Ssp Associates Inc, Petitioner Vs. Township Of Saginaw, Respondent
- Petitioner
- Ssp Associates Inc
- Respondent
- Township Of Saginaw
Case overview
- Docket number
- 25-002492-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Saginaw
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 17 | Answer was received | RESP | Not recorded | 07/26/2025 | Not recorded | Download |
| 16 | Order of Dismissal | Not recorded | Not recorded | 10/17/2025 | Not recorded | Download |
| 15 | Documentation | RESP | Not recorded | 10/17/2025 | Not recorded | Download |
| 14 | Proof of Service of Misc Documents was received. | RESP | Not recorded | 10/17/2025 | Not recorded | Download |
| 13 | A response to motion was filed. | RESP | Not recorded | 10/17/2025 | Not recorded | Download |
| 12 | Notice of Filing of Motion to Withdraw | Not recorded | Not recorded | 10/17/2025 | Not recorded | Download |
| 11 | Motion to Withdraw Appeal was received. | Not recorded | Not recorded | 10/17/2025 | $0.00 | Download |
| 10 | Granted | RESP | 6 | 10/16/2025 | Not recorded | Download |
| 9 | Order granting Motion. | Not recorded | 6 | 10/16/2025 | Not recorded | Download |
| 8 | Documentation | RESP | Not recorded | 09/16/2025 | Not recorded | Download |
| 7 | Proof of Service of Misc Documents was received. | RESP | Not recorded | 09/16/2025 | Not recorded | Download |
| 6 | Motion to Compel was received. | RESP | Not recorded | 09/16/2025 | $50.00 | Download |
| 5 | Proof of service of petition was received. | Not recorded | Not recorded | 08/15/2025 | Not recorded | Download |
| 4 | Appearance | RESP | Not recorded | 07/01/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 07/01/2025 | Not recorded | Download |
| 2 | A petition has been filed. | Not recorded | Not recorded | 06/30/2025 | Not recorded | Download |
| 1 | Order Severing 2025 Tax Year from 24-002208 | Not recorded | Not recorded | 06/24/2025 | Not recorded | Download |
Documents
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Page 1
RECEIVED JUL 29 2025 MICHIGAN TAX TRIBUNAL FRANCIS J. KEATING Attorney TEL: 989.631.1027 FAX: 989.631.9880 EMAIL: frakea@braunkendrick.com July 25, 2025 Ms. Samantha M. Welton Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 Re: SSP Associates Inc v Township of Saginaw MTT Docket No.: 25-002492 Dear Ms. Welton: Enclosed please find the following for the above-referenced matter: 1. Respondent’s Answer to Entire Tribunal Property Tax Petition; and 2. Proof of Service. Please file them in your usual manner. Thank you for your attention to this matter. If you have any questions regarding it, please contact me. CIS J. KEATING FJK/Is Enclosures
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S ANSWER TO ENTIRE TRIBUNAL PROPERTY TAX PETITION NOW COMES Respondent, Township of Saginaw, by and through its attorneys, Braun Kendrick Finkbeiner P.L.C., and for its Answer to Petition, states as follows: 1. 2, Admitted. Admitted. N/A. No parcels of personal property are under appeal. N/A. Admitted.
