Toni Zhang, Petitioner V City Of Ann Arbor, 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 

Toni Zhang, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 25-002569 

 

City Of Ann Arbor, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner’s appeal. Petitioner, appealing the true cash and taxable values for Parcel 

No. 09-09-15-104-105 for the 2024 and 2025 tax years, was held in default on August 

12, 2025, for failing to file a copy of the notice giving rise to the appeal, i.e. Board of 

Review (BOR) results. On August 19, 2025, Petitioner filed a response, however their 

attempt to cure was incomplete because Petitioner filed a copy of the 2024 BOR results 

but failed to include a copy of the 2025 BOR results. 

 

On August 29, 2025, Respondent filed an answer stating Petitioner failed to protest the 

disputed assessment for the subject property at the 2025 March BOR. 

 

Thus, the Tribunal finds it has no authority over the 2024 assessment. In accordance 

with MCL 205.735a(6), “[t]he jurisdiction of the tribunal in an assessment dispute as. . . 

residential property. . . is invoked by a party in interest, as petitioner, filing a written 

petition on or before July 31 of the tax year involved.” Here, Petitioner is appealing 

assessments for the 2024 and 2025 tax years, and the Tribunal has no authority over 

the 2024 assessment as the petition was not filed until June 30, 2025. 

 

Moreover, Petitioner failed to protest the disputed assessments to the 2025 March 

BOR. As specified in Sixarp LLC v Byron Twp,1 “[b]ecause Praxis failed to file a timely 

protest before the Board as required by MCL 205.735a(3), the MTT did not have 

jurisdiction to hear Praxis's claim.” Further, “[t]he MTT correctly explained that ‘because 

the Tribunal has no equitable power to waive or otherwise disregard a statutory 

requirement or filing deadline, it has no authority to grant Praxis's exemption request.’”2 

Additionally, the Tribunal has no authority under MCL 211.53a because the facts 

alleged do not establish that the assessments were the result of a clerical error (i.e., “an 

error of a transpositional, typographical, or mathematical nature”) or a mutual mistake of 

fact (i.e., “an erroneous belief, which is shared and relied on by both parties”). And 

though MCL 211.53b provides July and December boards of review with the authority to 

correct qualified errors, Petitioner did not appear before Respondent’s July or 

 

1 Sixarp LLC v Byron Twp___Mich___;___NW3d___(2025). 

2 Id.

Page 2

MTT Docket No. 25-002569 

Page 2 of 3 

 

December BOR or appeal an action taken by any such board. As such, and inasmuch 

as the Tribunal has no equitable power to waive or otherwise disregard a statutory 

requirement or filing deadline, it has no authority to grant Petitioner the relief 

requested.3 

 

Therefore, 

 

IT IS ORDERED that the case is DISMISSED. 

 

This order resolves all pending claims in this matter and closes this 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 

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. 

 

 

 

Entered: September 9, 2025 

 

 

By _____________________________ 

kac/jcr 

 

 

 

3 The Tribunal’s powers are limited to those authorized by statute and do not include powers of equity. 

See Federal-Mogul Corp v Dep’t of Treasury, 161 Mich App 346 (1987), Elec Data Sys Corp v Flint Twp, 

253 Mich App 538 (2002), and VanderWerp v Plainfield Twp, 278 Mich App 624 (2008).

Page 3

MTT Docket No. 25-002569 

Page 3 of 3 

 

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

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

Toni Zhang,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-002569

City Of Ann Arbor,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this 

case through an informal settlement conference. An informal settlement conference 

is a meeting between the parties and/or their representatives to discuss the issues in a 

case in an effort to settle the case. This process may be an alternative to a hearing with 

a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

NOTE: The parties may not request an informal settlement conference to discuss an 

appeal of a principal residence exemption that was denied by either the Michigan 

Department of Treasury or a County. Also, state taxes levied by the Michigan 

Department of Treasury, such as income taxes, are not subject to the informal 

settlement conference process.

Page 2

MTT Docket No. 25-002569

Page 2 of 6

MEDIATION: Parties have the option of handling this case through mediation. 

Mediation is a voluntary process where a mediator facilitates communication between 

the parties, assists in identifying issues, and helps explore solutions to promote a 

mutually acceptable settlement. This process may be an alternative to a hearing with a 

judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

If you have any questions, please contact the Tribunal by phone at (517) 335-9760 or 

email taxtrib@michigan.gov.

