Raed & Sons Holdings LLC, Petitioner Vs. Township Of Pittsfield, Respondent

Page 1

RECEIVED 

AW 

MAR 9 4 2026 

PROPERTY TAX 

MICHIGAN TAX TRIBUNAL 

CONSULTANTS 

YOUR PROPERTY TAX EXPERTS SINCE 1989 

March 18, 2026 

Iraninfo:4é06 

26104722-1 

03/20/26 

| 

Clerk of the Court 

2 

p 

ork 

Chi: 

2555 

mt: $50.00 

Michigan Tax Tribunal 

ID: 

FROFERTY TAX CONSULTANTS 

P.O. Box 30232 

Lansing, MI 48909 

| 

RE: 

Property Tax Consultants for Raed & Sons Holdings LLC 

| 

Parcel # L -12-24-300-007, v. Pittsfield Township 

| 

Docket # 25-002291 

Dear Clerk, 

Regarding the above matter, enclosed please find the STIPULATION TO CONSENT 

JUDGEMENT fully authorized by the petitioner and the respondent. 

We hope that this meets with the approval of the Michigan Tax Tribunal. 

Agent for Raed & Sons Holdings LLC 

JA/ac 

Cc: Attorney, Pittsfield Township

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for: Raed & Sons Holdings LLC, 

Petitioner, 

v 

MTT Docket No. 25-002291 

Pittsfield Township, 

Respondent. 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

I. 

The case is pending in the 

x__ 

Entire Tribunal OR ___ Small Claims 

Division, 

| 

2. 

Property Parcel No: L -12-24-300-007. 

(If more than one parcel is at issue, attach a completed Multiple Parcel 

Stipulation Form addressing all other parcels at issue.) 

3. 

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

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$1,245,636 

$622,818 

$622,818 

4. 

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

settlement purposes are:

Page 3

MTT Docket No, 25-002201 

Consént Judgment, Page 2 of 2 

tax year originally appealed 

5. 

| If stipulation addresses tax years other than the 

; or tax years added through motions to amend that have been granted by the 

i Tribunal, list the separate facts upon which thejparties rely to invoke the 

Tribunal’s authority over those tax year or years (attach additional page if 

necessary): 

| 

6. 

| Listseparately any special terms or conditions peing proposed by the parties 

"| 

that would affect the execution of this Consent udgment including, but not 1 

imited to, the joint payment of the refund, the 

waiver of interest, etc. (attach 

| additional page if necessary): The parties agree that interest is waived on all refunds issue 

! d pursuant to this stipulation as to all applicable jurisdictio 5 Payment will be made in 60 days. _ 

Signa 

itioner 

ized Representative or, if non 2, Petitioner: 

4 

Jon 

flyhorth, Property Tax Consultants 

Date: 

2 / é / 46 

Signature of Respondent’s authorized representative; 

Alana E, Knox 

Attomey, Pittsfield Township 

Date: 

[Cons 

2/4 [db 

pt Judgment will be prepared by the Tribunal.}

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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 

 

 

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 

Raed & Sons Holdings LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002291 

 

Pittsfield Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ 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 

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

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after 

December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 

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

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-002291 

Page 2 of 2 

 

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

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

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

8.66%, and (ix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 

 

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. 

 

 

 

 

 

 

 

 

 

 

By: /s/ Patricia L. Halm 

Entered: March 23, 2026 

jcr 

 

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 TRIBLTNAL

Property Tax Consultants for: Raed & Sons Holdings LLC-

Petitioner,

V

The case is pending in the x Entire Tribunal OR

Division.

MTT Docket No. 25-002291

Small Claims

Pittsfield Township,

Respondent.

STIPULATION FOR ENTRY OF CONSENT JUDGMENT

AND CONSENT JUDGMENT

1

)

J

Property Parcel No: L -12-24-300-007.

(If more than one parcel is at issue, attacha completed Multiple Parcel

Stipulation Form addressing all other parcels at issue.)

