Statewide Macomb LLC, Petitioner Vs. Township Of Macomb, Respondent

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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

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

Statewide Macomb LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001815 

 

Macomb Township, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

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%, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001815 

Page 2 of 2 

 

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

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

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

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: October 14, 2025 

am 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

MTT Docket No. 25-001815 

MACOMB TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

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

Property Parcel No: 20-08-36-227-021 

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

Board of Review are: 

2025 True Cash 

Value (TCV) 

2025 AV/SEV 

2025 TV 

$1,224,600 

$612,300 

$612,300 

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

settlement purposes are: 

2025 True Cash 

Value (TCV) 

2025 AV/SEV 

2025 TV 

$1,060,000 

$530,000 

$530,000 

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

or tax years added through motions fo 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}: 

List separately any special terms 

or conditions being proposed by the 

parties that would affect the execution of this Consent Judgment including,

Page 2

MIT Docket No. 25-001815 

Entire Tribunal Consent Judgment 

but not limited to, the joint payment of the refund, the waiver of interest, 

etc.: 

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

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

BIRMINGHAM, MI 48009. 

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

York, Dolan, & Tomlinson, P.C. 

Attorneys for Petitioner, 

Attorneys for Respondent, 

By: pa a 

By: 

7 

A) 

Aaron Fales (P72864) 

Timotty“omiinson 

330 Hamilton Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Township, MI 48036 

248-767-9840 

(586) 263-5050 

Dated: 

10713725 

Dated: 

/0 ~15 “74

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 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

MTT Docket No. 25-001815 

MACOMB TOWNSHIP, 

Respondent. 

/ 

JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

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

Property Parcel No: 20-08-36-227-021 

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

Board of Review are: 

2025 True Cash 

Value (TCV) 

2025 AV/SEV 

2025 TV 

$1,224,600 

$612,300 

$612,300 

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

settlement purposes are: 

2025 True Cash 

Value (TCV) 

2025 AV/SEV 

2025 TV 

$1,060,000 

$530,000 

$530,000 

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

or tax years added through motions fo 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}: 

List separately any special terms 

or conditions being proposed by the 

parties that would affect the execution of this Consent Judgment including,

Page 2

MIT Docket No. 25-001815 

Entire Tribunal Consent Judgment 

but not limited to, the joint payment of the refund, the waiver of interest, 

etc.: 

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

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

BIRMINGHAM, MI 48009. 

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

York, Dolan, & Tomlinson, P.C. 

Attorneys for Petitioner, 

Attorneys for Respondent, 

By: pa a 

By: 

7 

A) 

Aaron Fales (P72864) 

Timotty“omiinson 

330 Hamilton Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Township, MI 48036 

248-767-9840 

(586) 263-5050 

Dated: 

10713725 

Dated: 

/0 ~15 “74

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

V. 

MTT Docket # 25-001815 

TOWNSHIP OF MACOMB, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on August 

| 

2025 he served a copy 

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

Bee 

ee 

Aaron M. Fales

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

MACOMB TWP. 

54111 BROUGHTON ROAD 

MACOMB, MI 48042 

ASSESSOR 

MACOMB TWP, 

54111 BROUGHTON ROAD 

MACOMB, MI 48042 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATIN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

NEW HAVEN COMMUNITY SCHOOLS 

30375 CLARK STREET, P.O. BOX 482000 

NEW HAVEN, Mi 48048-2000 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Statewide Macomb LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-001815 

Township Of Macomb, 

Respondent. 

NOTICE OF DOCKET NUMBER 

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.7354, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case. 

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default. 

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunals rules. 

By: __ Tribunal Clerk 

Entered: July 24, 2025 

PROOF OF SERVICE 

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

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

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

representatives. 

By: Tribunal Clerk 

MICHIGAN TAX TRIBUNAL 

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

- 517-335-9760 

PO BOX 30232, LANSING, MI 48909 

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

Page 4

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

MTT Docket #25- 

001815 

he 

Parcel No. 

20-08-36-227-021 

MACOMB TOWNSHIP, 

Respondent. 

/ 

PETITION 

STATEWIDE MACOMB LLC (“Petitioner”), through 

its attorneys, Law Office 

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

1. 

Petitioner's 

principal 

office 

address 

is 

48991 

Jefferson 

Ave, 

Chesterfield, MI 48047. 

Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 20-08-36-227-021 

("Petitioner's Property”), at 

46705 Erb Dr., Macomb MI. 

2. 

Respondent, Macomb Township 

assesses 

and 

collects 

property 

taxes on Petitioner's Property. 

3: 

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

Property to be $612,300 and assessed Petitioner's Property at $612,300 resulting in 

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

factor.

Page 5

4. 

Petitioner's 

Property 

is 

classified 

as 

commercial 

Real 

Property. 

Petitioner's Property is commercial property. 

Petitioner believes that Petitioner's 

Property was designed to be used for commercial purposes. 

5. 

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

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

6. 