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10. Admitted. 11. Admitted. 12. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 12. 13. Respondent admits that Petitioner’s Petition states that this appeal involves issues relating to the property’s true cash value and taxable value. 14. Admitted. 15. N/A. 16. Admitted. 17. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 17. 18. Respondent admits that Petitioner has correctly computed the values in dispute by subtracting its erroneous value claims from the values correctly determined by Respondent. 19. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 19 regarding what Petitioner requests. Respondent denies as untrue that Petitioner is entitled to the relief it is requesting. 20. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 20 regarding what Petitioner requests. Respondent denies as untrue that Petitioner is entitled to the relief it is requesting. NEW MATTERS AND AFFIRMATIVE DEFENSES 1. Petitioner has failed to allege specific and sufficient facts to set forth a cause of
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3. Petitioner may not be the real party in interest to bring this tax appeal. 4. Petitioner may not have standing to bring this tax appeal. S. 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 respective assessments appearing on the roll, and also fails to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper. 6. Respondent has properly and lawfully assessed Petitioner’s property and established its taxable value in accordance with statutory and constitutional
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STATE OF
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BX
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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 SSP Associates Inc, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002492 Township Of Saginaw, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner has filed a Motion to Withdraw the Petition and Respondent has filed a Response concurring with the requested withdrawal Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending issues and closes the case. APPEAL RIGHTS If you disagree with the final decision in this case, you may file a motion for reconsideration with the Tribunal or a claim of appeal with the Michigan Court of Appeals. A motion for reconsideration must be filed with the Tribunal with the required filing fee within 21 days from the date of entry of the final decision. Because the final decision closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing system; it must be filed by mail or personal service. The fee for the filing of such motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless the Small Claims decision relates to the valuation of property and the property had a principal residence exemption of at least 50% at the time the petition was filed or the decision relates to the grant or denial of a poverty or disabled veterans exemption and, if so, there is no filing fee. You are required to serve a copy of the motion on the opposing party by mail or personal service or by email if the opposing party agrees to electronic service, and proof demonstrating that service must be submitted with the motion. Responses to motions for reconsideration are prohibited and there are no oral arguments unless otherwise ordered by the Tribunal. Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If
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MTT Docket No. 25-002492 Page 2 of 6 the claim is filed more than 21 days after the entry of the final decision, it is an “appeal by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the record on appeal. There is no certification fee. By:___________________________________ Patricia L. Halm, Tribunal Chair Entered: October 17, 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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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 SSP Associates Inc, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002492 Township Of Saginaw, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner has filed a Motion to Withdraw the
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MTT
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S
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BRAUN KENDRICK FRANCIS J. KEATING ATTORNEYS AT LAW Attorney TEL: 989.631.1027 FAX: 989.631.9880 EMAIL: frakea@braunkendrick.com October 17, 2025 VIA ELECTRONIC FILING Ms. Samantha M. Welton Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 Re: SSP Associates Inc v Township of Saginaw MTT Docket No.: 25-002492 Dear Ms. Welton: Enclosed please find Respondent’s Consent to Withdraw Appeal and Proof of Service for the above- referenced matter. Please file the same in your usual manner. Thank you for your attention to this matter. If you have any questions regarding it, please contact me. Very trul NCIS J. KEATING FIK/Is Enclosures cc: Client (w/encs) Steve Johnson (w/encs) 4922-8716-7092, v. 1 BRAUN KENDRICK FINKBEINER PL.C. MIDLAND in St. St MT. PLEASANT BRAUNKENDRICK.COM
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
SSP ASSOCIATES INC,
Petitioner,
MTT Docket No.: 25-002492
v
TOWNSHIP OF SAGINAW,
Respondent.
MICHIGAN TAX APPEAL SERVICES
BRAUN KENDRICK FINKBEINER P.L.C.
By:
Steve Johnson
By:
Francis J. Keating (P39223)
Representative for Petitioner
Attorneys for Respondent
436 N. Center St.
4301 Fashion Square Blvd.
Northville, MI 48167
Saginaw, MI 48603
(248) 392-4342
(989) 498-2100
sjohnson@mitaxappeal.com
frakea@braunkendrick.com
PROOF OF SERVICE
LEE STADLER, duly sworn, deposes and says that she is a secretary in the employ of
BRAUN KENDRICK Se
PUL Es
attorneys
for
the
Respondent,
Township
of
Saginaw, and states that on the
{\
y of October, 2025, she served a copy of Respondent’s
Consent to Withdraw Appeal by first class mail, by placing same in an envelope with sufficient
postage attached and plainly addressed to:
Steve Johnson, 436 N. Center St., Northville, MI
48167.
