Pnc Bank National Association, Petitioner Vs. City Of Fraser, 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

PNC Bank National Association, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001811

City Of Fraser,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: July 20, 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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

PNC Bank National Association, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001811

City Of Fraser,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: July 20, 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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

PNC BANK, NATIONAL ASSOCIATION 

 

 

Petitioner, 

 

 

MTT Docket No. 25-001811 

v. 

 

CITY OF FRASER 

 

 

Respondent. 

 

AD VALOREM PARTNERS, LLC 

Scott Aston 

Petitioner’s Representative 

21446 Columbine Court 

Grosse Ile, MI 48138 

(734) 731-0558 

aston@advalpartners.com 

CITY OF FRASER 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

JOINT MOTION TO WITHDRAW APPEAL 

 

Petitioner and Respondent, by and through their representative and attorneys, desire to withdraw 

this matter pursuant to Tax Tribunal Rule 231(4), R 792.10237(4) with no costs to either party. 

Respectfully Submitted, 

Scott Aston 

Laura M. Hallahan 

Representative for Petitioner, 

Attorney for Respondent, 

 

 

By:/s/Scott Aston 

 

By:/s/Laura M. Hallahan_____ 

 

 

Dated: July 18, 2026 

 

Dated: July 18, 2026

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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: 25-001811

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

Party Filing Document 

Joint

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Joint Motion to Withdraw- PNC Fraser MTT 25-001811

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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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

NOTICE OF NOVEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

PNC Bank National Association,

Petitioner,

v

 

 

City Of Fraser,

Respondent.

 MTT Docket No. 25-001811

Please be advised that 25-001811 has been placed on a two-week Prehearing General 

Call commencing November 16, 2026. Unless ordered otherwise, parties will be 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 25-001811

Page 2 of 3

IT IS ORDERED that the parties shall:

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

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

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

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

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

by July 20, 2026. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

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

Statements by July 20, 2026. Witnesses, with the exception of rebuttal witnesses, will 

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

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

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

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

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

July 20, 2026, which means all discovery has been requested, all Motions to Compel 

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

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

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

Page 3

MT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

PNC Bank, National Association, 

 

 

 

Petitioner, 

 

v 

 

City of Fraser, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001811 

 

Parcel No. 03-14-05-177-016 

 

_____________________________________________________________________________/ 

 

SCOTT ASTON 

Representative for Petitioner 

21446 Columbine Court 

Grosse Ile, MI 48138 

(734) 731-0558 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Fraser, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1 as to parcel number and property 

address. Respondent lacks the information and knowledge necessary to respond to the remainder 

of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

2

4. 

Respondent admits the statement that the subject property is classified as 

commercial real. Respondent lacks the information and knowledge sufficient to respond to the 

remainder of the allegations set forth in Paragraph 4 and, therefore, leaves Petitioner to its proofs. 

5. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief. 

6. 

Respondent neither admits nor denies the allegations in Paragraph 6 for the reason 

that the Geneal Property Tax Act speaks for itself. 

7. 

Respondent denies the allegations in Paragraph 7, including subparagraphs (a)-(d), 

as untrue. Furthermore, the assessed, state equalized, and/or taxable values do not exceed permitted 

amounts, do not exceed the percentage for true cash value permitted by law, were correctly 

determined and are based upon correct application of proper principles; and the values and 

Respondent’s mode of assessment are non-discriminatory and constitutional. 

8. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

 

WHEREFORE, Respondent, City of Fraser, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees.

Page 3

3

 

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated September 18, 2025 

 

 

 

(258) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Fraser, asserts the following affirmative defenses: 

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. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

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

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to

Page 4

4

res

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001811

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Fraser (MACOMB)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN O F F I C E O F ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

PNC Bank, National Association, 

Petitioner, 

v. 

 MTT Docket No. 25-001811 

 

 

 

City of Fraser, 

Respondent. 