By: Tribunal Clerk

Entered: August 29, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Toni Zhang,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-002569

City Of Ann Arbor,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this 

case through an informal settlement conference. An informal settlement conference 

is a meeting between the parties and/or their representatives to discuss the issues in a 

case in an effort to settle the case. This process may be an alternative to a hearing with 

a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

NOTE: The parties may not request an informal settlement conference to discuss an 

appeal of a principal residence exemption that was

Page 4

M

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

PROPERTY TAX APPEAL ANSWER FORM

VALUATION / EXEMPTION / CLASSIFICATION APPEAL

MOAHR DOCKET NO. 25-002569

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government City Of Ann Arbor (WASHTENAW)

First Name

M.I.

Last Name/Company Name/Unit of Government

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

E-mail Address

Section 2: Respondent’s Attorney/Authorized Representative’s Contact Information

First Name

Jerry

M.I.

Last Name

Markey

Firm Name (if any)

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

301 E Huron Street

PO Box 8647

City or Town

Ann Arbor

State

Michigan

ZIP Code

48107

Telephone Number

734-794-6530

Fax Number

E-mail Address

assessor@a2gov.org

Section 3: Subject Property Information

Does the subject property have a Principal Residence Exemption of 50% or more? 

No

Are the parcels listed by Petitioner contiguous or adjoining? If not, list which parcels adjoin one another.

N/A 

Section 4: Explain Your Answer to this Appeal

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review 

Decision, Notice of Uncapping, or Assessment Change Notice) with this Small Claims Answer, if applicable. If you do not submit this 

document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

PETITIONER FAILED TO PROTEST THE DISPUTED ASSESSMENT FOR THE SUBJECT PROPERTY INCLUDED IN ITS PETITION TO THE 2025 

MARCH BOARD OF REVIEW, WHICH IS A STATUTORY PREREQUISITE TO INVOKING THE TRIBUNAL’S JURISDICTION. IN ACCORDANCE 

WITH MCL 205.735A(3), FOR AN ASSESSMENT DISPUTE AS TO THE VALUATION OF PROPERTY, THE ASSESSMENT MUST BE PROTESTED 

BEFORE THE BOARD OF REVIEW BEFORE THE TRIBUNAL ACQUIRES JURISDICTION OF THE DISPUTE. THEREFORE, RESPONDENT 

CONTENDS THE MICHIGAN TAX TRIBUNAL LACKS JURISDICTION OVER THE ASSESSMENT DISPUTE FOR THE 2025 YEAR. 

THE PETITIONER DID NOT MEET THE STATUTORY JULY 31, 2024 DEADLINE TO APPEAL THE 2024 MARCH BOARD OF REVIEW DECISION.

AT THIS TIME, RESPONDENT CONTENDS THE 2024 AND 2025 ASSESSED AND TAXABLE VALUES ARE CORRECT.

ADDITIONALLY, THERE IS NO PRE IN PLACE ON THIS PARCEL AS THE PETITIONER STATES ON THEIR PETITION.

Section 5: Jurisdictional Issues

IF PETITIONER IS APPEALING THE TRUE CASH AND/OR TAXABLE VALUES

Did Petitioner protest the assessment at a Board of Review (BOR)? No

If yes, check which BOR Petitioner attended: 

If no, was the Notice of Assessment properly sent to Petitioner prior to the March BOR? *Submit a copy of the Notice of Assessment with the Answer.

If the July or December BOR revised the assessment(s) at issue, did it have authority? 

If yes, cite the Board’s authority.

Was the assessment(s) at issue established as the result of a clerical error or mutual mistake of fact? No

If yes, explain.

Is Petitioner appealing from a State Tax Commission Order? 

If so, what is the issue date?

N/A

IF PETITIONER IS APPEALING THE UNCAPPING OF TAXABLE VALUE

When was the Notice of Uncapping, if applicable, issued?

N/A

Under what statutory section was the Taxable Value uncapped?

N/A

N/A

IF PETITIONER IS APPEALING THE DENIAL OF A POVERTY EXEMPTION

Did Petitioner request a Poverty Exemption at a BOR? No

If Yes, check which BOR Petitioner attended:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

List the date the BOR denied Petitioner’s Poverty Exemption:

N/A

IF PETITIONER IS APPEALING THE DENIAL OF AN EXEMPTION 

OTHER THAN POVERTY, PRINCIPAL RESIDENCE, OR QUALIFIED AGRICULTURAL EXEMPTIONS

Did Petitioner request the exemption at the BOR? 

