Rsaa Property LLC, Petitioner Vs. City Of Imlay City, 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 

RSAA Property LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001710 

 

City of Imlay City, 

 

Presiding Judge 

Respondent. 

 

Joshua M. Wease 

 

 

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, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001710 

Page 2 of 2 

 

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

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

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

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

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

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

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

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

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

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

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

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

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

8.66%. 

 

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 _____________________________ 

Entered: September 11, 2025 

gc 

 

PROOF OF SERVICE 

 

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

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

or email addresses on file, as provided by those

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

RECEIVED 

SEP 102023 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RSAA PROPERTY LLC, 

Petitioner, 

MTT Docket No. 25-001710 

vs. 

CITY OF IMLAY CITY, 

Respondent. 

/ 

IVAN AMMORI 

NATHAN HAGER, ASSESSOR 

THE AMMORI GROUP 

CITY OF IMLAY CITY 

Representative for Petitioner 

Representative for Respondent 

77 E. Long Lake Rd., F1 

1 

150 North Main Street 

Bloomfield Hills, MI 48304-2328 

Imlay City, MI 48444 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the 

_X 

Entire Tribunal ___ Small Claims Division. 

2. 

Property Parcel Nos: 

44-119-76-600-001-00; 44-119-76-602-001-00; 44-120-27-300- 

040-02; and 44-119-76-601-001-00. 

3. 

The properties are located at: 572 N. Cedar Street, Imlay City, Lapeer County, MI; 525 

E. Capac Road, Imlay City, Lapeer County, MI; 632 N. Cedar Street, Imlay City, Lapeer 

County, MI; 578 N. Cedar Street, Imlay City, Lapeer County, MI. 

4. 

The 2025 values for the properties identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Parcel Number 

Original TCV 

Original AV 

Original TV

Page 2

MTT Docket No. 25-001710 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

5. 

The 2025 values for the properties identified above as stipulated by the parties for 

settlement purposes are: 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Parcel Number 

Original TCV 

Original AV 

Original TV 

44-119-76-600-001-00 

$200,000 

$100,000 

$100,000 

44-119-76-602-001-00 

$40,000 

$20,000 

$20,000 

44-120-27-300-040-02 

$100,000 

$50,000 

$50,000 

| 44-119-76-601-001-00 

$35,000 

$17,500 

| 

$17,500 

6. 

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): 

7. 

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. (attach additional page if necessary): 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

Signature of Petitioner’s mz or, if none, Petitioner: 

/s/ Ivan Ammori 

— 

9 

g ~ 2029 

Ivan Ammori 

Signature of Respondent’s authorized representative: 

Nathan D. Hager 

09/03/2025 

Nathan Hager 

v

Page 3

Psap Pegervy LLC 

Ivan Ammori 

.,. 

~METROPLEX MI 4 

77 E Long Lake Rd. 

ey 

Co 

5 SEP 2025 PM 

Suite 100 

Bloomfield Hills MI 48804 

MICHIGAN TAX TRIBUNAL 

PO BOX 30232 

LANSING MI 48909-7732 

$0.740 £

US POSTAGE BE

FIRST-CLASS Ei

FROM 48304 [

09/0412025 EB

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

RECEIVED 

SEP 102023 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RSAA PROPERTY LLC, 

Petitioner, 

MTT Docket No. 25-001710 

vs. 

CITY OF IMLAY CITY, 

Respondent. 

/ 

IVAN AMMORI 

NATHAN HAGER, ASSESSOR 

THE AMMORI GROUP 

CITY OF IMLAY CITY 

Representative for Petitioner 

Representative for Respondent 

77 E. Long Lake Rd., F1 

1 

150 North Main Street 

Bloomfield Hills, MI 48304-2328 

Imlay City, MI 48444 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The case is pending in the 

_X 

Entire Tribunal ___ Small Claims Division. 

2. 

Property Parcel Nos: 

44-119-76-600-001-00; 44-119-76-602-001-00; 44-120-27-300- 

040-02; and 44-119-76-601-001-00. 

3. 

The properties are located at: 572 N. Cedar Street, Imlay City, Lapeer County, MI; 525 

E. Capac Road, Imlay City, Lapeer County, MI; 632 N. Cedar Street, Imlay City, Lapeer 

County, MI; 578 N. Cedar Street, Imlay City, Lapeer County, MI. 

4. 

The 2025 values for the properties identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Parcel Number 

Original TCV 

Original AV 

Original TV

Page 2

MTT Docket No. 25-001710 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

5. 

The 2025 values for the properties identified above as stipulated by the parties for 

settlement purposes are: 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Parcel Number 

Original TCV 

Original AV 

Original TV 

44-119-76-600-001-00 

$200,000 

$100,000 

$100,000 

44-119-76-602-001-00 

$40,000 

$20,000 

$20,000 

44-120-27-300-040-02 

$100,000 

$50,000 

$50,000 

| 44-119-76-601-001-00 

$35,000 

$17,500 

| 

$17,500 

6. 

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): 

7. 