The values for the property identified above as established by Respondent's

Board of Review are:

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

settlement pu{poses are:

4

Tax Year

True Cash Value

Assessed Value

Taxable Value

2025

$r,245,636

$622,818

$622,818

Tax Year

True Cash Value

State Equalized Value

Taxable Value

2025

$1,144,800

s572,400

s572,400

Page 2

6

MTT

No.25-002291

Judgment, Page 2 of 2

5

If stipulation addresses tax years other than

tax y ear originally appealed

or tax years added through motions to amend

have been granted by the

Tribunal, list the separate facts upon which

parties rely to invoke the

Tribunal's authority over those tax year or

(attach additional page if

necessary):

List separately any special terms or conditions

proposed by the parties

that would affect the execution of ths

Judgment including, but not I

imited to, the joint payment of the refund, the

of interest, etc. (attach

additional page if necessary): rneparties agree

interest is waived on all refunds issue

d pursuant to this stipulation as to all applicable

Payment will be made in 60 days._

Petitioner:

Representative ol if

Jon

Date:

Judgment will be prepared by the Tribunal.l

Property Tax Consultants

of Respondent' s authorized representative:

Pittsfield Township

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 TRIBLTNAL

Property Tax Consultants for: Raed & Sons Holdings LLC-

Petitioner,

V

The case is pending in the x Entire Tribunal OR

Division.

MTT Docket No. 25-002291

Small Claims

Pittsfield Township,

Respondent.

STIPULATION FOR ENTRY OF CONSENT JUDGMENT

AND CONSENT JUDGMENT

1

)

J

Property Parcel No: L -12-24-300-007.

(If more than one parcel is at issue, attacha completed Multiple Parcel

Stipulation Form addressing all other parcels at issue.)

The values for the property identified above as established by Respondent's

Board of Review are:

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

settlement pu{poses are:

4

Tax Year

True Cash Value

Assessed Value

Taxable Value

2025

$r,245,636

$622,818

$622,818

Tax Year

True Cash Value

State Equalized Value

Taxable Value

2025

$1,144,800

s572,400

s572,400

Page 2

6

MTT

No.25-002291

Judgment, Page 2 of 2

5

If stipulation addresses tax years other than

tax y ear originally appealed

or tax years added through motions to amend

have been granted by the

Tribunal, list the separate facts upon which

parties rely to invoke the

Tribunal's authority over those tax year or

(attach additional page if

necessary):

List separately any special terms or conditions

proposed by the parties

that would affect the execution of ths

Judgment including, but not I

imited to, the joint payment of the refund, the

of interest, etc. (attach

additional page if necessary): rneparties agree

interest is waived on all refunds issue

d pursuant to this stipulation as to all applicable

Payment will be made in 60 days._

Petitioner:

Representative ol if

Jon

Date:

Judgment will be prepared by the Tribunal.l

Property Tax Consultants

of Respondent' s authorized representative:

Pittsfield Township

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

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

Raed & Sons Holdings LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-002291

Township Of Pittsfield,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on March 2, 2026, and 

finds that the docket number listed on the first page of the stipulation is incorrect as it 

does not relate to the parcel number listed in the stipulation. Further, the Michigan Tax 

Tribunal is not a part of the Michigan Administrative Hearing Systems and should not be 

referenced as such in the stipulation’s heading. Therefore,

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall remain on the previously-scheduled 

Prehearing General Call and a Prehearing Conference will be scheduled accordingly.

IT IS FURTHER ORDERED that because this Stipulation for Entry of Consent 

Judgment is no longer pending before the Tribunal, a new stipulation is required for any 

future settlement. However, if the new stipulation is filed within 14 days of the issuance 

of this order, no additional filing fee is required.

By _____________________________

 Patricia L. Halm, Tribunal Chair 

Entered: March 6, 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

Raed & Sons Holdings LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-002291

Township Of Pittsfield,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on March 2, 2026, and 

finds that the docket number listed on the first page of the stipulation is incorrect as it 

does not relate to the parcel number listed in the stipulation. Further, the Michigan Tax 

Tribunal is not a part of the Michigan Administrative Hearing Systems and should not be 

referenced as such in the stipulation’s heading. Therefore,

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall remain on the previously-scheduled 

Prehearing General Call and a Prehearing Conference will be scheduled accordingly.

