Tjs Flint, LLC, Petitioner Vs. Township Of Flint, 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

TJS Flint, LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002166

Township of Flint,

Respondent.

ORDER OF DISMISSAL

The Tribunal has considered the file in this 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

Page 2

MTT Docket No. 25-002166

Page 2 of 2

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: /s/ Patricia L. Halm

Entered: August 24, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

TJS Flint, LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002166

Township of Flint,

Respondent.

ORDER OF DISMISSAL

The Tribunal has considered the file in this 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

Page 4

MTT

Page 5

ST

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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 

 

_____________________________, 

 

 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

RESPONSE TO MOTION TO WITHDRAW APPEAL 

 

1. Petitioner filed a Motion to Withdraw Appeal on __________________________. 

 

2. Choose one: 

 Respondent concurs with the withdrawal of the appeal. 

 

 Respondent objects to the withdrawal of the appeal. 

 

3. If you checked the box that you object to the withdrawal, explain here: 

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________ 

 

 

 

 

 

 

 

 

_________________________________________ 

Party/Representative (sign here) 

 

_________________________________________ 

[Print/type name of person signing] 

 

I certify that on this date I served a copy of this request on the opposing party or their 

representative. 

 

 

___________________________ 

________________________________ 

 

Date 

 

 

 

 

Signature 

TJS Flint , LLC 

25-002166

Township of Flint 

08/17/2026



 /s/ Paula Dotson

Paula Dotson 

08/17/2026

/s/ Paula Dotson

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

MICHIGAN TAX TRIBUNAL

Docket Number: 25-002166

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Respondent

Files

Document Type: Response to Motion

Attachment File Name: Response-to-Motion-to-Withdraw-Appeal-Form-fillable 25-002166 TJS 

Flint

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

TJS Flint, LLC,

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 25-002166

Township of Flint,

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: August 17, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

TJS Flint, LLC,

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 25-002166

Township of Flint,

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.2

By: Tribunal Clerk

Entered: August 17, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

2 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.

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 

TJS Flint LLC, 

Petitioner, 

v 

Flint Township, 

Respondent.

MTT Docket No. 25-002166 

Stewart Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7420 

slmandell@honigman.com

Paula Dotson 

Township Assessor 

Flint Township 

Representative for Respondent 

1490 S. Dye Road 

Flint, MI 48532 

(810) 600-3227 

assessingdept@flinttownship.org

Motion to Withdraw Petition 

For this Motion, Petitioner states: 

Petitioner desires to withdraw its Petition and files this Motion pursuant to Tax Tribunal 

Rule 231, R 792.10231 and MCL 205.732(c). Respondent’s representative has confirmed that 

Respondent concurs with the Tribunal dismissing this case as requested herein. 

WHEREFORE, Petitioner requests that the Tribunal enter an Order allowing the Petition 

to be withdrawn, or dismissing this case, with each party bearing its own costs.

Page 2

2 

76675480.1 

 

Respectfully submitted, 

HONIGMAN LLP, 

Attorneys for Petitioner 

By:/s/ Stewart Mandell 

Stewart Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

Dated: August 14, 2026 

slmandell@honigman.com

Page 3

3 

76675480.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint LLC, 

Petitioner, 

v 

Flint Township, 

Respondent.

MTT Docket No. 25-002166 

Stewart Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7420 

slmandell@honigman.com

Paula Dotson 

Township Assessor 

Flint Township 

Representative for Respondent 

1490 S. Dye Road 

Flint, MI 48532 

(810) 600-3227 

assessingdept@flinttownship.org

Proof of Service 

Lisa Joseph states that on August 14, 2026 she served a copy of Petitioner’s Motion to 

Withdraw upon Respondent’s Representative via electronic mail as shown below: 

Paula Dotson 

Township Assessor 

Flint Township 

Representatives for Respondent 

assessingdept@flinttownship.org

____/s/ Lisa Joseph__________________________ 

Dated: August 14, 2026 

 Lisa Joseph

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 25-002166

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Motion to Withdraw - TJS Flint (25-002166)

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

NOTICE OF JANUARY 4 - 15, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

TJS Flint, LLC,

Petitioner,

v

 

 

Township of Flint,

Respondent.