/ 

PROOF OF SERVICE 

The undersigned states that on September 8, 2025, he mailed a copy of the Property Tax 

Petition in the above matter by certified mail to: 

 

Fraser Assessor, 33000 Garfield, PO Box 10, Fraser MI 48026 

Fraser Clerk, 33000 Garfield, PO Box 10, Fraser MI 48026 

 

And by first-class mail to: 

School District Secretary, 33466 Garfield Road, Fraser, MI 48026 

Macomb County Clerk, Krycia Adm Bldg, 1 S. Main St, 8th Floor Mt. Clemens, MI 48043 

Macomb County Equalization Director, Krycia Adm Bldg, 1 S. Main St, 8th Floor Mt. Clemens, MI 

48043 

 

Treasurer, State of Michigan, 430 West Allegan, Lansing, MI 48922 

 

By affixing proper postage and mailing from a U.S. mailbox in Grosse Ile, Michigan. 

 

 

 

 

 

 

 

 

 

 

 

 

 

______________________________ 

 

 

 

 

 

 

Scott Aston

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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

PNC Bank National Association, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001811

City Of Fraser,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that Petitioner 

was held in default on July 23, 2025, and the default has been timely cured. The 

documents curing the default can be reviewed through the docket search function on 

the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and 

clicking on the document link next to the line item entry for the documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 13, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

PNC Bank National Association, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001811

City Of Fraser,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that Petitioner 

was held in default on July 23, 2025, and the default has been timely cured. The 

documents curing the default can be reviewed through the docket search function on 

the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and 

clicking on the document link next to the line item entry for the documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 13, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

RECEIVED 

AUG 06 2025 

STATE OF MICHIGAN 

MICHIGAN Tax TRIRU 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 1. BROWRI, 

DIA 

GOVERNOR 

LANSING 

DIRECTOR 

PNC Bank National Association, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

v 

MTT Docket No. 25-001811 

0) 

§ 

; 

City Of Fraser, 

% 

A 

£7) x ] 

Respondent. 

| 

fi oS 

ORDER OF DEFAULT 

| 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

Petitioner did not pay the full required fee for the filing of the petition. See TTR 223. As 

such, the appeal is not properly pending. See TTR 225. Petitioner must pay the 

additional fee amount required for the filing of the petition within 14 days of the entry of 

this order. Tribunal rules and information on filing fees can be found on our website at 

www.michigan.govitaxtrib. Unfortunately, the payment may not be made via e-filing. 

Therefore, 

IT IS ORDERED that Petitioner is HELD IN DEFAULT. 

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.’ 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee). 

) 

. 

TR 

By: Caley 

oe Nad mn 

Entered: July 23, 2025 

Patricia L. Halm, Tribunal Chair 

PROOF OF SERVICE 

| 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.

Page 2

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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

PNC Bank National Association,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001811

City Of Fraser,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner did not pay the full required fee for the filing of the petition. See TTR 223. As 

such, the appeal is not properly pending. See TTR 225. Petitioner must pay the 

additional fee amount required for the filing of the petition within 14 days of the entry of 

this order. Tribunal rules and information on filing fees can be found on our website at 

www.michigan.gov/taxtrib. Unfortunately, the payment may not be made via e-filing.

Therefore,

IT IS ORDERED that Petitioner is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: July 23, 2025

Patricia L. Halm, Tribunal Chair

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

i “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by

Page 2

MTT Docket No. 25-001811

Page 2 of 2

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

PNC Bank, National Association, 

Petitioner, 

v. 

MTT Docket No. 

 

 Parcel No. 03-14-05-177-016 

City of Fraser, 

 

 

 

 

 

 

Respondent. 

/ 

 

 

PETITION 

PNC Bank, National Association ("Petitioner"), through its representatives, AD VALOREM 

PARTNERS LLC, says: 

 

Petitioner's principal office address is 300 Fifth Avenue, Pittsburgh, PA 15222-2719. 

Petitioner is a party in interest with respect to property taxes on tax parcel no. 03-14-05-177-016 ("Petitioner's 

Property"), at 32001 Groesbeck Hwy, Fraser, Michigan 48026. 

2. 

Respondent, City of Fraser, assesses and collects property taxes on Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of parcel number 03-14-05-177-016 to 

be $503,973 and the assessed value to be $619,600, which will result in a state equalized value in the same 

amount based upon the tentative equalization factor. 

4. 

Petitioner’s Property is classified as Commercial Real. Petitioner's Property is presently 

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

used for Commercial purposes.

Page 2

5. 