nae Shea
LEE STADLER
4910-3483-9668, v. 1These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S CONSENT TO WITHDRAW APPEAL NOW COMES, Respondent, Township of Saginaw, by and through its attorneys, and hereby consents to Petitioner’s withdrawal of this entire property tax appeal. BRAUN KENDRICK FINKBEINER P.L.C. Dated: October /7/ 2025 BY: PRANCIS/I. KEATING (P39223) Attornayg for Respondent 4926-2985-4836, v. 1
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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 SSP Associates Inc, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002492 Township Of Saginaw, Respondent. NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above- captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or representatives), Respondent has seven days from the service of the motion to file a response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of the case or by objecting to the motion. If Respondent does not timely submit a concurrence or objection to the request, it will be deemed to be a concurrence and the request will be granted, unless otherwise ordered by the Tribunal. If the request is granted, the case will be dismissed. If a request is not granted or the Tribunal has not notified you that it has been granted, you are required to attend the hearing. For your convenience, you may use the Tribunal’s form “Response to Motion to Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small Claims” page, depending on the division in which the case is pending. To submit the response, please fill out the form and file it with the Tribunal by e-mail or e-filing.1 By: Tribunal Clerk__________ Entered: October 17, 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 1 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the efficient administration of justice.
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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 SSP Associates Inc, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002492 Township Of Saginaw, Respondent. NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above- captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or representatives), Respondent has seven days from the service of the motion to file a response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of the case or by objecting to the motion. If Respondent does not timely submit a concurrence or objection to the request, it will be deemed to be a concurrence and the request will be granted, unless otherwise ordered by the Tribunal. If the request is granted, the case will be dismissed. If a request is not granted or the Tribunal has not notified you that it has been granted, you are required to attend the hearing. For your convenience, you may use the Tribunal’s form “Response to Motion to
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. ______________________________________________________________________________ MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com ______________________________________________________________________________ PETITIONER’S MOTION TO WITHDRAW APPEAL Petitioner, by and through its Representative, states the following in support of its above captioned request: 1. As of the date of this filing the above noted case has not been placed on a prehearing general call. Respondent has filed an answer. 2. The same parcel at issue in this case is at issue in MTT 24-002208. Indeed, the 2025 tax year began as part of the 2024 appeal and was severed to this docket. 3. In light of the pending 2024 appeal and that any reduction in value from that year will carry forward into the 2025 assessment, Petitioner has determined that it is no longer necessary to pursue two cases at the same time and wishes to have this case dismissed with prejudice and without costs to either party.
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2 4. Respondent will not be harmed nor prejudiced by the dismissal of this case involving only the 2025 tax year. Petitioner informed Respondent that it desired to dismiss the case on October 9, 2025 and sought concurrence in the request but Respondent did not reply. There is good cause to dismiss this matter with prejudice and without costs to either party due to the status of the case. Said relief is in the interest of efficient administration of justice. Respondent has been served with a copy of this request as set forth below. WHEREFORE, Petitioner, by and through its representative, requests that the Tribunal enter an Order dismissing the above captioned appeal with prejudice and without costs to either party. By: /s/ Steve Johnson__________ Steve Johnson Michigan Tax Appeal Services Representative for Petitioner 436 N. Center St. Northville, MI 48167 616-710-4119
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3 PROOF OF SERVICE On the date below I sent by electronic mail a copy of the foregoing motion to dismiss to: Francis J. Keating, Esq. frakea@braunkendrick.com I declare that the statement above is true to the best of my information, knowledge and belief. _/s/Rebecca Adler Dated: October 17, 2025 Rebecca Adler
