Autodie LLC v. City of Grand Rapids
305 Mich. App. 423
Mich. Ct. App.2014Background
- Autodie LLC reports personal property using Form 4798; Grand Rapids assessor rejected the form and valued property.
- Autodie petitions the State Tax Commission claiming omission or incorrect reporting under MCL 211.154.
- Commission dismisses for lack of subject-matter jurisdiction, holding Tribunal must review value determinations, not petition issues.
- Autodie petitions the Michigan Tax Tribunal to review the Commission’s dismissal; Department and Commission move to dismiss from the case.
- Tax Tribunal sua sponte grants Grand Rapids summary disposition for lack of jurisdiction; Autodie does not appeal that ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Tribunal vs Commission jurisdiction over valuation disputes | Autodie argues Commission had original or Tribunal appellate jurisdiction. | City/Tribunal contend Tribunal holds exclusive appellate jurisdiction on value disputes. | Tribunal has exclusive appellate jurisdiction over valuation disputes; Commission limited to original review. |
| Whether Commission retains original jurisdiction after Tribunal creation | Autodie asserts Commission can still hear improper assessment/omissions. | Commission only handles initial investigations; Tribunal handles appeals. | Commission retains limited original jurisdiction under MCL 211.150(3) and 211.154; Tribunal reviews appeals. |
| Omits property under MCL 211.154 | Autodie contends rejection of Form 4798 caused omitted property. | Autodie did not show omitted property; assessor performed valuation. | Property was not omitted; rejection of Form 4798 did not create omitted property. |
| Incorrect reporting under MCL 211.154 | Autodie contends assessor incorrectly reported property by rejecting Form 4798. | Taxpayer reports; assessor does not report; incorrect reporting not shown. | No incorrect reporting by the taxpayer; statute not triggered by assessor's rejection. |
| Preservation of improper assessment under MCL 211.150(3) | Autodie argued improper assessment under MCL 211.150(3). | Issue was not preserved before Commission; Tribunal lacked basis to decide. | Unpreserved issue declined; court would not review absent proper preservation. |
Key Cases Cited
- Superior Hotels, LLC v Mackinaw Twp, 282 Mich App 621 (2009) (distinguishes omitted property from rejected Form 4798 context)
- Ford Motor Co v Woodhaven, 475 Mich 425 (2006) (statutory interpretation and tax valuation framework)
- McCahan v Brennan, 492 Mich 730 (2012) (standard of review and tax decision analysis)
- US Fidelity & Guaranty Co v Mich Catastrophic Claims Ass’n, 484 Mich 1 (2009) (agency interpretations and statutory construction guidance)
- Jefferson Sch v Detroit Edison Co, 154 Mich App 390 (1986) (statutory scheme and reporting vs assessing distinction)