IT IS FURTHER ORDERED that because this Stipulation for Entry of Consent 

Judgment is no longer pending before the Tribunal, a new stipulation is required for any 

future settlement. However, if the new stipulation is filed within 14 days of the issuance 

of this order, no additional filing fee is required.

By _____________________________

 Patricia L. Halm, Tribunal Chair 

Entered: March 6, 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 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Raed & Sons Holdings LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-002291

Township Of Pittsfield,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on March 2, 2026, and 

finds that the docket number listed on the first page of the stipulation is incorrect as it 

does not relate to the parcel number listed in the stipulation. Further, the Michigan Tax 

Tribunal is not a part of the

Page 4

MTT

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Page 1

RECEIVED 

MAR 0'5 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for: Raed & Sons Holdings LLC, 

Petitioner, 

Vv 

MTT Docket No. 25-002337 

Pittsfield Township, 

Respondent. 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

1. 

The case is pending in the 

x 

Entire Tribunal OR ___ Small Claims 

Division. 

2. 

Property Parcel No: L -12-24-300-007. 

(If more than one parcel is at issue, attach a completed Multiple Parcel 

Stipulation Form addressing all other parcels at issue.) 

3. 

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

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$1,245,636 

$622,818 

$622,818 

4. 

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

settlement purposes are:

Page 2

MTT Docket No. 25-002291 

Consent Judgment, Page 2 of 2 

5. 

If stipulation addresses tax years other than the tax year originally appealed 

or tax years added through motions to amend that have been granted by the 

Tribunal, list the separate facts upon which the parties rely to invoke the 

Tribunal’s authority over those tax year or years (attach additional page if 

necessary): 

6 

List separately any special terms or conditions being proposed by the parties 

"that would affect the execution of this Consent Judgment including, but not 1 

imited to, the joint payment of the refund, the waiver of interest, etc. (attach 

additional page if necessary): The parties agree that interest is waived on all refunds issue 

d pursuant to this stipulation as to all applicable jurisdictions. Payment will be made in 60 days.__ 

a 

a 

Representative ot, if none, Petitioner: 

Jon 

Aglgworth, Property Tax Consultants 

Date: 

2 [4/46 

Signature of Respondent’s authorized representative: 

Alana E. Knox 

Attorney, Pittsfield Township 

Date: 

3 i d/ Als 

[Consent Judgment will be prepared by the Tribunal]

Page 3

als 

PROPERTY TAX 

CONSULTANTS 

YOUR PROPERTY TAX EXPERTS SINCE 1989 

March 2, 2026 

Clerk of the Court 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

Property Tax Consultants for Raed & Sons Holdings LLC 

Parcel # L -12-24-300-007, v. Pittsfield Township 

Docket # 25-002291 

Dear Clerk, 

Regarding the above matter, enclosed please find the STIPULATION TO CONSENT 

JUDGEMENT fully authorized by the petitioner and the respondent. 

We hope that this meets with the approval of the Michigan Tax Tribunal. 

Very truly yours, 

Ce: Attorney, Pittsfield Township

Page 4

PROPERTY TAX 

CONSULTANTS 

861 Pinecrest Ave SE 

East Grand Rapids, MI 49506 

269.366.0300 

Clerk of the Court 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

sli 

shifjaliyyi 

il 

flip

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

ACTING 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 AUGUST 3 - 14, 2026 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Raed & Sons Holdings LLC,

Petitioner,

v

 

 

Township Of Pittsfield,

Respondent.

 MTT Docket No. 25-002291

Please be advised that 25-002291 has been placed on a two-week Prehearing General 

Call commencing August 03, 2026. Parties will be notified at least one week before 

they are scheduled to appear.

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, as provided by TTR 237.