Af this time, Petitioner believes, as 

it relates to taxable value, that 

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

7. 

The 2025 assessment, including state equalized value and taxable 

value, 

imposed 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

(a) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

(b) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

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

under the Michigan Constitution and applicable statutes; 

(c) 

The 

assessment, 

including 

taxable 

value 

and/or 

state 

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

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

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

Page 6

(d) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable 

value, 

and 

the 

mode 

of 

assessment 

adopted 

by 

Respondent, 

discriminate against Petitioner and deny Petitioner 

its constitutional 

rights 

to 

uniformity, equal protection and due process of law. 

WHEREFORE, 

Petitioner requests 

that 

the Tax Tribunal 

enter 

an 

Order 

reducing 

the 

2025 

taxable 

value 

of 

Petitioner's 

Property from 

$612,300 

to

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 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

VS. 

Petitioner, 

MTT Docket No. 25-001815 

MACOMB TOWNSHIP, 

Respondent. 

AARON M. FALES (P72864) 

TIMOTHY D. TOMLINSON (P48519) 

LAW OFFICE OF AARON M. FALES P.C. 

YORK, DOLAN & TOMLINSON, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Twp., MI 48036 

(248) 767-9840 

(586) 263-5050 

afaleslaw@gmail.com 

ttomlinson@yorkdolanlaw.com 

RESPONDENT'S ANSWER TO PETITION 

(Entire Tribunal, 2024 Tax Year) 

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

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

L 

Respondent neither admits nor denies paragraph 1 being without sufficient 

information to form a reasonable belief thereto. 

Respondent admits paragraph 2. 

Respondent admits paragraph 3. 

Respondent admits paragraph 4. 

Respondent denies paragraph 5 because it is untrue, leaving Petitioner to its 

proofs. 

Respondent denies paragraph 6 because it is untrue, leaving Petitioner to its 

proofs.

Page 2

7. 

Respondent denies paragraph 7 because it is untrue, leaving Petitioner to its 

proofs. 

(@ 

Respondent denies paragraph (a) because it is untrue, leaving Petitioner to 

its proofs. 

(b) 

Respondent denies paragraph (b) because it is untrue, leaving Petitioner to 

its proofs. 

(©) 

Respondent denies paragraph (c) because it is untrue, leaving Petitioner to 

its proofs. 

(d) 

Respondent denies paragraph (d) because it is untrue, leaving Petitioner to 

its proofs. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss 

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

wrongfully incurred in having to defend this matter. 

Respectfully submitted, 

YORK, DOLAN & TOMLINSON, P.C. 

TIMOTHY D. TOMLINSON (P48519) 

Attorneys for Respondent 

22600 Hall Road, Ste. 205 

Clinton Twp., MI 48036 

(586) 263-5050 

ttomlinson@yorkdolanlaw.com 

Dated: July 29, 2025 

CERTIFICATE OF SERVICE 

The undersigned certifies that the foregoing instrument was 

served upen all parties 

to ths abovs caussto each of the attornoys 

of record herein at 

theif 

reypecive 

addresses disclosed cn 

tis 

pleadings on 

uly 

¢ 

Az) 

20 

By: = Overnight 

i Pk 

X( E maited 

c 

[Zi E fled 

Sica

Page 3

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

Vs. 

MTT Docket No. 25-001815 

MACOMB TOWNSHIP, 

Respondent. 

AARON M. FALES (P72864) 

TIMOTHY D. TOMLINSON (P48519) 

LAW OFFICE OF AARON M. FALES P.C. 

YORK, DOLAN & TOMLINSON, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Ste. 350 

22600 Hall Road, Ste. 205 

Birmingham, MI 48009 

Clinton Twp., MI 48036 

(248) 767-9840 

(586) 263-5050 

afaleslaw@gmail.com 

ttomlinson@yorkdolanlaw.com 

RESPONDENT'S AFFIRMATIVE DEFENSES 

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

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

L. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

the Respondent. 

3. 

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

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

properties in the Respondent’s taxing unit for the year in question.

Page 4

10. 

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

value, assessed value and taxable value of its property. 

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

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

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

the property’s taxable value is improper. 

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

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

others to arrive at the respective equalized assessments. 

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

preference by application of a method of assessment different from that employed 

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

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

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

cause of action. 

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

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

otherwise equitable tax burden. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in accordance with statutory and constitutional 

requirements.

Page 5

11. 

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

Affirmative Defenses that discovery reveals. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss 

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

wrongfully incurred in having to defend this matter. 

Respectfully submitted, 

YORK, DOL: 

TOMLINSON, P.C. 

TIMOTHY D. TOMLINSON (P48519) 

Attorneys for Respondent 

+ 22600 Hall Rd., Ste. 205 

Clinton Township, MI 48036 

(586) 263-5050 

ttomlinson@yorkdolanlaw.com 

Dated: July 29, 2025 

CERTIFICATE OF SERVICE 

The undersigned certifies that the foregoing instrument was 

served upon all partie 

0 above cause to each of the attorneys 

rd herein 

a 

i 

disclosed 25 

rs

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001815

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Macomb (MACOMB)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Timothy

M.I.

