Rpmc 12 Associates, LLC, Petitioner Vs. Township Of Macomb, 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 

RPMC 12 Associates LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001637 

 

Macomb Township, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

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, 2013, through June 30, 2016, at the rate of 4.25%, 

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

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

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

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001637 

Page 2 of 2 

 

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

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

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

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

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

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

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

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

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

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

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES LLC, 

Petitioner, 

\ 

MTT Docket No. 25-001637 

MACOMB TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

Property Parcel No: 20-08-32-230-012 

3. 

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

Board of Review are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Value 

Assessed Value 

Value 

2025 

$989,600 

$494,800 

$494,800 

Bro 

4, 

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

settlement purposes are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Value 

Assessed Value 

Value 

2025 

$650,000 

$325,000 

$325,000 

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 limited to, the joint payment of the refund, the waiver of interest, 

etc.:

Page 2

MTT Docket No. 25-001637 

Entire Tribunal Consent Judgment 

REFUNDS ARE TO BE MADE PAYABLE TO THE LAW OFFICE OF AARON M. FALES, 

P.C. AND SENT CARE OF SAID COUNSEL TO 330 HAMILTON ROW, SUITE 350, 

BIRMINGHAM, MI 48009. 

Law OFFICE OF AARON M. FALEs, P.C. 

York, Dolan, & Tomlinson, P.C. 

Attorneys for Petitioner, 

Sila 

a a 

By: 

Vz / 

: 

Aaron Fales [P72864) 

Timothy Tomlinson 

330 eho Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Township, MI 48036 

248-767-9840 

(586) 263-5050 

Dated: 

__1¥725 

Dated: 

___J0- 172

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES LLC, 

Petitioner, 

\ 

MTT Docket No. 25-001637 

MACOMB TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

Property Parcel No: 20-08-32-230-012 

3. 

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

Board of Review are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Value 

Assessed Value 

Value 

2025 

$989,600 

$494,800 

$494,800 

Bro 

4, 

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

settlement purposes are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Value 

Assessed Value 

Value 

2025 

$650,000 

$325,000 

$325,000 

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 limited to, the joint payment of the refund, the waiver of interest, 

etc.:

Page 2

MTT Docket No. 25-001637 

Entire Tribunal Consent Judgment 

REFUNDS ARE TO BE MADE PAYABLE TO THE LAW OFFICE OF AARON M. FALES, 

P.C. AND SENT CARE OF SAID COUNSEL TO 330 HAMILTON ROW, SUITE 350, 

BIRMINGHAM, MI 48009. 

Law OFFICE OF AARON M. FALEs, P.C. 

York, Dolan, & Tomlinson, P.C. 

Attorneys for Petitioner, 

Sila 

a a 

By: 

Vz / 

: 

Aaron Fales [P72864) 

Timothy Tomlinson 

330 eho Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Township, MI 48036 

248-767-9840 

(586) 263-5050 

Dated: 

__1¥725 

Dated: 

___J0- 172

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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

RPMC 12 Associates, LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-001637

Township Of Macomb,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on October 8, 2025, 

and finds that the parties have failed to provide the correct true cash value indicated by 

the assessed value established by Respondent’s Board of Review, for the 2025 tax 

year. Therefore,

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

DENIED.

IT IS FURTHER ORDERED that this case shall be placed on a Prehearing General Call 

in the normal course of scheduling.

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 _____________________________

 Joshua M. Wease, Tribunal Member 

Entered: October 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

MTT Docket No. 25-001637

Page 2 of 6

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

RPMC 12 Associates, LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-001637

Township Of Macomb,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on October 8, 2025, 

and finds that the parties have failed to provide the correct true cash value indicated by 

the assessed value established by Respondent’s Board of Review, for the 2025 tax 

year. Therefore,

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

DENIED.

IT IS FURTHER ORDERED that this case shall be placed on a Prehearing General Call 

in the normal course of scheduling.

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 _____________________________

 Joshua M. Wease, Tribunal Member 

Entered: October 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 4

MTT Docket No. 25-001637

Page 4 of 6

Page 5

STATE OF MICHIGAN

GRETCHEN

Page 6

MTT

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES LLC, 

Petitioner, 

v 

MTT Docket No. 25-001637 

MACOMB TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the X Entire Tribunal OR _ Small Claims Division. 