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. (attach additional page if necessary): 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

Signature of Petitioner’s mz or, if none, Petitioner: 

/s/ Ivan Ammori 

— 

9 

g ~ 2029 

Ivan Ammori 

Signature of Respondent’s authorized representative: 

Nathan D. Hager 

09/03/2025 

Nathan Hager 

v

Page 3

Psap Pegervy LLC 

Ivan Ammori 

.,. 

~METROPLEX MI 4 

77 E Long Lake Rd. 

ey 

Co 

5 SEP 2025 PM 

Suite 100 

Bloomfield Hills MI 48804 

MICHIGAN TAX TRIBUNAL 

PO BOX 30232 

LANSING MI 48909-7732 

$0.740 £

US POSTAGE BE

FIRST-CLASS Ei

FROM 48304 [

09/0412025 EB

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 JULY 16 - 31, 2026 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

RSAA Property LLC,

Petitioner,

v

 

 

City Of Imlay City,

Respondent.

 MTT Docket No. 25-001710

Please be advised that 25-001710 has been placed on a two-week Prehearing General 

Call commencing July 16, 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 March 19, 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. 25-001710

Page 2 of 2

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

Statements by March 19, 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 

March 19, 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 

July 16, 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: August 18, 2025

Page 3

STATE

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Page 1

RECEIVED 

JUL 11 2025 

MICHIGA 

STATE OF MICHIGAN 

N TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RSAA Property LLC, 

Petitioner, 

vs. 

MOAHR Docket No. 25-001710 

City of Imlay City, 

Respondent. 

PROOF OF SERVICE 

(Property Tax Petition) 

On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: 

City Assessor 

City Clerk 

City of Imlay City 

City of Imlay City 

150 North Main Street 

150 North Main Street 

Imlay City, MI 48444 

Imlay City, MI 48444 

On the date below I sent by first class mail a copy of the Petition to: 

County Clerk 

Lapeer County 

255 Clay Street 

Lapeer, MI 48446 

Equalization Director 

Lapeer County 

255 Clay Street 

Lapeer, MI 48446 

Secretary, Board of Education 

Imlay City Community Schools 

634 W Borland Rd 

Imlay City, MI 48444 

State Treasurer 

Department of Treasury 

430 W. Allegan Street 

Lansing, MI 48922 

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

/s/ Ivan Ammori

Page 2

RECEIVED 

q 

APR 8 0 2025 

J 

STATE OF mvircHiGHIgAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

RSAA Property LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 25- 001710 

City of Imlay City, 

Parcel No.: 

44-119-76-600-001-00, 

Respondent. 

and additional parcels 

PROPERTY TAX PETITION 

(Entire Tribunal, 2025 Tax Year) 

Petitioner, by and through its representative, contends: 

1. 

The property that is the subject of this appeal consists of these contiguous real property 

parcels: 

REAL PROPERTY - CONTIGUOUS 

Parcel Number 

] 

Address 

Classification 

Use 

44.119-76-600-001-00 

572 N. Cedar Street 

Vacant Auto 

201 Comm 

shop 

44-119-76-602-001-00 

525 E. Capac Road 

201 Comm 

Vacant 

44-120-27-300-040-02 

632 N. Cedar Street 

201 Comm 

Vacant 

44-119-76-601-001-00 

578 N. Cedar Street 

201 Comm 

Vacant 

2. 

BIN/A. 

Ifthe assessment at issue was protested, the protest was made to Respondent’s: 

[0 March, 

[0 July, O December 

Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4, 

The subject property is located in the County of Lapeer and school district of Imlay City 

Community School District. 

5. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 

6. 

The Petitioners principal office/legal residence address is: 77 East Long Lake Road, 1st Floor, 

Bloomfield Hills, MI 48304,

Page 3

® 

the subject property’s true cash and taxable values 

[1 

the subject property’s taxable value only 

there is a dispute as to the value of an addition or loss: 

[J Yes 

OO No 

0 

uniformity of the subject property’s assessment 

O 

the subject property’s exemption from ad valorem taxation under MCL 

8. 

The tax year at issue is 2025. 

9. 

The subject property is listed on the attachment, including, by parcel number: 

a. 

Respondent’s Board of Review established values, 

b. 

 Petitioner’s value contentions, and 

c. 

Values in dispute, 

10. Petitioner relies upon the following to support the relief requested: 

The 2025 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: 

a. 

The assessed, state equalized and/or taxable values exceed the amounts permitted by the 

Michigan Constitution and applicable statutes; 

b. 

The assessed, state equalized and/or taxable values are at higher percentages of true cash 

value than permissible under the Michigan Constitution and applicable statutes; 

c. 

The assessed, 

state equalized and/or taxable values 

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 

d. 

The assessed, state equalized and/or taxable values, and the mode of assessment adopted 

by Respondent, discriminate against Petitioner and deny Petitioner its constitutional 

rights of uniformity, equal protection and due process of law. 