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S MOTION TO COMPEL DISCOVERY NOW COMES Respondent, Township of Saginaw, by and through its attorneys, Braun Kendrick Finkbeiner P.L.C., and for its Motion to Compel Discovery states the following: 1. On August 11, 2025, Respondent served Respondent’s Interrogatories and Request for Production of Documents to Petitioner, upon Petitioner (“Discovery Request”). A copy of this Discovery Request and Proof of Service is attached hereto and incorporated herein as Exhibit A. 2. Petitioner’s response to said Discovery Request was due on September 8, 2025. 3. Petitioner has not responded formally or informally to Respondent’s August 11, 2025 Discovery Request. 4927-6064-4199, v. 1
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4. More than a week ago, Petitioner’s Representative indicated she was out of the office and will provide the responses when she returned to the office. To date, no responses have been received. 53 Petitioner’s failure to timely assert any objections to said Discovery Request constitutes a complete waiver of any such objections. 6. Petitioner’s Representative has advised Respondent that appraisals are necessary in this case. 1k The information Respondent requested, and asks the Tribunal to compel disclosure of, is relevant and required for Respondent’s preparation for this property tax appeal. WHEREFORE, Respondent requests that this Honorable Tribunal grant it the following relief: A. Enter an Order compelling Petitioner to immediately and fully answer the interrogatories and produce the requested documents; and B. Provide Respondent with such other relief as the Tribunal deems appropriate. BRAUN KE RP.L.C. Dated: September 16, 2025 BiY:: ARA . KEATING (P39223) Attorneys fbr Respondent 4927-6064-4199, v. 1
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EXHIBIT A
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjiohnson(@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PETITIONER PLEASE TAKE NOTICE that the following discovery requests are directed to you under the provisions of the Michigan Tax Tribunal Rules of Practice and Procedure including TTR 239 and TTR 247. You are requested to serve answers to the interrogatories and produce the requested documents within twenty-eight (28) days after service of them upon you, the original answers to be served upon the undersigned. The answers should be signed and sworn to by the person(s) making answer hereto. These discovery requests shall be deemed continuing and supplemental answers shall be
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DEFINITION
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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 SSP Associates Inc, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-002492 Saginaw Township, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING RESPONDENT’S MOTION TO COMPEL On September 16, 2025, Respondent filed a motion requesting that the Tribunal compel Petitioner to respond to its discovery requests, which were served on or about August 11, 2025. Petitioner has not filed a response to the motion. The Tribunal has considered the motion and the case file and finds that Petitioner failed to respond to Respondent’s discovery requests within 28 days of service, as required by TTR 243 and TTR 247. The Michigan Court of Appeals has held that if a party fails to timely respond to discovery requests, its right to object has been waived.1 Unlike other courts, however, the Tribunal’s discovery process is bifurcated into pre-valuation and post-valuation disclosure discovery. Because of this, a carte blanche rule that disallows a party’s right to object to discovery requests does not comport with the Tribunal’s practices, and the parties shall be afforded the right to object to discovery sought at the wrong phase of the discovery process. Petitioner may therefore object to discovery reserved for post-valuation disclosure discovery. All other objections have been waived, however, and Petitioner is required to respond to the requested discovery accordingly. Therefore, IT IS ORDERED that Respondent’s Motion to Compel is GRANTED. IT IS FURTHER ORDERED that Petitioner shall serve its responses to the requested discovery on Respondent within 14 days of the entry of this order. IT IS FURTHER ORDERED that Petitioner’s responses to the interrogatories shall be limited to the first 20 interrogatories. For purposes of this order, each discrete subpart of an interrogatory counts as a separate interrogatory.2 Failure to comply with this order may result in Petitioner being held in default, as 1 See Wallace R Welch v J Walter Thompson USA, Inc, 187 Mich App 49 (1991). 2 See MCR 2.309(A)(2) and TTR 243.
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MTT Docket No. 25-002492 Page 2 of 2 provided by TTR 237.3 Entered: October 16, 2025 By _____________________________ sw 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 3 See also MCL 205.732.
