Record Finder / 26-001616-TT
Michigan
USA2Go Qck Store / Tim Hortons Petitioner Vs. Township Of Lyon Respondent
- Petitioner
- USA2Go Qck Store / Tim Hortons
- Respondent
- Township Of Lyon
Case overview
- Docket number
- 26-001616-TT
- Status
- Ready Schedule
- CaseType
- ET Property
- Division
- ET
- County
- Oakland
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 5 | Answer was received | RESP | Not recorded | 08/27/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | Not recorded | Not recorded | 08/20/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 08/20/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 08/20/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/27/2026 | $400.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
Answer to Petition - Tim Hortons 26-001616.pdfRead complete document text →
Read document text excerpt
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL USA2GO QCK STORE/TIM HORTONS, Petitioner, MTT Docket No. 26-001616 v. LYON TOWNSHIP, Respondent. COLLIERS INTERNATIONAL Joshua T. Shillair (P72674) Attorney for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 (248) 226-1632 joshua.shillair@colliers.com ROSATI, SCHULTZ, JOPPICH & AMTSBUECHLER, P.C. Jeremy J. Romer (P77287) Gopi P. Pate; (P77727) Attorneys for Respondent 27555 Executive Drive Suite 250 Farmington Hills, MI 48331-3550 (248) 489-4100 jromer@rsjalaw.com gpatel@rsjalaw.com Respondent's Answer to Petition NOW COMES Respondent, TOWNSHIP OF LYON, by and through its Attorneys, ROSATI, SCHULTZ, JOPPICH & AMTSBUECHLER, P.C. and for its Answer to Petitioner's Petition, states as follows: 1. As to the allegations contained in Paragraph 1 of the Petition, Respondent neither admits nor denies the same for the reason Respondent is without sufficient knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proof. 2. As to the allegations contained in Paragraph 2 of the Petition, Respondent admits the same.
Page 2
2 3. As to the allegations contained in Paragraph 3 of the Petition, Respondent admits the same. 4. As to the allegations contained in Paragraph 4 of the Petition, Respondent admits that the property is classified as alleged; as to the remainder of the allegations, Respondent neither admits nor denies the same for the reason Respondent is without sufficient knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proofs. 5. As to the allegations contained in Paragraph 5 of the Petition, Respondent neither admits nor denies the same for the reason Respondent is without sufficient knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proofs. 6. As to the allegations contained in Paragraph 6 of the Petition, Respondent admits the same. 7. As to the allegations contained in Paragraph 7 of the Petition, Respondent neither admits nor denies the same for the reason Respondent is without sufficient knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proofs. 8. As to the allegations contained in Paragraph 8 of the Petition, Respondent admits the same. 9. As to the allegations contained in Paragraph 9 of the Petition, Respondent admits the same. 10. As to the allegations contained in Paragraph 10 and its subparts of the Petition, Respondent denies the same as untrue. 11. As to the allegations contained in Paragraph 11 of the Petition, Respondent neither admits nor denies the same for the reason Respondent is without sufficient
Page 3
3 knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proofs. 12. As to the allegations contained in Paragraph 12 of the Petition, Respondent neither admits nor denies the same for the reason Respondent is without sufficient knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proofs. 13. As to the allegations contained in Paragraph 13 of the Petition, Respondent neither admits nor denies the same for the reason Respondent is without sufficient knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict proofs. 14. Respondent further states the ratio of the average level of assessment in relation to true cash value in the assessment district is 50%, and the equalization factor was uniformly applied in the assessment district for the year in question. WHEREFORE, Respondent, TOWNSHIP OF LYON, denies that Petitioner is entitled to the relief it seeks and respectfully requests that the Respondent's assessment and taxable value of the subject property be affirmed or increased, that Petitioner's Petition be dismissed with prejudice and that Respondent be granted costs and attorney fees so wrongfully sustained. Respectfully submitted, ROSATI, SCHULTZ, JOPPICH & AMTSBUECHLER, P.C. /s/ Jeremy J. Romer Jeremy J. Romer (P77287) Attorney for Respondent 27555 Executive Drive, Suite 250 Farmington Hills, MI 48331 (248) 489-4100 jromer@rsjalaw.com Dated: August 27, 2026
Page 4
4 Affirmative Defenses For its further Answer to Petitioner's Petition and by way of its Affirmative Defenses, Respondent states as follows and demands an answer from Petitioner as to each: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. 2. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, 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 with the mode and method applied in the case of all of the properties in the Respondent's taxing unit for the year in question. 4. Petitioner fails to allege specific and sufficient facts to establish the true cash value, assessed value and taxable value of its property. 5. 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 its allegations that the property's taxable value is improper. 6. 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. 7. Petitioner, in essence, asks that this Honorable
Page 5
5
Page 6
6
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.