 MTT Docket No. 25-002166

Please be advised that 25-002166 has been placed on a two-week Prehearing General 

Call commencing January 04, 2027. Unless ordered otherwise, parties will be notified 

at least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

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. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, 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. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 25-002166

Page 2 of 3

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 September 8, 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.

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

Statements by September 8, 2026. Witnesses, with the exception of rebuttal 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. See TTR 237. 

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

September 8, 2026, which means all discovery has been requested, all Motions to 

Compel have been filed, 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 

January 4, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure”

Page 3

MTT

Page 4

STA

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Page 1

RECEIVED 

, 

JUL 09 2025 

MIC 

SUPERVISOR 

Rost IGAN TAX TRIBUNAL 

KARYN MILLER 

BARB VERT 

CLERK 

1490 S. Dye Road 

) PEAR DALL. 

MANYA TRIPLETT 

Flint, Michigan 48532 

CAR 

- 

TREASURER 

TOM KLEE 

LISA R. ANDERSON 

DEBBE CAMPBELL 

July 2,2025 

Office of the Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

MTT Docket No.: 25-002166 

TIS Flint LLC v Township of Flint 

Parcels: 07-27-100-025 

Dear Honorable Michigan Tax Tribunal: 

Enclosed for filing, please find Respondent’s Reply to Petitioner’s Petition (in the Entire 

Tribunal) and Respondent’s Proof of Service. 

Re 

ctfully submitted, 

ada 

JOD red — 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint LLC 

MTT Docket No.: 25-002166 

Petitioner 

Parcel 

07-27-100-025 

AY 

Flint Township, Genesee County 

Respondent 

Honigman LLP 

Paula Dotson 

Stewart L. Mandell 

Deputy Assessor, Charter Township of Flint 

39400 Woodward Avenue, Suite 101 

1490 S. Dye Road 

Bloomfield Hills, MI 48304-5151 

Flint, MI 48532 

313.465.7420 

810.600.3227 

RESPONDENT’S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2025 

ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) 

Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy 

Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 

I. 

Respondent acknowledges 

that 

parcel 

07-27-100-025 

identified 

in paragraph 

1 

of 

Petitioner’s Petition will be the subject of Petitioner’s appeal 

as to the remainder of the 

statements, Respondent neither admits nor denies for the reason Respondent is without 

sufficient knowledge to form a belief as to the truth and leaves Petitioner to meeting its 

required burden of proof. 

2. 

Respondent admits the statements set forth in paragraph 2 of Petitioner’s Petition. 

3. 

Respondent admits the statements set forth in paragraph 3 of Petitioners Petition. 

4. 

Respondent admits the subject property is classified as commercial real; as to the remainder 

of the statements, Respondent neither admits nor denies for the reason Respondent 

is 

without sufficient knowledge to form a belief as to the truth and leaves Petitioner to

Page 3

MTT Docket 25-002166 

7 

Respondent admits the statements and or allegations set forth in paragraph 7 of Petitioner’s 

Petition. 

8. 

Respondent denies the statements and or allegations set forth in paragraph 8 of Petitioner’s 

Petition because they are untrue. 

Respondent leaves Petitioner to meeting its required 

burden of proof. 

WHEREFORE, Respondent, Charter Township of Flint, denies that Petitioner is entitled to the 

relief it seeks and respectfully requests that the Respondent’s assessed value and taxable value of 

the subject property be affirmed and that the Honorable Tribunal dismiss the Petition with 

prejudice. 

Respondent’s Response submitted on this date, 

July 2, 2025, by: 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint LLC 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

MTT DOCKET NO.: 25-002166 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

GENESEE COUNTY) 

THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on 

July 2, 2025, she caused to be served upon: 

Honigman LLP 

Michigan Tax Tribunal 

Stewart L. Mandell 

PO Box 30232 

39400 Woodward Avenue, Suite 101 

Lansing, Michigan 48909 

Bloomfield Hills, MI 48304-5151 

by enclosing the same in an envelope, plainly addressed to said party at the above address, with 

lawful United States first class postage affixed thereon and by placing same in the United States 

mail. 

py 2 

’ 

: 