2. 

Property Parcel No: 20-08-32-230-012 

3. 

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

Board of Review are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Valve 

Assessed Value 

Valve 

2025 

$989,692 

$494,800 

$494,800 

4, 

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

settlement purposes are: 

Tax 

True Cash 

State Equalized & 

Taxable 

Year 

Valve 

Assessed Value 

Value 

2025 

$650,000 

$325,000 

$325,000 

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 limited to, the joint payment of the refund, the waiver of interest, 

etc.

Page 2

MTT Docket No. 25-001637 

Enfire Tribunal Consent Judgment 

REFUNDS ARE TO BE MADE PAYABLE TO THE LAW OFFICE OF AARON M. FALES, 

P.C. AND SENT CARE OF SAID COUNSEL TO 330 HAMILTON ROW, SUITE 350, 

BIRMINGHAM, MI 48009. 

LAW OFFICE OF AARON M. FALES, P.C. 

York, Dolan, & Tomlinson, P.C. 

Attorneys for Petitioner, 

ene 

2 TR 

a ZZ 

By: 

Vs 9 

: 

Aaron Fales (P72864) 

Timothy Tomlinson 

330 Hamilton Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, Mi 48009 

Clinton Township, MI 48036 

248-767-9840 

(586) 263-5050 

Dated: 

17% 

Dated: 

J 1724

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES LLC, 

Petitioner, 

V. 

MTT Docket # 25-001637 

MACOMB TOWNSHIP, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on August 8 2025 he served a copy 

of Petitioner's Petition on the parties named on the attached list. 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

MACOMB TWP. 

54111 BROUGHTON ROAD 

MACOMB, MI 48042 

ASSESSOR 

MACOMB TWP. 

54111 BROUGHTON ROAD 

MACOMB, MI 48042 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 

1 

S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 1S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

NEW HAVEN COMMUNITY SCHOOLS 

30375 CLARK STREET, P.O. BOX 482000 

NEW HAVEN, MI 48048-2000 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

RPMC 12 Associates, LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-001637 

Township Of Macomb, 

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 Tribunals rules. 

By: __ Tribunal Clerk 

Entered: July 16, 2025 

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. 

By: Tribunal Clerk 

MICHIGAN TAX TRIBUNAL 

- 611 W. OTTAWA ST., LANSING, MI 48933 

- 517-335-9760 

PO BOX 30232, LANSING, MI 48909 

- Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

MTT Docket #25- 001637 

vs. 

Parcel No. 20-08-32-230-012 

MACOMB TOWNSHIP, 

Respondent. 

/ 

PETITION 

RPMC 12 ASSOCIATES LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales,

Page 5

4

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

vs. 

MTT Docket No. 25-001637 

MACOMB TOWNSHIP, 

Respondent. 

AARON M. FALES (P72864) 

TIMOTHY D. 

TOMLINSON (P48519) 

LAW OFFICE OF AARON M. FALES P.C. 

YORK, DOLAN & TOMLINSON, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Twp., MI 48036 

(248) 767-9840 

(586) 263-5050 

afaleslaw@gmail.com 

ttomlinson@yorkdolanlaw.com 

PROOF OF SERVICE 

On July 24, 2025, I served by first class U.S. Mail a copy of Respondent's Answer to 

Petitioner's Petition, Affirmative Defenses and this Proof of Service in the above-captioned 

matter upon: 

AARON M. FALES 

LAW OFFICE OF AARON M. FALES P.C. 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

I declare that the statements above are true to the best of my information, knowledge and 

belief. 

Ferre Hp 

Donna L. Hall 

York, Dolan & Tomlinson, P.C.

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

VS. 

MTT Docket No. 25-001637 

Parcel No. 20-08-32-230-012 

MACOMB TOWNSHIP, 

Respondent. 