EntireTribunalCaseISAnswer.pdfRead complete document text →
Read document text excerpt
Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Respondent MTT DOCKET NO. 26-001616 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government Township Of Lyon (OAKLAND) First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone 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 Jeremy M.I. J Last Name Romer Firm Name (if any) Rosati, Schultz, Joppich & Amtsbuechler, P.C. Address (No., Street, P.O. Box or Rural Route) 27555 Executive Drive Suite 250 City or Town Farmington Hills State Michigan ZIP Code 48331 Telephone Number 2484894100 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jromer@rsjalaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Jeremy J. Romer /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.
POS_USA2GO_QCK_STORETIM_HORTONS_26-001616.pdfRead complete document text →
Read document text excerpt
Page 1
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: 26-001616 Page 1 of 2 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL USA2GO QCK STORE/TIM HORTONS, Petitioner, v MTT Docket No. 26-001616 LYON TOWNSHIP, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Senior Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com Oakland County Equalization Division 250 Elizabeth Lake Road, Suite 1000W Pontiac, MI 48341 248-858-0740 _____________________________________________________________________________/ PROOF OF SERVICE STATE OF MICHIGAN ) )ss COUNTY OF OAKLAND ) Jennifer Lunsford, states that on 8/20/2026, in compliance with TTR 221, she did place in the US mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number as well as this Proof of Service of Petition for the above captioned appeal to the units of government listed on the second page of this Proof of Service of Petition. /s/Jennifer Lunsford Jennifer Lunsford Karen Cameron states that she submitted electronically on 8/20/2026, to the Michigan Tax Tribunal a copy of this Proof of Service of Petition at eFile through www.etaxappeal.lara.state.mi.us. /s/Karen Cameron Karen Cameron
Page 2
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: 26-001616 Page 2 of 2 By Certified Mail Assessor’s Office Oakland County Equalization Division 250 Elizabeth Lake Road, Suite 1000W Pontiac, MI 48341 Office of the Township Clerk Lyon Township Clerk's Office 58000 Grand River Avenue New Hudson, MI 48165 By First Class Mail Director of Equalization Oakland County Equalization Director 250 Elizabeth Lake Road, Suite 1000W Pontiac, MI 48341 County Clerk’s Office Oakland County Clerk’s Office 1200 N Telegraph Road Pontiac, MI 48341 Secretary of the School Board Secretary South Lyon School district 345 South Warren South Lyon, Michigan Treasurer for the State of Michigan Michigan Department of Treasury Lansing, MI 48922
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.
SubsequentFiling.pdfRead complete document text →
Read document text excerpt
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: 26-001616 Is this case currently pending in the Small Claims Division? No Party Filing Document Petitioner Files Document Type: Proof of Service: Petition Attachment File Name: POS_USA2GO_QCK_STORETIM_HORTONS_26-001616 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.
USA2GOQCKSTORETIMHORTONS.PET & POS.pdfRead complete document text →
Read document text excerpt
Page 1
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 1 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL USA2GO QCK STORE/TIM HORTONS, Petitioner, v MTT Docket No. Lyon Township, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com Lyon Township Assessing Office 58000 Grand River Avenue New Hudson, MI 48165 (248) 437-2240 _____________________________________________________________________________/ 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. The Petitioner in this matter, USA2GO QCK STORE/TIM HORTONS, has the legal residence or principal office address of 130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada. Petitioner is a party in interest with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject Property) 21-31-200-041. If the Subject Property in this petition includes more than one (1) real property tax parcel, the Subject Property’s tax parcels are contiguous. 2. The Subject Property is located in Oakland County.
