Whether the petitioners were entitled to a homestead exemption under MCL 211.7cc and 7dd; Interpretation of statutory tax exemptions; Detroit v. Detroit Commercial Coll.; "Owner"; "Person"; Who or what owned the property in question during the relevant tax years; Effect of the quitclaim deed to the petitioners' limited liability company (LLC); Frost v. Cockerham; Whether the term "owner" should be limited to the definitions provided in MCL 211.7dd(b) (§ 7dd(b)); Expressio unius est exclusio alterius; Whether the LLC was an owner under § 7dd(b)(vi); Whether the 2004 correction deed should be given retroactive effect; Reliance on equity

Holding the LLC, not the trust, owned the property in question during the relevant tax years and neither the LLC nor petitioners qualified as an "owner" for purposes of the homestead exemption, the court concluded the Tax Tribunal properly interpreted and applied MCL 211.7cc and 7dd in ruling petitioners were not entitled to a homestead exemption for the home they occupied for tax years 2001-2003. In 2000, petitioners executed a comprehensive estate plan, which included formation of a LLC and establishing revocable living trusts. The petitioner-wife (C.) signed documents to organize the LLC in her capacity as trustee of her trust. The LLC's operating agreement listed C., as trustee of her trust, as the LLC's sole member, thus actually making the trust the LLC's sole member. On March 28, 2000 petitioners executed a quitclaim deed transferring title of the property to the LLC. After the respondent determined in 2004 the property did not qualify for the homestead exemption because the LLC now owned it, petitioners received additional assessments for tax years 2001-2003. They paid the assessments under protest and executed a correcting quitclaim deed, trying to make it retroactively effective as of March 28, 2000, in which the LLC transferred title of the property to the trust. Petitioners appealed the rescission of the exemption for tax years 2001-2003. They could not claim the homestead exemption as persons under § 7dd(b) because they no longer owned the property. "A 'person' means only an 'individual,' as opposed to a business organization, when considering that term in relation to MCL 211.7cc." Since a "person" is limited to an individual, the LLC could not be an owner pursuant to § 7dd(b)(i) through (v). It was also not an "owner" as defined by § 7dd(b)(vii) or (viii). The court concluded § 7dd(b)(vi) also did not apply because under the trust agreement, C., not the LLC, was the settlor-grantor. The court rejected petitioners' claim the 2004 correction deed should be given retroactive effect, concluding equity did not require their mistake in giving up their exemption be rectified. Affirmed.