PROOF OF SERVICE 

On July 24, 2025, I served by first class U.S. Mail a copy of Respondents Answer to 

Petitioner’s Petition and Affirmative Defenses in the above-captioned matter upon: 

AARON M. FALES (P72864) 

LAW OFFICE OF AARON M. FALES, P.C. 

330 Hamilton Row, Suite 350 

Birmingham, MI 48009 

1 declare that the statements above are true to the best of my information, knowledge and belief. 

/s/ Donna L. Hall 

Donna L. Hall

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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. 25-001637

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Macomb (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

Timothy

M.I.

D

Last Name

Tomlinson

Firm Name (if any)

York, Dolan & Tomlinson, P.C.

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

22600 Hall Rd

Ste 205

City or Town

Clinton Twp

State

Michigan

ZIP Code

48036

Telephone Number

586-263-5050

Fax Number

586-263-4763

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

ttomlinson@yorkdolanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Timothy D. Tomlinson

/s/

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

vs. 

MTT Docket No. 25-001637 

Parcel No. 20-08-32-230-012 

MACOMB TOWNSHIP, 

Respondent. 

RESPONDENT’S AFFIRMATIVE DEFENSES 

NOW COMES the Respondent, Macomb Township, by and through its attorneys, York, 

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

1. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

Respondent. 

3. 

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

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

Respondent’s taxing unit for the year in question. 

4. 

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

assessed value and taxable value of its property.

Page 2

5. 

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

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

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

property’s taxable value is improper. 

6. 

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

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

at the respective equalized assessments. 

7. 

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

by application of a method of assessment different from that employed in the 

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

8. 

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

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

action. 

9. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

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

equitable tax burden. 

10. 

Respondent has properly and lawfully assessed Petitioner’s property and established 

its taxable value in accordance with statutory and constitutional requirements. 

11. 

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

Affirmative Defenses that discovery reveals. 

‘WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss the 

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

Page 3

wrongfully incurred in having to defend this matter. 

Respectfully submitted, 

YORK, DOLAN & TOMLINSON, P.C. 

/s/ Timothy D. Tomlinson 

TIMOTHY D. TOMLINSON (P48519) 

Attorneys for Respondent 

22600 Hall Rd., Ste. 205 

Clinton Township, MI 48036 

(586) 263-5050 

ttomlinson@yorkdolanlaw.com 

Dated: July24, 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 - Respondent

MOAHR DOCKET NO. 25-001637

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Macomb (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

Timothy

M.I.

D

Last Name

Tomlinson

Firm Name (if any)

York, Dolan & Tomlinson, P.C.

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

22600 Hall Rd

Ste 205

City or Town

Clinton Twp

State

Michigan

ZIP Code

48036

Telephone Number

586-263-5050

Fax Number

586-263-4763

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

ttomlinson@yorkdolanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Timothy D. Tomlinson

/s/

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

vs. 

MTT Docket No. 25-001637 

Parcel No. 20-08-32-230-012 

MACOMB TOWNSHIP, 

Respondent. 

ANSWER TO PETITION 

NOW COMES Respondent, MACOMB TOWNSHIP, by and through its attorneys, York, 

Dolan & Tomlinson, P.C., and in Answer to Petitioner’s Petition states as follows: 

1. 

Respondent neither admits nor denies the allegations set forth in Paragraph 1. 

2. 

Respondent admits the allegations set forth in Paragraph 2. 

3. 

Respondent admits the allegations set forth in Paragraph 3. 

4. 

Respondent admits the allegations set forth in Paragraph 4. 

5. 

Respondent denies the allegations set forth in Paragraph 5, the same being untrue. 

6. 

Respondent denies the allegations set forth in Paragraph 6, the same being untrue. 

7. 

Respondent denies the allegations set forth in Paragraph 7 (including sub- 

paragraphs (a)-(d), the same being untrue. 

WHEREFORE, Respondent, MACOMB TOWNSHIP, respectfully requests the within

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cause of action be dismissed in its entirety, together with costs and attorney fees so wrongfully 

incurrerd. 

Respectfully submitted, 

YORK, DOLAN & TOMLINSON, P.C. 