No

If Yes, check which BOR Petitioner attended:

Tax Year(s) denied:

N/A

List the date the exemption was denied:

N/A

What statutory section did Petitioner request the subject property be exempt?

N/A

IF PETITIONER IS APPEALING THE CLASSIFICATION OF PROPERTY

What do you believe the classification should be: 

Section 6: Valuation Information *Use the multiple parcel form for additional, contiguous parcels.

Parcel Identification Number:

09-09-15-104-105

Classification of Property:

Real 

Residential

Current Assessed Value (also known as State Equalized Value) as established by the BOR:

288,900

Current Taxable Value as established by the BOR:

288,900

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

$577,800

Multiply the True Cash Value by. 5 and enter here. This is your contention of Assessed Value.

288,900

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

288,900

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

Respondent or Attorney/Authorized Representative’s Signature: 

/s/ Jerry Markey

Page 4

CITY OF ANN ARBOR, MICHIGAN 

 301 E. Huron Street, P.O. Box 8647, Ann Arbor, Michigan 48107-8647 

 Phone (734) 794-6530 Fax (734) 997-1437 

 ASSESSOR www.assessor@a2gov.org 

 

 

 

 

 

 

 

 

 

 

 

 

August 27, 2025 

 

Samantha M. Welton, Chief Clerk 

Michigan Tax Tribunal 

611 W. Ottawa, 4th Floor 

P.O. Box 30232 

Lansing, Michigan 48909 

 

 

RE: 

Toni Zhang v City of Ann Arbor - Docket No. 25-002569 

 

Parcel No. 09-09-15-104-105 

 

To Whom it May Concern: 

 

Petitioner for the above-referenced docket failed to protest the disputed assessment for the 

subject property included in its petition to the 2025 March Board of Review, which is a statutory 

prerequisite to invoking the Tribunal’s jurisdiction. In accordance with MCL 205.735a(3), for an 

assessment dispute as to the valuation of property, the assessment must be protested before the 

board of review before the tribunal acquires jurisdiction of the dispute. The Tribunal has no 

equitable power to waive or otherwise disregard a statutory

Page 5

S

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Page 1

http://www.michigan.gov/taxtrib/0,4677,7-187-38254---,00.html

08/08/2025 02:42 PM

BOARD OF REVIEW DECISION

ANN ARBOR, MI 48107

PO BOX 8647

ASSESSOR'S OFFICE

CITY OF ANN ARBOR

“Effective March 1, 2013, the Tribunal is no longer able to accept Small Claims letter appeals. Rather, you are required to file a petition to

initiate a new Small Claims appeal. Petition forms are available on this website.”

Please feel free to contact the assessor at the address listed above or call if you have any questions.

PRINCIPAL RESIDENCE EXEMPTION/QUALIFIED AG 

2024

0.0000

2024

292,600

"BOARD OF REVIEW" TAXABLE VALUE 

292,600

2024 ORIGINAL TAXABLE VALUE 

(If the above amounts are the same, no revisions have occured)

"BOARD OF REVIEW" ASSESSED VALUE 

2024

292,600

292,600

2024 ORIGINAL ASSESSED VALUE

ASSESSMENT DETERMINED ACCURATE

Board of Review Comments:

They have made the following determination based on the information you supplied.

09-09-15-104-105

The Board has completed their review of parcel number

Thank you for attending this years March Board of Review. The Board has reviewed the information you supplied and the data necessary

to compute your assessment and taxable value.

401 (RESIDENTIAL-IMPROVED)

THIS PROPERTY IS CLASSIFIED AS

ANN ARBOR MI 48105

2898 RAYFIELD AVE

ZHANG TONGXIAO

UNIT 346 NORTH OAKS CONDOMINIUMS Split/Combined on

02/27/2017 from 09-09-15-103-014;

2898 RAYFIELD AVE

09-09-15-104-105

PROPERTY IDENTIFICATION: (Parcel Code required. Property address

and legal description optional.):

NAME AND ADDRESS OF OWNER OR PERSON NAMED ON ASSESSMENT ROLL:

FROM

2024

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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

Toni Zhang,

Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

v

 

MTT Docket No. 25-002569

City Of Ann Arbor,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of 

action taken by Board of Review, uncapping notice, PRE denial notice, final assessment 

notice, etc.), as required by TTR 279. As such, Petitioner must submit the notice within 

14 days of the entry of this order. 

Therefore,

IT IS ORDERED that Petitioner is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: August 12, 2025

Patricia L. Halm, Tribunal Chair

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

i “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received.