In accordance with MCR 1.109(D)(9), as of January 1, 2021, 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. Please refer to the 

Tribunal’s FAQs and Glossary of Terms pages on our website for more information.

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 April 6, 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.

Page 2

MTT Docket No. 25-002291

Page 2 of 2

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

Statements by April 6, 2026. 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, as provided by 

TTR 237. 

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

April 6, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, 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 

August 3, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, 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: September 2, 2025 

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal

Page 3

STAT

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Page 1

1

S E C R E S T W A R D L E 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

RAED & SONS HOLDINGS, LLC, 

 

 

Petitioner, 

MTT Docket No. 25-002291 

 

 

Parcel No. TB-12-24-300-007 

-vs- 

 

 

 

 

 

 

 

 

PITTSFIELD TOWNSHIP 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

PROPERTY TAX CONSULTANTS 

Jon Aylsworth 

Representative for Petitioner 

861 Pinecrest Ave. SE 

Grand Rapids, MI 49506 

(269) 366-0300 

SECREST WARDLE 

Alana E. Knox (P85859) 

Attorney for Respondent 

2600 Troy Center Drive 

P.O. Box 5025 

Troy, MI 48007-5025 

(248) 851-9500 

aknox@secrestwardle.com

_________________________________________________________________________________/ 

 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

 

 

NOW COMES Respondent, PITTSFIELD TOWNSHIP, by and through its attorneys, 

SECREST WARDLE, and for its Answer to Petitioner’s Petition, states as follows: 

1. 

Answering paragraph 1, Respondent admits that the Petitioner is Raed & Sons 

Holdings, LLC. Respondent neither admits nor denies the remainder of the allegations contained in 

paragraph 1 for lack of sufficient knowledge or information upon which to form a belief and leaves 

Petitioner to its proofs. 

2. 

Answering paragraph 2, Respondent admits the allegations contained therein. 

3. 

Answering paragraph 3, Respondent admits that the subject property is real property 

classified as commercial that has tax identification number L-12-24-300-007 and that the Petitioner’s 

property is presently being used for commercial purposes. Respondent neither admits nor denies the

Page 2

2

S E C R E S T W A R D L E 

remainder of the allegations contained in paragraph 3 for lack of sufficient knowledge or information 

upon which to form a belief and leaves Petitioner to its proofs. 

4. 

Answering paragraph 4, Respondent admits the allegations contained therein. 

5. 

Answering paragraph 5, Respondent neither admits nor denies the allegations 

contained in paragraph 5 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

6. 

Answering paragraph 6, Respondent admits that the subject property has a 2025 

assessed value of $622,818, state equalized value of $622,818, and a taxable value of $622,818. 

7. 

Answering paragraph 7, Respondent admits that the Petitioner appealed the 2025 

assessment of the subject property to the Board of Review and that the Board of Review denied the 

Petitioner’s requested relief. 

8. 

Answering paragraph 8, Respondent denies the allegations contained therein for the 

reason that the same are untrue. 

9. 

Answering paragraph 9, Respondent denies that the 2025 true cash value of the subject 

property should be $800,00 and Respondent also denies that the 2025 state equalized value and 2025 

taxable value of the subject property should be $400,000. Respondent neither admits nor denies the 

remainder of the allegations contained in paragraph 9 for lack of sufficient knowledge or information 

upon which to form a belief and leaves Petitioner to its proofs. 

10. 

Answering paragraph 10, Respondent denies that the Michigan Tax Tribunal should 

reduce the 2025 assessed value and 2025 taxable value of the subject property to $400,000 and also 

denies that the Michigan Tax Tribunal should order a refund with interest. 

WHEREFORE, Respondent, Pittsfield Township, denies that Petitioner is entitled to the relief 

it seeks and respectfully requests that the Respondent’s assessment and taxable value of the subject 

property be affirmed or increased, that Petitioner’s Petition be dismissed with prejudice and that 

Respondent be granted costs and attorney fees so wrongfully incurred.

