Property tax assessment; True cash value (TCV); MCL 211.27(1); Mathieu-Gast Home Improvement Act exemption (M-G exemption); MCL 211.27(2); Normal repairs, replacement, & maintenance; Burden of proof; MCL 205.737(3); Burden of going forward; President Inn Props, LLC v Grand Rapids; Tax Tribunal’s (TT) independent duty to determine value; Great Lakes Div of Nat’l Steel Corp v Ecorse; Dismissal for lack of competent evidence; Jones & Laughlin Steel Corp v Warren; Taxable value (TV)

The court held that the TT did not err by dismissing petitioner’s challenge to his property assessment because he failed to produce sufficient evidence supporting his claimed M-G exemption or the property’s TCV. Petitioner challenged an increase in the 2024 TV of his residential property, arguing that renovations were exempt from consideration under MCL 211.27(2). The TT dismissed the petition after finding he did not provide adequate evidence of the renovations or the property’s value. On appeal, the court held that the TT’s findings were supported by competent, material, and substantial evidence. Although MCL 211.27(2) bars assessors from considering increases in TCV resulting from “normal repairs, replacement, and maintenance” until the property is sold, petitioner failed to provide sufficient evidence for the TT to determine “what, if any, improvements may qualify” under the statute. The court noted that he provided some testimony about upstairs bathroom and bedroom work, but he could not identify when the heating system or kitchen were updated and offered no documentary evidence beyond a bathroom permit. The court also held that dismissal was appropriate because petitioner did not meet his burden as to TCV. His testimony that he purchased the home several years earlier for “over $503,000” did not trigger the TT’s duty to make an independent valuation. Affirmed.