July 2, 2025 

Date 

Paula Dotson 

Deputy Assessor

Page 5

=, CHARTER TOWNSE 

1490S. Dye R 

_ Flint, Michigan 

CERTIFIED MAIL" J 

Ti 

: 2009 

6 R

g589 

0710 

5270 

L5kk 7304 

83 

E WANN .6

Snir 

Office of the Chief Clerk, 

Michigan Tax Tribunal 

®.0. Box 30232 

Lansing, MI 48909 

AEEOE—T TREES 

ET rT 

A SL 

Rr Le 

FL FL PELL 

LE 

FU LEE 

PT

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 So 

JUN 062025 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint, LLC, 

Petitioner, 

MTT Docket No. A 570 oO P= lp Z 

Ye 

Parcel No. 07-27-100-025 

Flint Twp., 

Respondent, 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Proof of Service 

Lisa Joseph states that on 

( A [3 

( 2-S” 

|, she did serve a copy of Petitioner's Petition, 

with docket number, upon the parties named on the attached list. 

Dated: 

Gf 3 

/ >5 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

FLINT TWP. 

1490 S. DYE RD. 

FLINT, MI 48532 

ASSESSOR 

FLINT TWP. 

1490 S. DYE RD. 

FLINT, MI 48532 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

GENESEE COUNTY 

900 S. SAGINAW STREET 

FLINT, MI 48502-1514 

DIRECTOR OF EQUALIZATION 

GENESEE COUNTY 

900 S. SAGINAW STREET 

FLINT, MI 48502-1514 

SECRETARY OF SCHOOL BOARD 

SWARTZ CREEK COMMUNITY SCHOOLS 

8354 CAPPY LANE 

SWARTZ CREEK, MI 48473-1299 

STATE TREASURER 

MICHIGAN DEPARTMENT OF 

TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0117

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

25-0029 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint, LLC, 

Petitioner, 

v. 

Flint Twp., 

Respondent, 

MTT Docket No. ________ 

Parcel No. 07-27-100-025 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Petition 

TJS Flint, LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 111 W. Washington Street, Suite 1300, 

Chicago, IL 60602. Petitioner is a party in interest with respect to property taxes on tax parcel 

number 07-27-100-025 ("Petitioner's Property"), with an address of 3603 Miller Road, Flint Twp., 

located in Genesee County, Michigan. 

2.

Respondent, Flint Twp., assesses and collects property taxes on Petitioner's 

Property. 

3.

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

$2,062,000 and assessed Petitioner's Property at $2,087,300, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor.

Page 2

2 

60731676.1 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5.

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

value, and (d) due process, equal protection, and 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.

No board of review protest was required for Petitioner’s Property. 

8.

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 

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, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and 

(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.

Page 3

3 

60731676.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $2,062,000 to $1,300,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $2,087,300 to $1,300,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: June 2, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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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

TJS Flint, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002166

Township of Flint, 

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: August 14, 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

25-0029 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint, LLC, 

Petitioner, 

v. 

Flint Twp., 

Respondent, 

MTT Docket No. ________ 

Parcel No. 07-27-100-025 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Petition 

TJS Flint, LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 111 W. Washington Street, Suite 1300, 

Chicago, IL 60602. Petitioner is a party in interest with respect to property taxes on tax parcel 

number 07-27-100-025 ("Petitioner's Property"), with an address of 3603 Miller Road, Flint Twp., 

located in Genesee County, Michigan. 

2.

Respondent, Flint Twp., assesses and collects property taxes on Petitioner's 

Property. 

3.

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

$2,062,000 and assessed Petitioner's Property at $2,087,300, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor.

Page 2

2 

60731676.1 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5.

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

value, and (d) due process, equal protection, and 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.

No board of review protest was required for Petitioner’s Property. 

8.

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 

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, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and 

(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.

Page 3

3 

60731676.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $2,062,000 to $1,300,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $2,087,300 to $1,300,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: June 2, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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 - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

TJS Flint, LLC

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

111 W. Washington

City or Town

Chicago

State

Illinois

ZIP Code

60602

Telephone Number

2485668300

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

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

slmandell@honigman.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 Flint (GENESEE)

County

Genesee

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

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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

07-27-100-025

Classification of Property: Real 

Commercial

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

2087300

Current Taxable Value as established by the Board of Review:

2062000

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

2600000

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

1300000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

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

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

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

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

Fee Information

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

State 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/ Stewart L. Mandell

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