/s/ Timothy D. Tomlinson 

TIMOTHY D. TOMLINSON (P48519) 

Attorneys for Respondent 

22600 Hall Rd., Ste. 205 

Clinton Township, MI 48036 

(586) 263-5050 

Dated: July 24, 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 - Respondent

MOAHR DOCKET NO. 25-001637

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Macomb (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

Timothy

M.I.

D

Last Name

Tomlinson

Firm Name (if any)

York, Dolan & Tomlinson, P.C.

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

22600 Hall Rd

Ste 205

City or Town

Clinton Twp

State

Michigan

ZIP Code

48036

Telephone Number

586-263-5050

Fax Number

586-263-4763

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

ttomlinson@yorkdolanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Timothy D. Tomlinson

/s/

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

vs. 

MACOMB TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 20-08-32-230-012 

 

PETITION 

 

 

RPMC 12 ASSOCIATES LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 20-08-32-230-012 ("Petitioner's Property"), at 

46591 Romeo Plank Rd Unit 12, Macomb, MI. 

 

2. 

Respondent, Macomb Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

 In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $494,800 and assessed Petitioner's Property at $494,800 resulting in 

a state equalized value of the same amount based on the tenative equalization 

factor.

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4. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is an office Building. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

 

5. 

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

(c) taxable value, and (d) uniformity. 

 

6. 

At this time, Petitioner believes, as it relates to taxable value, that 

there is a dispute relative to the value of a loss. 

 

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, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or 

taxable value, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes; 

 

 

(c) 

The assessment, including taxable value and/or state 

equalized value, are based upon an erroneous determination of the true cash 

value of that portion of Petitioner's Property that is taxable under Michigan law, 

and are based upon the application of wrong principles; and,

Page 3

(d) 

The assessment, including state equalized value and/or 

taxable 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. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2025 taxable value of Petitioner's Property from $494,800 to 

$100,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $494,800 to $100,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 29, 2025 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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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

RPMC 12 Associates, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001637

Township Of Macomb, 

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 16, 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 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

RPMC 12 ASSOCIATES, LLC, 

Petitioner, 

vs. 

MACOMB TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 20-08-32-230-012 

 

PETITION 

 

 

RPMC 12 ASSOCIATES LLC (“Petitioner”), through its attorneys, Law Office 

of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 43900 Garfield Rd., Ste. 203, 

Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 20-08-32-230-012 ("Petitioner's Property"), at 

46591 Romeo Plank Rd Unit 12, Macomb, MI. 

 

2. 

Respondent, Macomb Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

 In 2025, Respondent determined the taxable value of Petitioner's 

Property to be $494,800 and assessed Petitioner's Property at $494,800 resulting in 

a state equalized value of the same amount based on the tenative equalization 

factor.

Page 2

4. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is an office Building. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

 

5. 

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

(c) taxable value, and (d) uniformity. 

 

6. 

At this time, Petitioner believes, as it relates to taxable value, that 

there is a dispute relative to the value of a loss. 

 

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, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or 

taxable value, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes; 

 

 

(c) 

The assessment, including taxable value and/or state 

equalized value, are based upon an erroneous determination of the true cash 

value of that portion of Petitioner's Property that is taxable under Michigan law, 

and are based upon the application of wrong principles; and,

Page 3

(d) 

The assessment, including state equalized value and/or 

taxable 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. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2025 taxable value of Petitioner's Property from $494,800 to 

$100,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $494,800 to $100,000, and requiring Respondent to pay 

Petitioner the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 29, 2025 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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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

RPMC 12 Associates, LLC

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

43900 Garfield Rd.

Suite 203

City or Town

Clinton Twp.

State

Michigan

ZIP Code

48038

Telephone Number

2487679840

Fax Number

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

aaron@afaleslaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Aaron

M.I.

M

Last Name

Fales

Firm Name (if any)

Law Office of Aaron M. Fales, P.C.

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

330 Hamilton Row, Ste. 350

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-767-9840

Fax Number

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

afaleslaw@gmail.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]

Michigan

Taxing Authority (City or Township)

Township Of Macomb (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:

20-08-32-230-012

Classification of Property: Real 

Commercial

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

494800

Current Taxable Value as established by the Board of Review:

494800

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

200000

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

100000

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

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