Page 2

MTT Docket No. 25-002569

Page 2 of 4

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

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

Toni Zhang,

Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

v

 

MTT Docket No. 25-002569

City Of Ann Arbor,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of 

action taken by Board of Review, uncapping notice, PRE denial notice, final assessment 

notice, etc.), as required by TTR 279. As such, Petitioner must submit the notice within 

14 days of the entry of this order. 

Therefore,

IT IS ORDERED that Petitioner is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.ii 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: August 12, 2025

Patricia L. Halm, Tribunal Chair

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

ii “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial

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MTT Docket No. 25-002569

Page 4 of 4

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

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

PROPERTY TAX APPEAL PETITION FORM

VALUATION / EXEMPTION / CLASSIFICATION APPEAL

MOAHR DOCKET NO. 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or Non-Property tax 

disputes.

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review 

Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Section 1: Petitioner’s Contact Information

Filer Type: Individual 

First Name

Toni

M.I.

Last Name/Company Name

Zhang

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

Ann Arbor

3071 N Spurway Dr

City or Town

ANN ARBOR

State

Michigan

ZIP Code

48105

Telephone Number

734-263-5108

Fax Number

E-mail Address

tw_ustc@yahoo.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

Toni

M.I.

Last Name

Zhang

Firm Name (if any)

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

Ann Arbor

City or Town

ANN ARBOR

State

Michigan

ZIP Code

48105

Telephone Number

7342635108

Fax Number

E-mail Address 

tw_ustc@yahoo.com

Section 3: Subject Property Information

How many parcels are you appealing?

1

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.

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

2898 Rayfield Ave

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

ANN ARBOR

Michigan

48105

Taxing Authority (City or Township)

City Of Ann Arbor (WASHTENAW)

County 

Washtenaw

Section 4: Issues Being Appealed (check all that apply)

True Cash and Taxable Value

 

Section 5: Explain the Reason for this Appeal

Dear MI State:

 

I am writing to respectfully request a review of my property tax assessment for the 2024/2025 tax year. I kindly ask that you consider my appeal, as I believe my 

property has been overvalued based on the evidence presented below.

My appeal is supported by the following key factors:

 

1. Market Data: I have identified several comparable properties sold in 2024 within my community, located near my address. These properties are similar to mine in 

size, features, and lot location (facing major roads with traffic). The average sales price of these comparable properties is $556,503.00, as detailed in the attached 

list. Assuming a standard assessment rate of approximately 50% of market value, this suggests my property’s assessed and taxable value should be $278,251.50. 

However, the City has assigned an assessed and taxable value of $288,900, which exceeds the current market evidence.

2. Lot Location: My property’s front door faces a major street, exposing it to significant noise, traffic, and dust. These conditions adversely affect its desirability and 

value compared to similar homes in quieter, less exposed locations within the community.

 

3. Community Reputation: The reputation of the builder and the HOA management company serving our community may also impact property values. I believe 

these entities have not maintained standards that justify the assessed value of my property. Public sentiment reflecting these concerns is widely available on 

platforms such as Reddit.com and Change.org. Additionally, I have enclosed a photograph of my front door’s concrete patio to illustrate the quality issues that 

further support my case.

I respectfully request that you review this information and adjust my property’s taxable valuation to reflect a fair and actual average taxable value: 278,251.50, 

 

Thank you for your time and consideration. I am grateful for your willingness to evaluate my petition despite my inability to attend an in-person appointment. Please 

let me know if you require any additional documentation to support my appeal.

 

Sincerely,

Toni Tongxiao Zhang

Section 6: Jurisdictional Issues

Year(s) you are appealing:

 2024 and 2025

Did you protest the assessment at a Board of Review (BOR)? Yes

If Yes, check which BOR you attended AND upload the BOR decision: March

If No, check the applicable reason(s):

Did you request a Poverty Exemption at the BOR? 

If Yes, check which BOR considered your application AND upload the BOR decision: 

 March  July  December

If No, explain why:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Valuation Information *Use the multiple parcel form for additional, contiguous parcels.

Parcel Identification Number: 09-09-15-104-105

Classification of Property:

Personal

Residential

Current Assessed Value (also known as State Equalized Value) as established by the BOR:

577800

Current Taxable Value as established by the BOR:

288900

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

556503 

Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

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

278251.50

Section 8: Classification Information *Only the MI Dep’t of Treasury may appeal this issue to the Tribunal*

Parcel Identification Number:

 

Current Classification of Property as established by Board of Review:

What do you believe is the property’s classification?