Page 2
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 2 of 5 3. Respondent, Lyon Township of Oakland County, assesses and collects property taxes on the Subject Property. 4. The Subject Property is real property and is classified as Commercial. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. Protest to the 2026 Board of Review was not made and is not required by law for the Subject Property. 6. The Subject Property’s address is: 21725 Pontiac Trl, South Lyon MI 48178 7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. 8. The tax year(s) at issue are: 2026 9. The values for the Subject Property as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 21-31-200-041 $893,700.00 $446,850.00 $408,680.00 10. The 2026 assessment, assessed value, state equalized value and taxable value imposed upon all parcels of the Subject 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, assessed value, state equalized value and/or taxable value exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law;
Page 3
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 3 of 5 b. The assessment, assessed value, state equalized value and/or taxable value are at higher percentages of true cash value than permissible under the Michigan Constitution, applicable statutes and case law; c. The assessment, assessed value, state equalized value and/or taxable value are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and d. The assessment, assessed value, state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and denies Petitioner its constitutional rights to uniformity, equal protection and dues process of law. 11. Petitioner contends that the actual values for the Subject Property are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 21-31-200-041 $581,600.00 $290,800.00 $290,800.00 12. The amount of value in contention for the Subject Property is: Tax Year Parcel Number Assessed Value in Contention 2026 21-31-200-041 $156,050.00 13. Petitioner relies on the following specific facts to support the relief requested: Market sales and income data indicates that the subject property’s assessed value, state equalized value and taxable value exceed 50% of its actual market value. In addition, the cost less depreciation method Respondent utilizes to establish the Subject Property’s assessment at issue is not related to the Subject Property’s actual market value.
Page 4
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 4 of 5 WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully Submitted, COLLIERS INTERNATIONAL Representative for Petitioner By:_/s/ Joshua T. Shillair__Dated:05/18/2026 Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal 400 E 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com
Page 5
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 5 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL USA2GO QCK STORE/TIM HORTONS, Petitioner,
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.
EntireTribunalCaseISPetition.pdfRead complete document text →
Read document text excerpt
Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Petitioner MTT DOCKET NO. Section 1: Petitioner’s Contact Information Filer type: Organization Local Unit of Government First Name M.I. Last Name/Company Name USA2GO QCK STORE/TIM HORTONS Home Address (No., Street, P.O. Box or Rural Route) 130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada. City or Town TORONTO State Michigan ZIP Code 12345 Telephone Number 2482261632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Joshua M.I. Thomas Last Name Shillair Firm Name (if any) Colliers International Address (No., Street, P.O. Box or Rural Route) 400 W 4th Street, Suite 350 City or Town Royal Oak State Michigan ZIP Code 48067 Telephone Number 248-226-1632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 21725 Pontiac Trl SOUTH LYON
Page 2
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48178 Taxing Authority (City or Township) Township Of Lyon (OAKLAND) County Oakland 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.) N/A Section 5: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values If “Other”, please explain: Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 21-31-200-041 Classification of Property: Real (check one) Commercial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 446850 Current Taxable Value as established by the Board of Review: 408680 What do you believe is the fair market value (also known as True Cash Value)? 581600 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 290800 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 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.
Page 3
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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/ /s/Joshua T. Shillair Payment Information Amount: 400 Success: True Message: "" Waiver Code: Transaction Number: 26052787104755 Supporting Waiver Documents:
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.
ET_Notice_of_Docket_Number.2026-08-20_06-42-26.pdfRead complete document text →
Read document text excerpt
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 USA2GO QCK Store / Tim Hortons, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001616 Township Of Lyon, 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 20, 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
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.