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BRAUN KENDRICK FRANCIS J. KEATING ATTORNEYS AT LAW Attorney TEL: 989.631.1027 FAX: 989.631.9880 EMAIL: frakea@braunkendrick.com September 16, 2025 VIA ELECTRONIC FILING Ms. Samantha M. Welton Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 Re: SSP Associates Inc v Township of Saginaw MTT Docket No.: 25-002492 Dear Ms. Welton: Enclosed please find the following for the above-referenced matter: 1. Respondent’s Motion to Compel Discovery; and 2. Proof of Service. Please file them in your usual manner. The motion fee will be paid at the time of electronic filing. Thank you for your attention to this matter. If you have any questions regarding it, please contact me. Ve S, FRANCIS J. KEATING FIK/1s Enclosures cc: Client (w/encs) Steve Johnson (w/encs) BRAUN KENDRICK FINKBEINER PL.C. MIDLAND SAGINAW 240 W. Main St, Suite 1200, Midland, MI 48640 TEL: 989.631.1027 TEL: 989.498.2100 FAX: 989.631.9880 FAX: 989.799.4666 BRAUNKENDRICK.COM MT. PLEASANT TEL: 989.775.7404 FAX: 989.775.3764 4928-1707-1207, v. 1
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
SSP ASSOCIATES INC,
Petitioner,
MTT Docket No.: 25-002492
v
TOWNSHIP OF SAGINAW,
Respondent.
MICHIGAN TAX APPEAL SERVICES
BRAUN KENDRICK FINKBEINER P.L.C.
By:
Steve Johnson
By:
Francis J. Keating (P39223)
Representative for Petitioner
Attorneys for Respondent
436 N. Center St.
4301 Fashion Square Blvd.
Northville, MI 48167
Saginaw, MI 48603
(248) 392-4342
(989) 498-2100
sjohnson(@mitaxappeal.com
frakea@braunkendrick.com
PROOF OF SERVICE
LEE STADLER, duly sworn, deposes and says that she is a secretary in the employ of
BRAUN KENDRICK FINKBEINER
P.L.C.,
attorneys
for
the Respondent,
Township
of
Saginaw,
and
states
that
on
the
{|eWday
of September,
2025,
she
served
a copy
of
Respondent’s Motion to Compel Discovery by first class mail, by placing same in an envelope
with sufficient postage attached and plainly addressed to:
Steve Johnson, 436 N. Center St.,
Northville, MT 48167.
0 ae
LEE STADLER
4911-9577-5847, v. 1These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S MOTION TO COMPEL DISCOVERY NOW COMES Respondent, Township of Saginaw, by and through its attorneys, Braun Kendrick Finkbeiner P.L.C., and for its Motion to Compel Discovery states the following: 1. On August 11, 2025, Respondent served Respondent’s Interrogatories and Request for Production of Documents to Petitioner, upon Petitioner (“Discovery Request”). A copy of this Discovery Request and Proof of Service is attached hereto and incorporated herein as Exhibit A. 2. Petitioner’s response to said Discovery Request was due on September 8, 2025. 3. Petitioner has not responded formally or informally to Respondent’s August 11, 2025 Discovery Request. 4927-6064-4199, v. 1
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4. More than a week ago, Petitioner’s Representative indicated she was out of the office and will provide the responses when she returned to the office. To date, no responses have been received. 53 Petitioner’s failure to timely assert any objections to said Discovery Request constitutes a complete waiver of any such objections. 6. Petitioner’s Representative has advised Respondent that appraisals are necessary in this case. 1k The information Respondent requested, and asks the Tribunal to compel disclosure of, is relevant and required for Respondent’s preparation for this property tax appeal. WHEREFORE, Respondent requests that this Honorable Tribunal grant it the following relief: A. Enter an Order compelling Petitioner to immediately and fully answer the interrogatories and produce the requested documents; and B. Provide Respondent with such other relief as the Tribunal deems appropriate. BRAUN KE RP.L.C. Dated: September 16, 2025 BiY:: ARA . KEATING (P39223) Attorneys fbr Respondent 4927-6064-4199, v. 1
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EXHIBIT A
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjiohnson(@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO PETITIONER PLEASE TAKE NOTICE that the following discovery requests are directed to you under the provisions of the Michigan Tax Tribunal Rules of Practice and Procedure including TTR 239 and TTR 247. You are requested to serve answers to the interrogatories and produce the requested documents within twenty-eight (28) days after service of them upon you, the original answers to be served upon the undersigned. The answers should be signed and sworn to by the person(s) making answer hereto. These discovery requests shall be deemed continuing and supplemental answers shall be
