon, MI 49443-0786 

Detroit, MI 48226-3506 

(231) 722-1621 

(313) 465-7270 

brennen@parmenterlaw.com 

jcook@honigman.com 

ANSWER TO PETITION 

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

its Answer to Petitioner’s Property Tax Petition states as follows: 

1. 

Admit. 

2. 

Admit. 

3. 

Admit.

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

* kk 

PMG JSJ PARTNERS LLC, 

MTT Docket No. 26-001004 

Petitioner, 

Parcel No. 24-230-003-0008-00 

v 

CITY OF MUSKEGON, 

Respondent. 

/ 

Jackie J. Cook (P68781) 

Brennen J. Gorman (P80958) 

HONIGMAN LLP 

PARMENTER LAW 

Attorneys 

for Petitioner 

Attorneys 

for Respondent 

2290 First National Building 

601 Terrace Street, PO Box 786 

660 Woodward Avenue 

Muskegon, MI 49443-0786 

Detroit, MI 48226-3506 

(231) 722-1621 

(313) 465-7270 

brennen@parmenterlaw.com 

jcook@honigman.com 

AFFIRMATIVE DEFENSES 

NOW COMES respondent, City of Muskegon, who sets forth the following affirmative 

defenses which it may rely on at trial: 

1. 

PMG JSJ Partners LLC is not a proper Petitioner having sold the property on or about May 

30, 2026. 

2. 

The Petitioner’s states use of the property violates the City’s zoning ordinance and/or

Page 4

8. 

Denied. By way of further answer, agricultural operations are not a permitted use. 

9. 

Denied. 

10. Denied. 

11. Neither admit nor deny, as it calls for a legal conclusion. 

12. Denied. 

PARMENTER LAW 

Dated: June =z, 2026 

= 

Brennen J. Gorman (P80958) 

John C. Schrier (P36702) 

Attorneys for Respondent

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

* kk 

PMG JSJ PARTNERS LLC, 

MTT Docket No. 26-001004 

Petitioner, 

Parcel No. 24-230-003-0008-00 

v 

CITY OF MUSKEGON, 

Respondent. 

/ 

Jackie J. Cook (P68781) 

Brennen J. Gorman (P80958) 

HONIGMAN LLP 

PARMENTER LAW 

Attorneys 

for Petitioner 

Attorneys for Respondent 

2290 First National Building 

601 Terrace Street, PO Box 786 

660 Woodward Avenue 

Muskegon, MI 49440-1192 

Detroit, MI 48226-3506 

(231) 722-1621 

(313) 465-7270 

brennen@parmenterlaw.com 

jcook@honigman.com 

PROOF OF SERVICE 

The undersigned certifies that on this 12th day of June 2026, copies of Respondent’s 

Answer to Petition, Affirmative Defenses, and this Proof of Service were served upon the 

Attorney for Petitioner at her address of record via first-class mail. 

Anil woltis rw, 

ylo’Anderson

Page 6

== PARMENTER 

LAW 

PO Box 786, Muskegon, MI 49443-0786 

FIRST-CLASS 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, Mi 48909 

rularthll 

“0 $ 

32890 

J

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Page 1

RECEIVED 

JUN ¢ 1 2026 

' 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

* kk 

PMG JSJ PARTNERS LLC, 

MTT Docket No. 26-001004 

Petitioner, 

Parcel No. 24-230-003-0008-00 

v 

CITY OF MUSKEGON, 

Respondent. 

/ 

Jackie J. Cook (P68781) 

Brennen J. Gorman (P80958) 

HONIGMAN LLP 

PARMENTER LAW 

Attorneys for Petitioner 

Attorneys for Respondent 

2290 First National Building 

601 Terrace Street, PO Box 786 

660 Woodward Avenue 

Muskegon, MI 49440-1192 

Detroit, MI 48226-3506 

(231) 722-1621 

(313) 465-7270 

brennen@parmenterlaw.com 

jcook@honigman.com 

/ 

APPEARANCE 

PLEASE TAKE NOTICE that Brennen J. Gorman, of Parmenter Law, hereby enters his 

appearance on behalf of Respondent, the City of Muskegon. 