Page 3

3

S E C R E S T W A R D L E 

 

 

 

 

 

 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

BY: 

 /s/ Alana E. Knox 

 

 

 

 ALANA E. KNOX (P85859) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

2600 Troy Center Drive, P.O. Box 5025 

 

 

 

 

 

 

Troy, Michigan 48007-5025 

 

 

 

 

 

 

(248) 851-9500 

Dated: July 25, 2025 

 

 

aknox@secrestwardle.com

Page 4

4

S E C R E S T W A R D L E 

AFFIRMATIVE DEFENSES 

 

 

For its further Answer to Petitioner’s Petition and by way of its Affirmative Defenses, 

Respondent respectfully requests unto this Honorable Tribunal 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, application of wrong principles

Page 5

5

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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. 25-002291

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Pittsfield (WASHTENAW)

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

Alana

M.I.

E.

Last Name

Knox

Firm Name (if any)

Secrest Wardle

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

2600 Troy Center Drive

PO Box 5025

City or Town

Troy

State

Michigan

ZIP Code

48007

Telephone Number

248-539-2820

Fax Number

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

aknox@secrestwardle.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Alana E. Knox

/s/

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Page 1

RECEIVED 

AW 

JUL 10 2025 

PROPERTY TAX 

37 TAX TRIBUNAL 

CONSULTANTS 

YOUR PROPERTY TAX EXPERTS SINCE 1989 

July 8, 2025 

RE: 

Notice of Docket Number for Entire Tribunal petition at Michigan Tax Tribunal 

MTT Docket # 

J S= 00) JU 

Enclosed please find a copy of the petition containing the docket number assigned by the 

Michigan Tax Tribunal, proof of service and copies of additional required documentation for the 

above captioned matter. 

Very truly yours, 

Ji 

ylsworth 

JA/ac 

Enclosures

Page 2

RECEIVED 

AW 

MAY 21 2025 

PROPERTY TAX 

MICHIGAN TAX TRIBUNAL 

CONSULTANTS 

YOUR PROPERTY TAX EXPERTS SINCE 1989 

May 21, 2025 

Clerk of the Court 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

Property Tax Consultants for Raed & Sons Holdings LL.C 

Parcel # L -12-24-300-007, v. Pittsfield Township 

Dear Clerk, 

Enclosed please find Petitioner's Petition and Proof of Service for filing in the above captioned matter. 

Also enclosed is our check in the amount of $400.00 representing the filing fee in this matter. 

Very teply yours, 

Aylsworth 

Alac 

Enclosures

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for Raed & Sons Holdings LLC, 

Vv 

MTT Docket No. 25-002291 

Pittsfield Township, 

PETITION 

Petitioner, Raed & Sons Holdings LLC, through their agent, Property Tax Consultants, petitions this 

Tribunal as follows: 

Petitioner is Raed & Sons Holdings LLC whose principal office or address is 5730 Pine View 

Dr, Ypsilanti, MI 48197. 

Respondent, Pittsfield Township, establishes, levies and collects the property taxes on the subject 

property. 

The property identification is # L -12-24-300-007 and the subject property address is 5561 

Carpenter Rd, Ypsilanti, MI 48197. The property is classified as commercial real property. 

Petitioner’s Property is presently used for commercial. Petitioner believes that Petitionet’s 

Property was originally designed to be used for commercial. 

The property is located in Washtenaw County and the school districts of Ann Arbor Public and 

the Washtenaw Intermediate School District and Washtenaw Community College. 

This matter involves issues relating to the true cash and taxable values for the parcel referenced 

above for the 2025 tax year. 

For tax year 2025, Respondent’s Board of Review determined an assessed value of $622,818 a 

state equalized value of $622,818 and a taxable value of $622,818. 

Petitioner appealed to the March Board of Review and the requested relief was denied. 

The 2025 values set by the respondent are invalid and unlawful as they exceed the amount 

allowed by Michigan law and the Michigan Constitution and do not reflect the true cash value of 

the fee simple interest as of the applicable tax date. 