Petitioner requests that the Tribunal enter an order reducing the 2025 values from those established 

by Respondents Board of Review to those contended by Petitioner, and order refunds

Page 4

ATTAC

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Page 1

*** Information herein deemed reliable but not guaranteed***

LAPEER

County:

CITY OF IMLAY CITY

Jurisdiction:

Printed on

Parcel Number:

44-I20-27-300-040-02

0

0

0

0

2022

0

0

0

0

2023

0

0

0

0

2024

111,700S

111,700

46,400

65,300

2025

Taxable

Value

Tribunal/

Other

Board of

Review

Assessed

Value

Building

Value

Land

Value

Year

Land Improvement Cost Estimates

Description Rate Size % Good Cash Value

Commercial Local Cost Land Improvements

Description Rate Size % Good Arch Mult Cash Value

 AVE BASE PARKING 4.00 7000 10 100 2,800

 Total Estimated Land Improvements True Cash Value = 2,800

 * Factors *

Description Frontage Depth Front Depth Rate %Adj. Reason Value

COMM N CED 1.00 PER SQ FT 130680 SqFt 1.00000 100 130,680

 3.00 Total Acres Total Est. Land Value = 130,680

Land Value Estimates for Land Table 00300.00300.COMMERCIALS N CEDAR ST

Who When What

Level

Rolling

Low

High

Landscaped

Swamp

Wooded

Pond

Waterfront

Ravine

Wetland

Flood Plain

 

 

 

 

 

 

 

 

 

 

 

 

 

Topography of 

Site

Dirt Road

Gravel Road

Paved Road

Storm Sewer

Sidewalk

Water

Sewer

Electric

Gas

Curb

Street Lights

Standard Utilities

Underground Utils.

 

 

 

 

 

 

 

 

 

 

 

 

 

Public

Improvements

Vacant

 

Improved

X

The Equalizer. Copyright (c) 1999 - 2009.

Licensed To: City of Imlay City, County of

Lapeer, Michigan

Comments/Influences

PART OF NE 1/4 SEC 17, T7N-R12E; COMM E

1/4 COR SAID SEC 17; TH N 02 04 55 E

429.74 FT TO C/L CAPAC RD/M-21; TH ALONG

SAID C/L N 79 20 00 W 1008.01 FT TO

INTERSECTION CAPAC RD/M-21 & N CEDAR

ST/M-53; TH ALONG C/L N 01 26 42 E 609.66

FT; TH S 89 41 22 E 50.00 FT TO EASTERLY

ROW LN N CEDAR ST/M-53 & POB; TH N 01 27

42 E 78.39 FT; TH S 88 58 08 W 17.02 FT

TO 33 FT ROW LN OF N CEDAR ST/M-53; TH N

01 26 42 E 137.99 FT TO APPROXMIATE C/L

BELLE RIVER; TH S 88 33 18 E 495.00 FT;

TH S 01 26 42 W 67.00 FT; TH S 89 43 10 E

477.42 FT; TH S 02 04 55 W 48.70 FT; TH S

88 45 21 W 455.12 FT; TH S 09 49 13 W

79.47 FT; TH N 89 41 22 W 488.65 FT TO

POB. CONT 3.00 ACRES. BOUD ADJ FOR

2025. 

Tax Description

RSAA PROPERTY LLC

986 CESAR CHAVEZ

PONTIAC MI 48340

Owner's Name/Address

632 N CEDAR ST

Property Address

2025 Est TCV 223,481 TCV/TFA: 190.03

MAP #: 

P.R.E. 0% 

School: IMLAY CITY COMMUNITY SCHOOLS

Status

Number

Date

Building Permit(s)

Zoning: B-3 GEN

Class: COMMERCIAL-IMPROVE

100.0

PROPERTY TRANSFER 

3408/369

19-MULTI PARCEL ARM'S LEN

WD

06/21/2024

310,000

RSAA PROPERTY LLC

SHULL JOSEPH 

0.0

NOT VERIFIED

3408/365

14-INTO/OUT OF TRUST

OTH

06/24/2024

1

SHULL JOSEPH J 

SHULL JOE (D)

Prcnt.

Trans.

Verified

By

Liber

& Page

Terms of Sale

Inst.

Type

Sale

Date

Sale

Price

Grantee

Grantor

07/01/2025

Page 2

*** Information herein deemed reliable but not guaranteed***

Parcel Number: 44-I20-27-300-040-02

Printed on

07/01/2025

Page 3

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

X

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: D Quality: Low Cost

Stories: 1 Story Height: 10 Perimeter: 140

 

Base Rate for Upper Floors = 134.07

 

(10) Heating system: Complete H.V.A.C. Cost/SqFt: 29.11 100%

 Bsmnt Heating system: No Heating or Cooling Cost/SqFt: 0.00

Adjusted Square Foot Cost for Upper Floors = 163.18

Adjusted Square Foot Cost for Basement = 59.51

 

Total Floor Area: 1,176 Base Cost New of Upper Floors = 191,900

 

 Reproduction/Replacement Cost = 191,900

Eff.Age:43 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 52 /100/100/100/52.0

 Total Depreciated Cost = 99,788

 