D

Last Name

Tomlinson

Firm Name (if any)

York, Dolan & Tomlinson, P.C.

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

22600 Hall Rd

Ste 205

City or Town

Clinton Twp

State

Michigan

ZIP Code

48036

Telephone Number

586-263-5050

Fax Number

586-263-4763

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

ttomlinson@yorkdolanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Timothy D. Tomlinson

/s/

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 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

vs. 

MACOMB TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 20-08-36-227-021 

 

PETITION 

 

 

STATEWIDE MACOMB LLC (“Petitioner”), through its attorneys, Law Office 

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

 

1. 

Petitioner's principal office address is 48991 Jefferson Ave, 

Chesterfield, MI 48047. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 20-08-36-227-021 ("Petitioner's Property"), at 

46705 Erb Dr., Macomb MI. 

 

2. 

Respondent, Macomb Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

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

Property to be $612,300 and assessed Petitioner's Property at $612,300 resulting in 

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

factor.

Page 2

4. 

Petitioner's Property is classified as commercial Real Property. 

Petitioner's Property is commercial property. Petitioner believes that Petitioner's 

Property was designed to be used for commercial purposes. 

 

5. 

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

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

 

6. 

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

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

 

7. 

The 2025 assessment, including state equalized value and taxable 

value, imposed on Petitioner's Property, and the taxes to be levied and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

 

 

(a) 

The assessment, including state equalized value and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or 

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

under the Michigan Constitution and applicable statutes; 

 

 

(c) 

The assessment, including taxable value and/or state 

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

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

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

Page 3

(d) 

The assessment, including state equalized value and/or 

taxable value, and the mode of assessment adopted by Respondent, 

discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection and due process of law. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2025 taxable value of Petitioner's Property from $612,300 to 

$300,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $612,300 to $300,000 and requiring Respondent to pay 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 28, 2025 

Respectfully submitted, 

 

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

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Statewide Macomb LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001815

Township Of Macomb, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: July 24, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

STATEWIDE MACOMB LLC, 

Petitioner, 

vs. 

MACOMB TOWNSHIP, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 20-08-36-227-021 

 

PETITION 

 

 

STATEWIDE MACOMB LLC (“Petitioner”), through its attorneys, Law Office 

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

 

1. 

Petitioner's principal office address is 48991 Jefferson Ave, 

Chesterfield, MI 48047. Petitioner is a party in interest with respect to property 

taxes on real property tax parcel no. 20-08-36-227-021 ("Petitioner's Property"), at 

46705 Erb Dr., Macomb MI. 

 

2. 

Respondent, Macomb Township assesses and collects property 

taxes on Petitioner's Property. 

 

3. 

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

Property to be $612,300 and assessed Petitioner's Property at $612,300 resulting in 

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

factor.

Page 2

4. 

Petitioner's Property is classified as commercial Real Property. 

Petitioner's Property is commercial property. Petitioner believes that Petitioner's 

Property was designed to be used for commercial purposes. 

 

5. 

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

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

 

6. 

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

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

 

7. 

The 2025 assessment, including state equalized value and taxable 

value, imposed on Petitioner's Property, and the taxes to be levied and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

 

 

(a) 

The assessment, including state equalized value and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or 

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

under the Michigan Constitution and applicable statutes; 

 

 

(c) 

The assessment, including taxable value and/or state 

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

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

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

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(d) 

The assessment, including state equalized value and/or 

taxable value, and the mode of assessment adopted by Respondent, 

discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection and due process of law. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order 

reducing the 2025 taxable value of Petitioner's Property from $612,300 to 

$300,000, and reducing the 2025 assessed and state equalized values of 

Petitioner's Property from $612,300 to $300,000 and requiring Respondent to pay 

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

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 28, 2025 

Respectfully submitted, 

 

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

Attorney for Petitioner 

 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste. 350 

 Birmingham, MI 48009 

 (248) 767-9840

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Statewide Macomb LLC

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

48991 Jefferson Ave.

City or Town

Chesterfield

State

Michigan

ZIP Code

48047

Telephone Number

2487679840

Fax Number

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

afaleslaw@gmail.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Aaron

M.I.

M

Last Name

Fales

Firm Name (if any)

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

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

330 Hamilton Row, Ste. 350

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-767-9840

Fax Number

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

afaleslaw@gmail.com

Section 5: Issue

Please designate one: 

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

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

Michigan

Taxing Authority (City or Township)

Township Of Macomb (MACOMB)

County

Macomb

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

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STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

20-08-36-227-021

Classification of Property: Real 

Commercial

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

612300

Current Taxable Value as established by the Board of Review:

612300

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

600000

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

300000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

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

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

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

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STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

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

Fee Information

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

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

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Aaron Fales

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