Petitioner contends the true cash value of the subject property is $800,000 which would yield a 

state equalized value of $400,000 and the taxable value is $400,000. The amount in contention is

Page 4

Dated: May 21, 2025 

By: 

J 

Jon Aylsworth, Property Tax Consultants 

861 Pinecrest Ave SE, Grand Rapids, MI 49506 

269-366-0300 

| jack@skylinepropertytax.com

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for: Raed & Sons Holdings LLC 

Petitioner 

Vv 

PETITION 

MTT Docket # 25-002291 

Pittsfield Township 

Respondent 

PROOF OF SERVICE 

Jon Aylsworth, deposes and says that on July 8, 2025 he served a copy of the Petition relative to the 

above-captioned matter upon: 

Via certified mail, return receipt requested, with proper postage affixed thereto. 

Assessor, Pittsfield Township 

6201 W Michigan Ave, Ann Arbor, MI 48108 

Clerk, Pittsfield Township 

6201 W Michigan Ave, Ann Arbor, MI 48108 

Via United States First-Class mail with proper postage affixed thereto. 

Clerk, Washtenaw County 

200 North Main, Ann Arbor, MI 48104 

Director of Equalization, Washtenaw County 

200 North Main STE 210, Ann Arbor, MI 48104 

Secretary of School Board, Ann Arbor Public School District 

2555 S State, Ann Arbor, MI 48104 

Secretary of School Board, Washtenaw Intermediate School District 

1819 South Wagner Rd, Ann Arbor, MI 48106 

State Treasurer, Michigan Department of Treasury 

430 W. Allegan, Lansing, MI 48922 

Clerk of the Court, Michigan Tax Tribunal

Page 6

Property Tax Consultants 

861 Pinecrest Ave SE 

Grand Rapids, MI 49506 

Michigan Tax Trib unal 

ATTN: Clerk of the Court 

P.O. Box 30232 

Lansing, MI 48909

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Page 1

PROPERTY TAX 

CONSULTANTS 

Clerk of the Court 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

May 21, 2025 

YOUR PROPERTY TAX EXPERTS SINCE 1989 

RECEIVED 

MAY 21 2025 W 

ne 

pO 

MICHIGAN TAX TRIBUNAL 

RE: 

Property Tax Consultants for Raed & Sons Holdings LLC 

Parcel # L -12-24-300-007, v. Pittsfield Township 

Dear Clerk, 

Enclosed please find Petitioner's Petition and Proof of Service for filing in the above captioned matter. 

Also enclosed is our check in the amount of $400.00 representing the filing fee in this matter. 

Aylsworth 

Alac 

Enclosures

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for Raed & Sons Holdings LLC, 

v 

MTT Docket No. 

Pittsfield Township, 

PETITION 

Petitioner, Raed & Sons Holdings LLC, through their agent, Property Tax Consultants, petitions this 

Tribunal as follows: 

Petitioner is Raed & Sons Holdings LLC whose principal office or address is 5730 Pine View 

Dr, Ypsilanti, MI 48197. 

Respondent, Pittsfield Township, establishes, levies and collects the property taxes on the subject 

property. 

The property identification is # L -12-24-300-007 and the subject property address is 5561 

Carpenter Rd, Ypsilanti, MI 48197. The property is classified as commercial real property. 

Petitioner’s Property is presently used for commercial. Petitioner believes that Petitioner’s 

Property was originally designed to be used for commercial. 

The property is located in Washtenaw County and the school districts of Ann Arbor Public and 

the Washtenaw Intermediate School District and Washtenaw Community College. 

This matter involves issues relating to the true cash and taxable values for the parcel referenced 

above for the 2025 tax year. 

For tax year 2025, Respondent’s Board of Review determined an assessed value of $622,818 a 

state equalized value of $622,818 and a taxable value of $622,818. 

Petitioner appealed to the March Board of Review and the requested relief was denied. 