Basement Area: 1,120 Base Cost New of Basement = 66,651

Eff.Age:43

Page 4

*** Information

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

*** Information herein deemed reliable but not guaranteed***

LAPEER

County:

CITY OF IMLAY CITY

Jurisdiction:

Printed on

Parcel Number:

44-I19-76-602-001-00

0

0

0

0

2022

0

0

0

0

2023

0

0

0

0

2024

64,300S

64,300

18,600

45,700

2025

Taxable

Value

Tribunal/

Other

Board of

Review

Assessed

Value

Building

Value

Land

Value

Year

Land Improvement Cost Estimates

Description Rate Size % Good Cash Value

Commercial Local Cost Land Improvements

Description Rate Size % Good Arch Mult Cash Value

 LC BASE PARKING 2.80 4200 10 100 1,176

 Total Estimated Land Improvements True Cash Value = 1,176

 * Factors *

Description Frontage Depth Front Depth Rate %Adj. Reason Value

M-21 COMME 2.50 PER SQ FT 36590 SqFt 2.50000 100 91,476

 0.84 Total Acres Total Est. Land Value = 91,476

Land Value Estimates for Land Table 00400.00400.COMMERCIALS M-21 (CAPAC RD)

Who When What

Level

Rolling

Low

High

Landscaped

Swamp

Wooded

Pond

Waterfront

Ravine

Wetland

Flood Plain

 

 

 

 

 

 

 

 

 

 

 

 

 

Topography of 

Site

Dirt Road

Gravel Road

Paved Road

Storm Sewer

Sidewalk

Water

Sewer

Electric

Gas

Curb

Street Lights

Standard Utilities

Underground Utils.

 

 

 

 

 

 

 

 

 

 

 

 

 

Public

Improvements

Vacant

 

Improved

X

The Equalizer. Copyright (c) 1999 - 2009.

Licensed To: City of Imlay City, County of

Lapeer, Michigan

Comments/Influences

PART OF SE /14 OF NE 1/4 SEC 17, T7N-R12E

 COMM E 1/4 COR SAID SEC 17; TH N 02 04

55 E 429.74 FT TO C/L CAPAC RD/M-21; TH

ALONG SAID C/L N 79 20 00 W 565.47 FT TO

POB; TH N 79 20 00 W 135.07 FT; TH N 10

40 00 E 45.00 FT TO 45 FT ROW LINE FOR

CAPAC RD/M-21; TH ALONG SAID ROW LN N 79

20 00 W 62.60 FT; TH N 09 49 13 E 40.00

FT; TH S 79 20 00 E 102.72 FT; TH S 09 49

13 W 236.16 FT TO POB. CONT 0.840 ACRE. 

SPLIT/BOUND ADJ FOR 2025. 

Tax Description

RSAA PROPERTY LLC

986 CESAR CHAVEZ

PONTIAC MI 48340

Owner's Name/Address

525 E CAPAC RD

Property Address

2025 Est TCV 128,655 TCV/TFA: 99.89

MAP #: 

P.R.E. 0% 

School: IMLAY CITY COMMUNITY SCHOOLS

Status

Number

Date

Building Permit(s)

Zoning: B-3 GEN

Class: COMMERCIAL-IMPROVE

100.0

PROPERTY TRANSFER 

3408/369

19-MULTI PARCEL ARM'S LEN

WD

06/21/2024

310,000

RSAA PROPERTY LLC

SHULL JOSEPH 

0.0

NOT VERIFIED

3408/365

14-INTO/OUT OF TRUST

OTH

06/24/2024

1

SHULL JOSEPH J 

SHULL JOE (D)

Prcnt.

Trans.

Verified

By

Liber

& Page

Terms of Sale

Inst.

Type

Sale

Date

Sale

Price

Grantee

Grantor

07/01/2025

Page 2

*** Information herein deemed reliable but not guaranteed***

Parcel Number: 44-I19-76-602-001-00

Printed on

07/01/2025

Page 3

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

X

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: C Quality: Low Cost

Stories: 1 Story Height: 12 Perimeter: 148

 

Base Rate for Upper Floors = 69.25

 

(10) Heating system: Forced Air Furnace Cost/SqFt: 12.59 100%

Adjusted Square Foot Cost for Upper Floors = 81.84

 

Total Floor Area: 1,288 Base Cost New of Upper Floors = 105,410

 

 Reproduction/Replacement Cost = 105,410

Eff.Age:58 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 45 /100/100/100/45.0

 Total Depreciated Cost = 47,435

 

ECF (00400.COMMERCIALS M-21 (CAPAC RD)) 0.759 => TCV of Bldg: 1 = 36,003

 Replacement Cost/Floor Area= 81.84 Est. TCV/Floor Area= 27.95

 ** ** Calculator Cost Data ** **

Quality: Low Cost 

Heat#1: Forced Air Furnace 100%

Heat#2: Space Heaters, Gas with Fan 0%

Ave. SqFt/Story: 1288

Ave. Perimeter: 148

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type: Finished Basement

Heat: No Heating or Cooling

 

 * Mezzanine Info *

Area

Page 4

***

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

*** Information herein deemed reliable but not guaranteed***

LAPEER

County:

CITY OF IMLAY CITY

Jurisdiction:

Printed on

Parcel Number:

44-I19-76-601-001-00

0

0

0

0

2022

0

0

0

0

2023

0

0

0

0

2024

81,600S

81,600

16,000

65,600

2025

Taxable

Value

Tribunal/

Other

Board of

Review

Assessed

Value

Building

Value

Land

Value

Year

Land Improvement Cost Estimates

Description Rate Size % Good Cash Value

Commercial Local Cost Land Improvements

Description Rate Size % Good Arch Mult Cash Value

 LC BASE PARKING 2.80 3000 10 100 840

 Total Estimated Land Improvements True Cash Value = 840

 * Factors *

Description Frontage Depth Front Depth Rate %Adj. Reason Value

COMM N CED 1.00 PER SQ FT 131203 SqFt 1.00000 100 131,203

 3.01 Total Acres Total Est. Land Value = 131,203

Land Value Estimates for Land Table 00300.00300.COMMERCIALS N CEDAR ST

Who When What

Level

Rolling

Low

High

Landscaped

Swamp

Wooded

Pond

Waterfront

Ravine

Wetland

Flood Plain

 

 

 

 

 

 

 

 

 

 

 

 

 

Topography of 

Site

Dirt Road

Gravel Road

Paved Road

Storm Sewer

Sidewalk

Water

Sewer

Electric

Gas

Curb

Street Lights

Standard Utilities

Underground Utils.

 

 

 

 

 

 

 

 

 

 

 

 

 

Public

Improvements

Vacant

 

Improved

X

The Equalizer. Copyright (c) 1999 - 2009.

Licensed To: City of Imlay City, County of

Lapeer, Michigan

Comments/Influences

PART OF SE 1/4 OF NE 1/4 SEC 17,

T7N-R12E; COMM E 1/4 COR SAID SEC 17; TH

N 02 04 55 E 429.74 FT TO C/L OF CAPAC

RD/M-21; TH ALONG SAID C/L N 49 20 00 W

1008.01 FT TO INTERSECTION OF CAPAC

RD/M-21 & N CEDAR ST/M-53; TH ALONG C/L N

CEDAR ST/M-53 N 01 26 42 E 334.66 FT; TH

S 88 33 18 E 50.00 FT TO A PT ON EASTERLY

ROW LN OF N CEDAR ST/M-53 AND POB; TH N

01 26 42 E 275.99 FT; TH S 89 41 22 E

488.65 FT; TH S 09 49 13 W 288.74 FT;L TH

N 88 33 18 W 446.53 FT TO POB. CONT

3.012 ACRES. BOUND ADJ FOR 2025. 

Tax Description

RSAA PROPERTY LLC

986 CESAR CHAVEZ

PONTIAC MI 48340

Owner's Name/Address

578 N CEDAR ST

Property Address

2025 Est TCV 163,182 TCV/TFA: 221.71

MAP #: 

P.R.E. 0% 

School: IMLAY CITY COMMUNITY SCHOOLS

Status

Number

Date

Building Permit(s)

Zoning: B-3 GEN

Class: COMMERCIAL-IMPROVE

100.0

PROPERTY TRANSFER 

3408/369

20-MULTI PARCEL SALE REF

WD

06/21/2024

310,000

RSAA PROPERTY LLC

SHULL JOSEPH 

0.0

NOT VERIFIED

3408/365

14-INTO/OUT OF TRUST

OTH

06/24/2024

1

SHULL JOSEPH J 

SHULL JOE (D)

Prcnt.

Trans.

Verified

By

Liber

& Page

Terms of Sale

Inst.

Type

Sale

Date

Sale

Price

Grantee

Grantor

07/01/2025

Page 2

*** Information herein deemed reliable but not guaranteed***

Parcel Number: 44-I19-76-601-001-00

Printed on

07/01/2025

Page 3

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

X

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: D Quality: Average

Stories: 1 Story Height: 8 Perimeter: 104

 

Base Rate for Upper Floors = 132.50

 

(10) Heating system: Wall or Floor Furnace Cost/SqFt: 5.11 100%

Adjusted Square Foot Cost for Upper Floors = 137.61

 

Total Floor Area: 640 Base Cost New of Upper Floors = 88,070

 

 Reproduction/Replacement Cost = 88,070

Eff.Age:58 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 45 /100/100/100/45.0

 Total Depreciated Cost = 39,632

 

ECF (00300.COMMERCIALS N CEDAR ST) 0.759 => TCV of Bldg: 1 = 30,080

 Replacement Cost/Floor Area= 137.61 Est. TCV/Floor Area= 47.00

 ** ** Calculator Cost Data ** **

Quality: Average 

Heat#1: Wall or Floor Furnace 100%

Heat#2: Package Heating & Cooling 0%

Ave. SqFt/Story: 640

Ave. Perimeter: 104

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type: Display

Page 4

***

Page 5

Bsmnt

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

*** Information herein deemed reliable but not guaranteed***

LAPEER

County:

CITY OF IMLAY CITY

Jurisdiction:

Printed on

Parcel Number:

44-I19-76-600-001-00

0

0

0

0

2022

0

0

0

0

2023

0

0

0

0

2024

176,600S

176,600

122,600

54,000

2025

Taxable

Value

Tribunal/

Other

Board of

Review

Assessed

Value

Building

Value

Land

Value

Year

Land Improvement Cost Estimates

Description Rate Size % Good Cash Value

Commercial Local Cost Land Improvements

Description Rate Size % Good Arch Mult Cash Value

 LC BASE PARKING 2.80 28000 10 100 7,840

 Total Estimated Land Improvements True Cash Value = 7,840

 * Factors *

Description Frontage Depth Front Depth Rate %Adj. Reason Value

COMM N CED 1.00 PER SQ FT 107985 SqFt 1.00000 100 107,985

 2.48 Total Acres Total Est. Land Value = 107,985

Land Value Estimates for Land Table 00300.00300.COMMERCIALS N CEDAR ST

Who When What

Level

Rolling

Low

High

Landscaped

Swamp

Wooded

Pond

Waterfront

Ravine

Wetland

Flood Plain

 

 

 

 

 

 

 

 

 

 

 

 

 

Topography of 

Site

Dirt Road

Gravel Road

Paved Road

Storm Sewer

Sidewalk

Water

Sewer

Electric

Gas

Curb

Street Lights

Standard Utilities

Underground Utils.

 

 

 

 

 

 

 

 

 

 

 

 

 

Public

Improvements

Vacant

 

Improved

X

The Equalizer. Copyright (c) 1999 - 2009.

Licensed To: City of Imlay City, County of

Lapeer, Michigan

Comments/Influences

PART OF SE 1/4 OF NE 1/4 SEC 17, T7N-R12E

 COMM E 1/4 COR SAID SEC 17; TH N 02 04

55 E 429.74 FT TO C/L CAPAC RD/M-21; TH

ALONG SAID C/L N 79 20 00 W 700.54 FT; TH

N 10 40 00 E 45.00 FT TO A PT ON 45 FT

ROW LN OF CAPAC RD/M-21; TH ALONG SAID

ROW LNN 49 20 00 W 62.60 FT TO POB; TH N

49 20 00 W 166.37 FT; TH N 40 48 00 W

51.61 FT; TH ALONG EASTERLY 50 FT ROW LN

FOR N CEDAR ST/M-53N 01 26 42 E 264.62

FT; TH S 88 33 18 E 446.53 FT; TH S 09 49

13 W 173.79 FT; TH N 49 20 00 W 102.72

FT; TH S 42 00 00 W 176.95 FT; TH S 09 49

13 W 40.00 FT TO POB. CONT 2.479 ACRES. 

BOUND ADJ FOR 2025. 

Tax Description

RSAA PROPERTY LLC

986 CESAR CHAVEZ

PONTIAC MI 48340

Owner's Name/Address

572 N CEDAR ST

Property Address

2025 Est TCV 353,134 TCV/TFA: 25.36

MAP #: 

P.R.E. 0% 

School: IMLAY CITY COMMUNITY SCHOOLS

Status

Number

Date

Building Permit(s)

Zoning: B-3 GEN

Class: COMMERCIAL-IMPROVE

100.0

PROPERTY TRANSFER 

3408/369

20-MULTI PARCEL SALE REF

WD

06/21/2024

310,000

RSAA PROPERTY LLC

SHULL JOSEPH 

0.0

NOT VERIFIED

3408/365

14-INTO/OUT OF TRUST

OTH

06/24/2024

1

SHULL JOSEPH J 

SHULL JOE (D)

0.0

NOT VERIFIED

3408/365

14-INTO/OUT OF TRUST

OTH

06/24/2024

1

SHULL JOSEPH J 

SHULL JOE (D)

Prcnt.

Trans.

Verified

By

Liber

& Page

Terms of Sale

Inst.

Type

Sale

Date

Sale

Price

Grantee

Grantor

07/01/2025

Page 2

*** Information herein deemed reliable but not guaranteed***

Parcel Number: 44-I19-76-600-001-00

Printed on

07/01/2025

Page 3

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Few

Average

Many

Unfinished

Typical

X

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

X

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: C Quality: Low Cost

Stories: 1 Story Height: 11 Perimeter: 400

Overall Building Height: 12

 

Base Rate for Upper Floors = 25.39

 

(10) Heating system: Space Heaters, Radiant Cost/SqFt: 5.38 90%

(10) Heating system: Package Heating & Cooling Cost/SqFt: 18.50 10%

 Combined Heating System adjustment: 6.69 100%

Adjusted Square Foot Cost for Upper Floors = 32.08

 

Total Floor Area: 8,748 Base Cost New of Upper Floors = 280,657

 

 Reproduction/Replacement Cost = 280,657

Eff.Age:53 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 45 /100/100/100/45.0

 Total Depreciated Cost = 126,296

 

Local Cost Items Rate Quantity/Area %Good

Page 4

***

Page 5

Bs

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

RSAA Property LLC, 

 

 

 

Petitioner, 

 

v 

 

City of Imlay City, 

 

Respondent.

