Joint Motion for Abeyance.pdf
Target Corporation, Petitioner Vs. Township Of Clinton, Respondent · 25-002276-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, v CLINTON TOWNSHIP, Respondent. Docket No. 25-002276 Parcel No. 16-11-34-328-004 _____________________________________________________________________________/ MICHAEL B. SHAPIRO (P20282) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA A. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-003079 The parties, by and through their respective counsel, state the following in support of the above captioned Motion: 1. The above captioned appeal concerns the 2025 valuation of the big box store commonly known as Target – Parcel No. 16-11-34-328-004 - located in Macomb County. 2. With the exception of the tax year at issue, the parties, property, and issues raised in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in MTT Docket No. 24-003079 – an appeal concerning the 2024 tax year. 3. The above captioned 2025 appeal is ready to be placed on a Prehearing General Call and Order of Procedure.
Page 2
2 4. However, as of the filing of the above captioned Motion, the 2024 matter (MTT Docket No. 24-003079) has not yet been resolved. A Prehearing Conference is scheduled for December 16-30, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered until Summer 2026 at the earliest. 5. A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24- 003079 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it could potentially be a waste of time and resources for the parties and the Tribunal to proceed with the above captioned appeal when the prior 2024 appeal remains pending. 6. To proceed with this case before a resolution regarding MTT Docket No. 24- 003079 has been reached would likely not constitute an efficient administration of justice. 7. Proceeding with the above captioned appeal will require the parties and the Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above captioned appeal in abeyance at this juncture before substantial time and resources have been spent – including, but not limited to, the preparation of prehearing statements and valuation disclosures – is in the interest of efficiency to all parties involved and judicial economy. 8. As evidenced above, there is good cause for granting this Motion to hold the above captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24- 003079. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-003079.
Page 3
3 Respectfully submitted, HONIGMAN LLP /s/ Daniel L. Stanley_______________ MICHAEL B. SHAPIRO (P20282) DANIEL L. STANLEY (P57052) Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 Dated: October 20, 2025 HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan______________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 Dated: October 20, 2025
Page 4
Payment Receipt Application: Merchant: Merchant City/State: Merchant Location Code: Payment Status: Result Message: Confirmation Number: Payment Date: Posting Date: Billing Information: Payment Amount: Card Type: Account #: Authorization Code: Method: Michigan Tax Tribunal - 8023112272 Michigan Tax Tribunal Dimondale, MI 00001 Success Success 25102050948780 10/20/2025 10/20/2025 Laura Hallahan 2573 Leroy Lane West Bloomfield, MI 48324 mtt@hallahanlaw.com 50.00 USD VISA XXXXXXXXXXXX9550 82556G Not Present
Page 5
1 Martin, Anna (LARA) From: noreply@fiserv.com Sent: Monday, October 20, 2025 1:57 PM To: MTT Subject: Payment Confirmation Thank you for your recent payment to Michigan Tax Tribunal. If you have quesƟons please contact the Michigan Tax Tribunal at 517-335-9760. Payment ApplicaƟon: Michigan Tax Tribunal Payment Status: Payment completed successfully. ConfirmaƟon Number: 25102050948780 Payment Date: 10/20/2025 -------------------- Billing Address: Laura Hallahan 2573 Leroy Lane West Bloomfield, MI 48324 -------------------- Card Type: VISA Card Number: x9550 -------------------- Payment Amount: 50.00 USD Total Amount: 50.00 USD -------------------- DO NOT REPLY DIRECTLY TO THIS EMAIL.