The 2025 values set by the respondent are invalid and unlawful as they exceed the amount 

allowed by Michigan law and the Michigan Constitution and do not reflect the true cash value of 

the fee simple interest as of the applicable tax date. 

Petitioner contends the true cash value of the subject property is $800,000 which would yield a 

state equalized value of $400,000 and the taxable value is $400,000. The amount in contention is

Page 3

/] 

Dated: May 21, 2025 

By: 

41 

Jon son 

ge Tax Consultants 

861 Pinecrest 

Ave SE, Grand Rapids, MI 49506 

269-366-0300 

| jack@skylinepropertytax.com

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for: Raed & Sons Holdings LLC 

Petitioner 

Vv 

PETITION 

Pittsfield Township 

Respondent 

PROOF OF SERVICE 

Jon Aylsworth, deposes and says that on May 21, 2025 he served a copy of the Petition relative to the 

above-captioned matter upon: 

Clerk of the Court, Michigan Tax Tribunal 

Via Hand Delivery

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

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

Raed & Sons Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002291

Township Of Pittsfield, 

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 5, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

PROPERTY TAX 

CONSULTANTS 

Clerk of the Court 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

May 21, 2025 

YOUR PROPERTY TAX EXPERTS SINCE 1989 

RECEIVED 

MAY 21 2025 W 

ne 

pO 

MICHIGAN TAX TRIBUNAL 

RE: 

Property Tax Consultants for Raed & Sons Holdings LLC 

Parcel # L -12-24-300-007, v. Pittsfield Township 

Dear Clerk, 

Enclosed please find Petitioner's Petition and Proof of Service for filing in the above captioned matter. 

Also enclosed is our check in the amount of $400.00 representing the filing fee in this matter. 

Aylsworth 

Alac 

Enclosures

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for Raed & Sons Holdings LLC, 

v 

MTT Docket No. 

Pittsfield Township, 

PETITION 

Petitioner, Raed & Sons Holdings LLC, through their agent, Property Tax Consultants, petitions this 

Tribunal as follows: 

Petitioner is Raed & Sons Holdings LLC whose principal office or address is 5730 Pine View 

Dr, Ypsilanti, MI 48197. 

Respondent, Pittsfield Township, establishes, levies and collects the property taxes on the subject 

property. 

The property identification is # L -12-24-300-007 and the subject property address is 5561 

Carpenter Rd, Ypsilanti, MI 48197. The property is classified as commercial real property. 

Petitioner’s Property is presently used for commercial. Petitioner believes that Petitioner’s 

Property was originally designed to be used for commercial. 

The property is located in Washtenaw County and the school districts of Ann Arbor Public and 

the Washtenaw Intermediate School District and Washtenaw Community College. 

This matter involves issues relating to the true cash and taxable values for the parcel referenced 

above for the 2025 tax year. 

For tax year 2025, Respondent’s Board of Review determined an assessed value of $622,818 a 

state equalized value of $622,818 and a taxable value of $622,818. 

Petitioner appealed to the March Board of Review and the requested relief was denied. 

The 2025 values set by the respondent are invalid and unlawful as they exceed the amount 

allowed by Michigan law and the Michigan Constitution and do not reflect the true cash value of 

the fee simple interest as of the applicable tax date. 

Petitioner contends the true cash value of the subject property is $800,000 which would yield a 

state equalized value of $400,000 and the taxable value is $400,000. The amount in contention is

Page 3

/] 

Dated: May 21, 2025 

By: 

41 

Jon son 

ge Tax Consultants 

861 Pinecrest 

Ave SE, Grand Rapids, MI 49506 

269-366-0300 

| jack@skylinepropertytax.com

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Property Tax Consultants for: Raed & Sons Holdings LLC 

Petitioner 

Vv 

PETITION 

Pittsfield Township 

Respondent 

PROOF OF SERVICE 

Jon Aylsworth, deposes and says that on May 21, 2025 he served a copy of the Petition relative to the 

above-captioned matter upon: 

Clerk of the Court, Michigan Tax Tribunal 

Via Hand Delivery

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.