 

 

 

 Docket No. 25-001710 

 

_____________________________________________________________________________/ 

Ivan Ammori 

 

 

 

 

Nathan Hager 

The Ammori Group 

 

 

 

City Assessor 

Representative for Petitioner 

 

 

Representative for Respondent 

77 E. Long Lake Rd, Fl 1 

 

 

 

150 North Main Street 

Bloomfield Hills, MI 48304-2328 

 

 

Imlay City, MI 48444 

______________________________________________________________________ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent City of Imlay City, 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 the parcel number, address, 

classification, County, and school district. 

 

2. 

Respondent admits that no Board of Review protest was made. 

 

3. 

Respondent admits the allegations in Paragraph 3. 

 

4. 

Respondent lacks the information necessary to respond to the allegations in Paragraph 4 

and leaves Petitioner to its proofs. 

 

5. 

Respondent lacks the information necessary to respond to the allegations in Paragraph 5 

and leaves Petitioner to its proofs.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

6. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal, but denies 

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

 

7. 

Respondent admits the allegations in Paragraph 7. 

 

8. 

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

Review are as stated in Petitioner’s Petition. 

 

9. 

Respondent contends that the values for the properties are as reflected on Respondent’s 

assessment roll. 

 

10. 

The values in dispute for all the properties are: 

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

2025

$268,400

$134,200

$134,200

 

11. 

Petitioner is not entitled to the relief requested in Paragraph 11, including all 

subparagraphs, for the reason that Petitioner’s amounts do not reflect the accurate 

valuations for this property. 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 principals, and the values and Respondent’s mode of assessment are non-

discriminatory and constitutional. 

 

WHEREFORE, Respondent City of Imlay City 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. 

CITY OF IMLAY CITY 

 

 

____________________________________ 

Nathan Hager 

City Assessor 

Representative for Respondent 

150 North Main Street 

 

 

 

 

 

 

 

Imlay City, MI 48444 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent City of Imlay City asserts the following affirmative defenses:

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

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 arrive at the

Page 4

Entire

Page 5

En

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

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001710

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Imlay City (LAPEER)

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

Nathan

M.I.

D

Last Name

Hager

Firm Name (if any)

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

7469 Clifford Rd

City or Town

Marlette

State

Michigan

ZIP Code

48453

Telephone Number

810-614-8487

Fax Number

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

ndhager@yahoo.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Nathan D. Hager

/s/

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

RECEIVED 

APR 80 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

Py 00 oT 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

= 

IN THE MICHIGAN TAX TRIBUNAL 

1995 Cedar Street LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 25- 

City of Imlay City 

Parcel No. 

44-119-85-253-040-00 

Respondent. 

TranInfo:4606 

26005015-1 

04/28/25 

PROPERTY TAX PETITION 

(hj: 

5017 

nt: $1,325.00 

(Entire Tribunal, 2025 Tax Year) [[: 

[UA Ad0R] 

[A045 Ceddx Steck-%100.°C 

gin 

fein 

db 

joni BO 

Petitioner contends: 

ivan Hodingy a op BHD. 

sh @-Yroperty 2338.0 

Is 

The property that is the subject of this appeal is one real property parcel: 

Parcel Number | 44-119-85-253-040-00 

Address 

1995 S. Cedar Street 

Classification 

201 Comm Imp 

Use 

Medical Office 

County 

Lapeer 

Sch Dist 

| Imlay City Community School 

District 

2. 

N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[OJ March, 

[0 July, 

OO December 

Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner 

is 

a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 

77 E. Long Lake Rd, Fl 

I, 

Bloomfield Hills, MI 48304-2328. 

6. 

This appeal involves issues related to:

Page 2

RECEIVED 

$s 

APR 3 0 2025 

LN 

9) 

STATE OF MICHIGHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

RSAA Property LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 25- 

City of Imlay City, 

Parcel No.: 

44-119-76-600-001-00, 

Respondent. 

and additional parcels 

PROPERTY TAX PETITION 

(Entire Tribunal, 2025 Tax Year) 

Petitioner, by and through its representative, contends: 

1. 

The property that is the subject of this appeal consists of these contiguous real property 

parcels: 

REAL PROPERTY - CONTIGUOUS 

Parcel Number 

] 

Address 

Classification 

Use 

44-119-76-600-001-00 

572 N. Cedar Street 

Vacant Auto 

201 Comm 

shop 

44-119-76-602-001-00 

525 E. Capac Road 

201 Comm 

Vacant 

44-120-27-300-040-02 

632 N. Cedar Street 

201 Comm 

Vacant 

44-119-76-601-001-00 

578 N. Cedar Street 

201 Comm 

Vacant 

| 

2. 

KIN/A. 

Ifthe assessment at issue was protested, the protest was made to Respondent’s: 

OO March, 

[OO July, 0 December 

Board of Review. 

| 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

The subject property is located in the County of Lapeer and school district of Imlay City 

Community School District. 

5. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 

6. 