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DEFINITION
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR SSP Associates Inc , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. 25-002492 Township of Saginaw Respondent(s) PROOF OF SERVICE FOR PROPERTY TAX PETITION *To be filed after the Tribunal issues the Notice of Docket Number* Rebecca Adler states that on August 14, 2025 he/she [Name of person serving/mailing petition] [date of service] served a copy of the Petition relative to the above-captioned matter upon: [Provide name and address of the following entities] 1. Assessor (via certified mail): Treena M. Chick, Assessor, Saginaw Township, Assessing Office, P.O.Box 6400, Saginaw, MI 48608 2. City Clerk or Township Supervisor/Clerk (via certified mail): City Clerk, Saginaw Township, Clerk's Office, 4980 Shattuck Rd, PO Box 6400, Saginaw, MI 48603 3. County Equalization Director (via first class mail or personal service): Equalization Director, Saginaw County, Equalization Department, 111 S. Michigan Avenue, Saginaw, MI 48602 4. County Clerk (via first class mail or personal service): County Clerk, Saginaw County, Clerk's Office, 111 S. Michigan Avenue, Saginaw, MI 48602 5. Secretary of the local school board (via first class mail or personal service): School Board Secretary, Saginaw Township Community School, P.O. Box 6278, Saginaw, Ml 6. State Treasurer (via first class mail): Michigan Department of Treasury, State Treasurer 430 W. Allegan Lansing, MI 48922 /s/ Rebecca Adler Rebecca Adler [Signature of person who is serving/mailing copy] [Print/type name of person serving/mailing copy] 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
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BRAUN KENDRICK FRANCIS J. KEATING ATTORNEYS AT LAW Attorney TEL: 989.631.1027 FAX: 989.631.9880 EMAIL: frakea@braunkendrick.com July 1, 2025 VIA E-MAIL: taxtrib@michigan.gov Ms. Samantha M. Welton Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 Re: SSP Associates Inc v Township of Saginaw MTT Docket No.: 25-002492 Dear Ms. Welton: Enclosed please find the following for the above-referenced matter: 1. Respondent’s Appearance; and 2. Proof of Service. Please file them in your usual manner. Thank you for your attention to this matter. If you have any questions regarding it, please contact me. FIK/Is Enclosures ce: Client (w/encs) Steve Johnson (w/encs) BRAUN KENDRICK FINKBEINER PL.C. MIDLAND 240 W. Main St, Suite 1200, Midland, MI 48640 TEL 989.631.1027 BRAUNKENDRICK. COM ~~ 7#7¢%178%0 Very trul our; FRANCIS J. KEATING SAGINAW TEL: 989.498.2100 FAX: 989.799.4666 MT. PLEASANT TEL: 989.775.7404 FAX: 989.775.3764 4922-9387-5538, v. 1
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com APPEARANCE NOW COMES Braun Kendrick Finkbeiner P.L.C., by Francis J. Keating, and hereby enters its Appearance on behalf of Respondent, Township of Saginaw. BRAUN KENDRICK FINKBEINER P.L.C. Dated: July / 2025 BY: FRANCISJ. WEATING (P39223) Attorney for Respondent 4899-0666-0946, v. 1
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com PROOF OF SERVICE STATE OF MICHIGAN ) )ss COUNTY OF MIDLAND) LEE STADLER, duly sworn, deposes and says that she is a secretary in the employ of BRAUN KENDRICK FINKBEINER P.L.C., attorneys for the Respondent, Township of Saginaw, and states that on the \ day of July, 2025, she served a copy of Respondent’s Appearance by first class mail, by placing same in an envelope with sufficient postage attached and plainly addressed to: Steve Johnson, 436 N. Center St., Northville, MI 48167. Rat. Shed\ LEE STADLER 4922-2453-8194, v. 1
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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 SSP Associates Inc, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002492 Township Of Saginaw, 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 1, 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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poms, STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR SSP Associates Inc , MICHIGAN TAX TRIBUNAL Petitioner(s) \% MTT Docket No. 25-002492 Township of Saginaw Respondent(s) ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 23-12-4-18-4018-000 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) 2. The property identified above is _X real ___ personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? ___ Yes ___ No. (If no, separate Petitions are required for each non- contiguous parcel.) 4. Are all of the parcels of personal property located on a parcel of real property under appeal? ___ Yes _X No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): N/A 6. The property identified above is classified as Commercial 7. If the assessment or assessments at issue were protested, the protest was made to Respondent's March July December Board of Review. 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