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

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

Fee Information

Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition?

Yes

Are you appealing ONLY the denial of a Poverty Exemption?

No

If you answered yes to either

Page 4

STA

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

Toni Zhang,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-002569

City Of Ann Arbor,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: August 12, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

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

Toni Zhang,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-002569

City Of Ann Arbor,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: August 12, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

PROPERTY TAX APPEAL PETITION FORM

VALUATION / EXEMPTION / CLASSIFICATION APPEAL

MOAHR DOCKET NO. 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or Non-Property tax 

disputes.

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review 

Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Section 1: Petitioner’s Contact Information

Filer Type: Individual 

First Name

Toni

M.I.

Last Name/Company Name

Zhang

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

Ann Arbor

3071 N Spurway Dr

City or Town

ANN ARBOR

State

Michigan

ZIP Code

48105

Telephone Number

734-263-5108

Fax Number

E-mail Address

tw_ustc@yahoo.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

Toni

M.I.

Last Name

Zhang

Firm Name (if any)

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

Ann Arbor

City or Town

ANN ARBOR

State

Michigan

ZIP Code

48105

Telephone Number

7342635108

Fax Number

E-mail Address 

tw_ustc@yahoo.com

Section 3: Subject Property Information

How many parcels are you appealing?

1

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.

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

2898 Rayfield Ave

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

ANN ARBOR

Michigan

48105

Taxing Authority (City or Township)

City Of Ann Arbor (WASHTENAW)

County 

Washtenaw

Section 4: Issues Being Appealed (check all that apply)

True Cash and Taxable Value

 

Section 5: Explain the Reason for this Appeal

Dear MI State:

 

I am writing to respectfully request a review of my property tax assessment for the 2024/2025 tax year. I kindly ask that you consider my appeal, as I believe my 

property has been overvalued based on the evidence presented below.

My appeal is supported by the following key factors:

 

1. Market Data: I have identified several comparable properties sold in 2024 within my community, located near my address. These properties are similar to mine in 

size, features, and lot location (facing major roads with traffic). The average sales price of these comparable properties is $556,503.00, as detailed in the attached 

list. Assuming a standard assessment rate of approximately 50% of market value, this suggests my property’s assessed and taxable value should be $278,251.50. 

However, the City has assigned an assessed and taxable value of $288,900, which exceeds the current market evidence.

2. Lot Location: My property’s front door faces a major street, exposing it to significant noise, traffic, and dust. These conditions adversely affect its desirability and 

value compared to similar homes in quieter, less exposed locations within the community.

 

3. Community Reputation: The reputation of the builder and the HOA management company serving our community may also impact property values. I believe 

these entities have not maintained standards that justify the assessed value of my property. Public sentiment reflecting these concerns is widely available on 

platforms such as Reddit.com and Change.org. Additionally, I have enclosed a photograph of my front door’s concrete patio to illustrate the quality issues that 

further support my case.

I respectfully request that you review this information and adjust my property’s taxable valuation to reflect a fair and actual average taxable value: 278,251.50, 

 

Thank you for your time and consideration. I am grateful for your willingness to evaluate my petition despite my inability to attend an in-person appointment. Please 

let me know if you require any additional documentation to support my appeal.

 

Sincerely,

Toni Tongxiao Zhang

Section 6: Jurisdictional Issues

Year(s) you are appealing:

 2024 and 2025

Did you protest the assessment at a Board of Review (BOR)? Yes

If Yes, check which BOR you attended AND upload the BOR decision: March

If No, check the applicable reason(s):

Did you request a Poverty Exemption at the BOR? 

If Yes, check which BOR considered your application AND upload the BOR decision: 

 March  July  December

If No, explain why:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Valuation Information *Use the multiple parcel form for additional, contiguous parcels.

Parcel Identification Number: 09-09-15-104-105

Classification of Property:

Personal

Residential

Current Assessed Value (also known as State Equalized Value) as established by the BOR:

577800

Current Taxable Value as established by the BOR:

288900

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

556503 

Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

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

278251.50

Section 8: Classification Information *Only the MI Dep’t of Treasury may appeal this issue to the Tribunal*

Parcel Identification Number:

 

Current Classification of Property as established by Board of Review:

What do you believe is the property’s classification?

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

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

Fee Information

Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition?

Yes

Are you appealing ONLY the denial of a Poverty Exemption?

No

If you answered yes to either

Page 4

STA

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.