24-003680 SD IC.pdf
Rhonda Holloway, Petitioner V City Of Detroit, Respondent · 24-003680-TT
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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 Rhonda Holloway, MICHIGAN TAX TRIBUNAL Petitioner, SMALL CLAIMS DIVISION v MTT Docket No. 24-003680 City of Detroit, Presiding Judge Respondent. Patricia L. Halm ORDER ADJOURNING JANUARY 22, 2026 HEARING ORDER GRANTING SUMMARY DISPOSITION IN FAVOR OF PETITIONER FINAL OPINION AND JUDGMENT The Tribunal has reviewed the file in this case and finds that Petitioner filed this appeal disputing the uncapping of taxable value (TV) of Parcel No. 22071910 for the 2024 tax year following a transfer “from mother to daughter.” Respondent filed an answer to the petition on October 23, 2024, stating that “[P]etitioner purchased the property on 8/28/23. Per Proposal A, the [TV] of a property uncaps . . . the following year after a transfer of ownership, but upon review the property was not a transfer of ownership recapped 2024 TV at DBOR to 22,388 [sic].”1 MCR 2.116(I)(1) states that “if the pleadings show that a party is entitled to judgment as a matter of law, or if the affidavits or other proofs show that there is no genuine issue of material fact, the court shall render judgment without delay.” Given that Respondent does not dispute that the uncapping was in error and has further indicated that the property’s TV was or will be recapped by the Board of Review (BOR), the Tribunal finds that summary disposition in favor of Petitioner is appropriate.2 As a result: The property’s TV, as established by the BOR for the tax year at issue, is: Parcel Number: 22071910 Year TV 2024 $82,900 1 Due to the timing of Respondent’s filing in October 2024, it is unclear whether it meant that the TV was recapped at the July 2024 BOR, or that it would be recapped at the December 2024 BOR. Regardless of this discrepancy, the answer establishes that there is no matter in controversy relative to the uncapping or the property’s correct TV. 2 Pursuant to MCL 205.731: “The tribunal has exclusive and original jurisdiction over . . . . [a] proceeding for direct review of a final decision, finding, ruling, determination, or order of an agency relating to assessment, valuation, rates, special assessments, allocation, or equalization, under the property tax laws of this state.” Id. (emphasis added). Thus, the July and December BOR would have no authority over the property’s 2024 TV, which was protested and affirmed by the March 2024 BOR.
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MTT Docket No. 24-003680 Page 2 of 3 The property’s final TV, as determined by the Tribunal for the tax year at issue, is: Parcel Number: 22071910 Year TV 2024 $22,388 IT IS SO ORDERED. IT IS FURTHER ORDERED that the hearing scheduled to commence on January 22, 2026 is ADJOURNED. IT IS FURTHER ORDERED that Summary Disposition is GRANTED in favor of Petitioner. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax year at issue shall correct or cause the assessment rolls to be corrected to reflect the property’s taxable values as provided in this Final Opinion and Judgment within 20 days of entry of this Final Opinion and Judgment, subject to the processes of equalization.3 To the extent that the final level of assessment for a given year has not yet been determined and published, the assessment rolls shall be corrected once the final level is published or becomes known. IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund within 28 days of entry of this Final Opinion and Judgment. If a refund is warranted, it shall include a proportionate share of any property tax administration fees paid and penalty and interest paid on delinquent taxes. The refund shall also separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall bear interest from the date of payment to the date of judgment, and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Final Opinion and Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, (viii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, and (ix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. This Final Opinion and Judgment resolves the last pending claim and closes this case. 3 See MCL 205.755.
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MTT Docket No. 24-003680 Page 3 of 3 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: January 21, 2026 By _____________________________ ejg/am 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