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MTT Docket No. 25002492 Page 2 of 4 8. 10. 11. 12. 13. 14. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): N/A If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): N/A The property or properties at issue are located in Saginaw County. The property or properties’ address is: 6200 State St., Saginaw, MI 48603 The assessment or assessments at issue were established by the (applicable local governmental unit): Township of Saginaw Petitioner's legal residence or principal office address is: 1100 S. Washington Ave, Suite 3, Saginaw, MI 48601 This appeal involves issues relating to the (check all that are applicable): X the property or properties’ true cash and taxable values the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition orloss? ___ Yes __ No uniformity of the property or properties’ assessment the property or the properties’ exemption from ad valorem taxation under MCL The tax year(s) at issue are: 2025
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MTT Docket No. 25:002492 Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunals authority over the prior tax year or years (attach additional page if necessary): N/A 16. The values for the property identified above as established by Respondent's Board of Review are: Tax Year True Cash Value Assessed Value Taxable
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MT
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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 SSP Associates Inc, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 24-002208 & 25-002492 Saginaw Township, Presiding Judge Respondent. Jason C. Grinnell ORDER GRANTING PETITIONER’S MOTION TO AMEND ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT DOCKET NUMBER 25-002492 On June 1, 2025, Petitioner filed a motion requesting that the Tribunal permit them to amend the petition filed in this case to include the 2025 tax year. On June 20, 2025, Respondent filed a response to the motion. In the response, Respondent states that valuation disclosures and prehearing statements are scheduled to be exchanged on September 19, 2025, and “Respondent has no discovery for tax year 2025.” Additionally, Respondent requests that the 2025 tax year be severed and assigned a new docket number. The Tribunal has considered the motion, the response, and case file and finds that Petitioner timely filed its Motion to Amend, included the necessary information and filing fee, and otherwise met all requirements, as set forth in MCL 205.737 and MCL 205.735a. Due to the stage in which this case is at, however, and in the interest of judicial efficiency, the 2025 tax year shall be severed from this case and assigned to a new docket number. Therefore, IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. IT IS FURTHER ORDERED that Petitioner’s assessment appeal for the 2025 tax year is SEVERED and ASSIGNED to Docket No. 25-002492. IT IS FURTHER ORDERED that Petitioner shall file a petition pertaining to the 2025 tax year within 21 days of the entry of this order.1 The petition shall note the docket number assigned by the Tribunal for the 2025 tax year and if filed utilizing the Tribunal’s e-filing system, must be filed on the assigned 2025 docket number as a “Severed Petition.”2 1 See TTR 233. 2 Alternatively, the petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition
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MTT Docket No. 24-002208 & 25-002492 Page 2 of 2 IT IS FURTHER ORDERED that the Tribunal shall issue a Notice of Docket after receipt of the petition for the 2025 tax year. Failure to comply with this order may result in dismissal of the appeal for the 2025 tax year.3 Entered: June 24, 2025 By ________________________________ kac/jcr PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933. 3 See TTR 237.
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