USA2GOQCKSTORETIMHORTONS.PET & POS.pdfRead complete document text →
Read document text excerpt
Page 1
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 1 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL USA2GO QCK STORE/TIM HORTONS, Petitioner, v MTT Docket No. Lyon Township, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com Lyon Township Assessing Office 58000 Grand River Avenue New Hudson, MI 48165 (248) 437-2240 _____________________________________________________________________________/ 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. The Petitioner in this matter, USA2GO QCK STORE/TIM HORTONS, has the legal residence or principal office address of 130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada. Petitioner is a party in interest with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject Property) 21-31-200-041. If the Subject Property in this petition includes more than one (1) real property tax parcel, the Subject Property’s tax parcels are contiguous. 2. The Subject Property is located in Oakland County.
Page 2
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 2 of 5 3. Respondent, Lyon Township of Oakland County, assesses and collects property taxes on the Subject Property. 4. The Subject Property is real property and is classified as Commercial. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. Protest to the 2026 Board of Review was not made and is not required by law for the Subject Property. 6. The Subject Property’s address is: 21725 Pontiac Trl, South Lyon MI 48178 7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. 8. The tax year(s) at issue are: 2026 9. The values for the Subject Property as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 21-31-200-041 $893,700.00 $446,850.00 $408,680.00 10. The 2026 assessment, assessed value, state equalized value and taxable value imposed upon all parcels of the Subject 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, assessed value, state equalized value and/or taxable value exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law;
Page 3
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 3 of 5 b. The assessment, assessed value, state equalized value and/or taxable value are at higher percentages of true cash value than permissible under the Michigan Constitution, applicable statutes and case law; c. The assessment, assessed value, state equalized value and/or taxable value are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and d. The assessment, assessed value, state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and denies Petitioner its constitutional rights to uniformity, equal protection and dues process of law. 11. Petitioner contends that the actual values for the Subject Property are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 21-31-200-041 $581,600.00 $290,800.00 $290,800.00 12. The amount of value in contention for the Subject Property is: Tax Year Parcel Number Assessed Value in Contention 2026 21-31-200-041 $156,050.00 13. Petitioner relies on the following specific facts to support the relief requested: Market sales and income data indicates that the subject property’s assessed value, state equalized value and taxable value exceed 50% of its actual market value. In addition, the cost less depreciation method Respondent utilizes to establish the Subject Property’s assessment at issue is not related to the Subject Property’s actual market value.
Page 4
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 4 of 5 WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully Submitted, COLLIERS INTERNATIONAL Representative for Petitioner By:_/s/ Joshua T. Shillair__Dated:05/18/2026 Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal 400 E 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com
Page 5
2026 Entire Tribunal Property Tax Petition & Proof of Service USA2GO QCK STORE/TIM HORTONS v Lyon Township Parcel Number: 21-31-200-041 MTT Docket No.: Page 5 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL USA2GO QCK STORE/TIM HORTONS, Petitioner,
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.
EntireTribunalCaseISPetition.pdfRead complete document text →
Read document text excerpt
Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Petitioner MTT DOCKET NO. Section 1: Petitioner’s Contact Information Filer type: Organization Local Unit of Government First Name M.I. Last Name/Company Name USA2GO QCK STORE/TIM HORTONS Home Address (No., Street, P.O. Box or Rural Route) 130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada. City or Town TORONTO State Michigan ZIP Code 12345 Telephone Number 2482261632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Joshua M.I. Thomas Last Name Shillair Firm Name (if any) Colliers International Address (No., Street, P.O. Box or Rural Route) 400 W 4th Street, Suite 350 City or Town Royal Oak State Michigan ZIP Code 48067 Telephone Number 248-226-1632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 21725 Pontiac Trl SOUTH LYON
Page 2
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48178 Taxing Authority (City or Township) Township Of Lyon (OAKLAND) County Oakland 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.) N/A Section 5: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values If “Other”, please explain: Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 21-31-200-041 Classification of Property: Real (check one) Commercial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 446850 Current Taxable Value as established by the Board of Review: 408680 What do you believe is the fair market value (also known as True Cash Value)? 581600 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 290800 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 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.
Page 3
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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/ /s/Joshua T. Shillair Payment Information Amount: 400 Success: True Message: "" Waiver Code: Transaction Number: 26052787104755 Supporting Waiver Documents:
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.