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

(d) uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

The 2025 assessment, including state equalized value and taxable value, imposed on 

Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate 

as a fraud upon the taxpayer for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, exceed the 

amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable statutes; 

(c) 

The assessment, including state equalized value, are based upon erroneous 

determinations of the true cash value of that portion of Petitioner's Property that is taxable under 

Michigan law, and is based upon the application of wrong principles; and, 

(d) 

The assessment, including state equalized value, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights 

to uniformity, equal protection and due process of law.

Page 3

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 2025 

taxable value of parcel number 03-14-05-177-016 from $503,973 to $250,000, and reducing the 2025 

assessed value and state equalized value from $619,600 to $250,000; and (ii) awarding Petitioner any other 

relief to which it is entitled. 

Respectfully submitted, 

 

 

 

 AD VALOREM PARTNERS LLC 

 

 

 

 Petitioner’s Representative 

 

 

 

 

 

 

 

 

 

 

 

 By:_________________________ 

 

 

 

 

Scott Aston 

 

 

 

 

21446 Columbine Court 

 

 

 

 

Grosse Ile, MI 48138 

 

 

 

 

(734) 731-0558 

 

 

 

 

aston@advalpartners.com 

Dated: May 29, 2025

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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

PNC Bank National Association, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001811

City Of Fraser, 

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 23, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

PNC Bank, National Association, 

Petitioner, 

v. 

MTT Docket No. 

 

 Parcel No. 03-14-05-177-016 

City of Fraser, 

 

 

 

 

 

 

Respondent. 

/ 

 

 

PETITION 

PNC Bank, National Association ("Petitioner"), through its representatives, AD VALOREM 

PARTNERS LLC, says: 

 

Petitioner's principal office address is 300 Fifth Avenue, Pittsburgh, PA 15222-2719. 

Petitioner is a party in interest with respect to property taxes on tax parcel no. 03-14-05-177-016 ("Petitioner's 

Property"), at 32001 Groesbeck Hwy, Fraser, Michigan 48026. 

2. 

Respondent, City of Fraser, assesses and collects property taxes on Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of parcel number 03-14-05-177-016 to 

be $503,973 and the assessed value to be $619,600, which will result in a state equalized value in the same 

amount based upon the tentative equalization factor. 

4. 

Petitioner’s Property is classified as Commercial Real. Petitioner's Property is presently 

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

used for Commercial purposes.

Page 2

5. 

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

(d) uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

The 2025 assessment, including state equalized value and taxable value, imposed on 

Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate 

as a fraud upon the taxpayer for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, exceed the 

amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable statutes; 

(c) 

The assessment, including state equalized value, are based upon erroneous 

determinations of the true cash value of that portion of Petitioner's Property that is taxable under 

Michigan law, and is based upon the application of wrong principles; and, 

(d) 

The assessment, including state equalized value, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights 

to uniformity, equal protection and due process of law.

Page 3

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 2025 

taxable value of parcel number 03-14-05-177-016 from $503,973 to $250,000, and reducing the 2025 

assessed value and state equalized value from $619,600 to $250,000; and (ii) awarding Petitioner any other 

relief to which it is entitled. 

Respectfully submitted, 

 

 

 

 AD VALOREM PARTNERS LLC 

 

 

 

 Petitioner’s Representative 

 

 

 

 

 

 

 

 

 

 

 

 By:_________________________ 

 

 

 

 

Scott Aston 

 

 

 

 

21446 Columbine Court 

 

 

 

 

Grosse Ile, MI 48138 

 

 

 

 

(734) 731-0558 

 

 

 

 

aston@advalpartners.com 

Dated: May 29, 2025

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

PNC Bank, National Association

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

21446 Columbine Ct

City or Town

Grosse Ile

State

Michigan

ZIP Code

48138

Telephone Number

7347310558

Fax Number

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

aston@advalpartners.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Scott

M.I.

Last Name

Aston

Firm Name (if any)

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

21446 Columbine Court

City or Town

Grosse Ile

State

Michigan

ZIP Code

48138

Telephone Number

734-731-0558

Fax Number

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

aston@advalpartners.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

32001 Groesbeck Hwy

Fraser

Michigan

48026

Taxing Authority (City or Township)

City Of Fraser (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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

03-14-05-177-016

Classification of Property: Real 

Commercial

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

69600

Current Taxable Value as established by the Board of Review:

503973

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

500000

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

250000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

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

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

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

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