Dated: May zy, 2026 

PARMENTER LAW 

By: I 

Ter 

Brennen J. Gorman (P80958) 

Attorneys for Respondent

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

* kk 

PMG JSJ PARTNERS LLC, 

MTT Docket No. 26-001004 

Petitioner, 

Parcel No. 24-230-003-0008-00 

v 

CITY OF MUSKEGON, 

Respondent. 

/ 

Jackie J. Cook (P68781) 

Brennen J. Gorman (P80958) 

HONIGMAN LLP 

PARMENTER LAW 

Attorneys 

for Petitioner 

Attorneys for Respondent 

2290 First National Building 

601 Terrace Street, PO Box 786 

660 Woodward Avenue 

Muskegon, MI 49440-1192 

Detroit, MI 48226-3506 

(231) 722-1621 

(313) 465-7270 

brennen@parmenterlaw.com 

jcook@honigman.com 

PROOF OF SERVICE 

The undersigned certifies that on this ZF day of May 2026, copies of Respondent’s 

Appearance and this Proof of Service were served upon the Attorney for Petitioner at her 

address of record via first-class mail. 

Aetna hed 

Taylor Ahderson 

Legal Assistant for PARMENTER LAW

Page 3

"=2 PARMENTER 

= LAW 

PO Box 786, iiluskegon, MI 49443-0786 

: 

places 

$ 00

= 

0006232890 

MA

FIRST-CLASS 

Michigan Tax Tribunal 

val 

P.O. Box 30232 

9202 

10 NOP 

‘Lansing, MI 48909 

paAposy

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

26-0014 

75539050.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PMG JSJ Partners LLC, 

Petitioner, 

v 

City of Muskegon,

Respondent. 

MTT Docket No. ________ 

Parcel No. 24-230-003-0008-00 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

PMG JSJ Partners LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1.

Petitioner's principal office address is 124 Tustin Avenue, Suite 200, Newport 

Beach, CA 92663. 

2.

The subject real property, parcel number 24-230-003-0008-00, is located at 1823 

Commerce St., Muskegon, MI, in Muskegon County ("Petitioner's Property"). 

3.

Respondent, City of Muskegon, assesses and collects property taxes on Petitioner's 

Property. 

4.

In 2026, Respondent’s Board of Review set the taxable value of Petitioner's 

Property to be $1,530,400 and assessed Petitioner's Property at $1,530,400.

Page 2

2 

75539050.1 

5.

Respondent’s board of review assessing Petitioner’s Property will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

6.

Petitioner's Property is misclassified as commercial real as the Property is used for 

agricultural operations and should be classified agricultural. 

7.

Petitioner's Property is presently used or available for use for agricultural purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

agricultural purposes. 

9.

This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

11.

No board of review protest was required for Petitioner’s Property. 

12.

The 2026 assessment – including the state equalized and taxable values – imposed 

on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode 

of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, 

because they 

(a) 

Exceed amounts permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

(c) 

Are based on the application of wrong principles and an erroneous 

determination of the true cash value of that portion of Petitioner's Property that 

is taxable under Michigan law, if any; and

Page 3

3 

75539050.1 

(d) 

Discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property from 

$1,530,400 to $700,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 15, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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

PMG JSJ Partners LLC

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

124 Tustin Avenue

Suite 200

City or Town

Newport Beach

State

California

ZIP Code

92663

Telephone Number

3134657270

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

(313) 465-7420

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

jcook@honigman.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]

1823 Comerce St

Muskegon

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

49440

Taxing Authority (City or Township)

City Of Muskegon (MUSKEGON) 

County

Muskegon

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:

24-230-003-0008-00

Classification of Property: Real (check one)

Agricultural (check one)

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

1530400

Current Taxable Value as established by the Board of Review:

1530400

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

1400000

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

700000

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

-3

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/ Jackie J. Cook

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051585549885

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

PMG JSJ Partners LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001004

City Of Muskegon, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 13, 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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PMG JSJ Partners LLC, 

Petitioner. , 

_ 

oo 

MTT Docket No. 2 & = ©0 (OQ 

rs 

v 

Parcel No. 24-230-003-0008-00 

City of Muskegon, 

Respondent. 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com 

Proof of Service 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

that on <5 / / 3 [. # 

she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

/s/ Fan SEope he 

Lisa Joseph 

26-0014 

75539050.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

MUSKEGON 

933 TERRACE STREET 

MUSKEGON, MI 49443 

ASSESSOR 

MUSKEGON 

933 TERRACE STREET 

MUSKEGON, MI 49443 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MUSKEGON COUNTY 

141 E. APPLE AVENUE, 2ND FLOOR 

MUSKEGON, MI 49442-3395 

DIRECTOR OF EQUALIZATION 

MUSKEGON COUNTY 

141 E. APPLE AVENUE, 2ND FLOOR 

MUSKEGON, MI 49442-3395 

SECRETARY OF SCHOOL BOARD 

MUSKEGON PUBLIC SCHOOLS 

349 W. WEBSTER AVENUE 

MUSKEGON, MI 49440-1275 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0015 

75539050.1

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Page 1

1 of 1

Docket #: 26-001004

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

26-0014 

75539050.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PMG JSJ Partners LLC, 

Petitioner, 

v 

City of Muskegon,

Respondent. 

MTT Docket No. ________ 

Parcel No. 24-230-003-0008-00 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

PMG JSJ Partners LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1.

Petitioner's principal office address is 124 Tustin Avenue, Suite 200, Newport 

Beach, CA 92663. 

2.

The subject real property, parcel number 24-230-003-0008-00, is located at 1823 

Commerce St., Muskegon, MI, in Muskegon County ("Petitioner's Property"). 

3.

Respondent, City of Muskegon, assesses and collects property taxes on Petitioner's 

Property. 

4.

In 2026, Respondent’s Board of Review set the taxable value of Petitioner's 

Property to be $1,530,400 and assessed Petitioner's Property at $1,530,400.

Page 2

2 

75539050.1 

5.

Respondent’s board of review assessing Petitioner’s Property will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

6.

Petitioner's Property is misclassified as commercial real as the Property is used for 

agricultural operations and should be classified agricultural. 

7.

Petitioner's Property is presently used or available for use for agricultural purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

agricultural purposes. 

9.

This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

11.

No board of review protest was required for Petitioner’s Property. 

12.

The 2026 assessment – including the state equalized and taxable values – imposed 

on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode 

of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, 

because they 

(a) 

Exceed amounts permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

(c) 

Are based on the application of wrong principles and an erroneous 

determination of the true cash value of that portion of Petitioner's Property that 

is taxable under Michigan law, if any; and

Page 3

3 

75539050.1 

(d) 

Discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property from 

$1,530,400 to $700,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 15, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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

PMG JSJ Partners LLC

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

124 Tustin Avenue

Suite 200

City or Town

Newport Beach

State

California

ZIP Code

92663

Telephone Number

3134657270

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

(313) 465-7420

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

jcook@honigman.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]

1823 Comerce St

Muskegon

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

49440

Taxing Authority (City or Township)

City Of Muskegon (MUSKEGON) 

County

Muskegon

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:

24-230-003-0008-00

Classification of Property: Real (check one)

Agricultural (check one)

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

1530400

Current Taxable Value as established by the Board of Review:

1530400

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

1400000

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

700000

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

-3

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/ Jackie J. Cook

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051585549885

Supporting Waiver Documents:

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.