The Petitioners principal office/legal residence address is: 77 East Long Lake Road, 1st Floor,

Page 3

X 

O 

the subject property’s true cash and taxable values 

the subject property’s taxable value only 

there is a dispute as to the value of an addition or loss: 

[J Yes 

[I No 

uniformity of the subject property’s assessment 

the subject property’s exemption from ad valorem taxation under MCL 

8. 

The tax year at issue is 2025. 

9. 

The subject property is listed on the attachment, including, by parcel number: 

a. 

b. 

c. 

Respondent’s Board of Review established values, 

Petitioner’s value contentions, and 

Values in dispute. 

10. Petitioner relies upon the following to support the relief requested: 

The 2025 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: 

a. 

The assessed, state equalized and/or taxable values exceed the amounts permitted by the 

Michigan Constitution and applicable statutes; 

The assessed, state equalized and/or taxable values are at higher percentages of true cash 

value than permissible under the Michigan Constitution and applicable statutes; 

The assessed, 

state equalized and/or taxable values 

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 

The assessed, state equalized and/or taxable values, and the mode of assessment adopted 

by Respondent, discriminate against Petitioner and deny Petitioner its constitutional

Page 4

ATTACHME

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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

RSAA Property LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001710

City Of Imlay City, 

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: May 29, 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

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

RECEIVED 

APR 80 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

Py 00 oT 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

= 

IN THE MICHIGAN TAX TRIBUNAL 

1995 Cedar Street LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 25- 

City of Imlay City 

Parcel No. 

44-119-85-253-040-00 

Respondent. 

TranInfo:4606 

26005015-1 

04/28/25 

PROPERTY TAX PETITION 

(hj: 

5017 

nt: $1,325.00 

(Entire Tribunal, 2025 Tax Year) [[: 

[UA Ad0R] 

[A045 Ceddx Steck-%100.°C 

gin 

fein 

db 

joni BO 

Petitioner contends: 

ivan Hodingy a op BHD. 

sh @-Yroperty 2338.0 

Is 

The property that is the subject of this appeal is one real property parcel: 

Parcel Number | 44-119-85-253-040-00 

Address 

1995 S. Cedar Street 

Classification 

201 Comm Imp 

Use 

Medical Office 

County 

Lapeer 

Sch Dist 

| Imlay City Community School 

District 

2. 

N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[OJ March, 

[0 July, 

OO December 

Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner 

is 

a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 

77 E. Long Lake Rd, Fl 

I, 

Bloomfield Hills, MI 48304-2328. 

6. 

This appeal involves issues related to:

Page 2

RECEIVED 

$s 

APR 3 0 2025 

LN 

9) 

STATE OF MICHIGHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

RSAA Property LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 25- 

City of Imlay City, 

Parcel No.: 

44-119-76-600-001-00, 

Respondent. 

and additional parcels 

PROPERTY TAX PETITION 

(Entire Tribunal, 2025 Tax Year) 

Petitioner, by and through its representative, contends: 

1. 

The property that is the subject of this appeal consists of these contiguous real property 

parcels: 

REAL PROPERTY - CONTIGUOUS 

Parcel Number 

] 

Address 

Classification 

Use 

44-119-76-600-001-00 

572 N. Cedar Street 

Vacant Auto 

201 Comm 

shop 

44-119-76-602-001-00 

525 E. Capac Road 

201 Comm 

Vacant 

44-120-27-300-040-02 

632 N. Cedar Street 

201 Comm 

Vacant 

44-119-76-601-001-00 

578 N. Cedar Street 

201 Comm 

Vacant 

| 

2. 

KIN/A. 

Ifthe assessment at issue was protested, the protest was made to Respondent’s: 

OO March, 

[OO July, 0 December 

Board of Review. 

| 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

The subject property is located in the County of Lapeer and school district of Imlay City 

Community School District. 

5. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 

6. 

The Petitioners principal office/legal residence address is: 77 East Long Lake Road, 1st Floor,

Page 3

X 

O 

the subject property’s true cash and taxable values 

the subject property’s taxable value only 

there is a dispute as to the value of an addition or loss: 

[J Yes 

[I No 

uniformity of the subject property’s assessment 

the subject property’s exemption from ad valorem taxation under MCL 

8. 

The tax year at issue is 2025. 

9. 

The subject property is listed on the attachment, including, by parcel number: 

a. 

b. 

c. 

Respondent’s Board of Review established values, 

Petitioner’s value contentions, and 

Values in dispute. 

10. Petitioner relies upon the following to support the relief requested: 

The 2025 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: 

a. 

The assessed, state equalized and/or taxable values exceed the amounts permitted by the 

Michigan Constitution and applicable statutes; 

The assessed, state equalized and/or taxable values are at higher percentages of true cash 

value than permissible under the Michigan Constitution and applicable statutes; 

The assessed, 

state equalized and/or taxable values 

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 

The assessed, state equalized and/or taxable values, and the mode of assessment adopted 

by Respondent, discriminate against Petitioner and deny Petitioner its constitutional

Page 4

ATTACHME

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.