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Petition - Romulus Development.pdf

Romulus Development LLC, Petitioner Vs. City Of Sterling Heights, Respondent · 24-004182-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

IN THE MICHIGAN TAX TRIBUNAL 

 

Romulus Development, LLC, 

 

Petitioner, 

 

v 

 

City of Sterling Heights, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 24-_____________ 

Parcel No. 10-10-26-477-041 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2024 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. 

☒ The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

10-10-26-477-041 

Address 

13255 15 Mile Road 

Classification 

201 Comm Imp 

Use 

Retail 

County 

Macomb 

Sch Dist Warren Consolidated Schools 

 

2. 

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 7486 Lakeport Street, West 

Bloomfield, MI 48323 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ 

uniformity of the subject property’s assessment 

☐ 

the subject property’s exemption from ad valorem taxation under MCL ______

Page 2

Petition 

2 

☒ 

Unlawful uncapping of Petitioner’s property. Respondent unlawfully uncapped 

the property at the December 2024 Board of Review and this Petition is timely filed 

within 35 days of that decision. See Board of Review decision attached. 

7. 

The tax year at issue is 2024. 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

4,720,000 

2,360,000 

2,360,000 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

3,150,000 

1,575,000 

1,110,822 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

1,570,000 

785,000 

1,249,178 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2024 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioner’s property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

constitutional rights of uniformity, equal protection and due process of law; and/or 

(e) 

The property transferred ownership on January 5, 2024 and, therefore Respondent 

unlawfully uncapped the property. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

Petitioner requests that the Tribunal enter an order reducing the 2024 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: December 18, 2024 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

Filing Fee: $600

Page 4

2024 DECEMBER BOARD OF REVIEW 

Change Notice 

12/13/2024 

ROMULUS DEVELOPMENT LLC 

7486 LAKEPORT ST 

WEST BLOOMFIELD MI 48323 

Regarding Address: 13255 15 MILE RD 

Parcel Number: 10-10-26-477-041 

Dear Property Owner: 

On Dec 09, 2024 

, the December Board of Review made the following correction to the assessed value, capped 

value, taxable value and/or to the Principal Residence Exemption for the above referenced parcel. 

Original 

Corrected 

Year 

Assessed 

Capped 

Taxable 

Year 

Assessed 

Capped 

Taxable 

2024 

2,360,000 

1,110,822 

1,110,822 

2024 

2,360,000 

2,360,000 

2,360,000 

Principal Residence Exemption 

0.0000 

Principal Residence Exemption 

0.0000 

Reason: 2024 DBOR: Uncap 2024 taxable value to equal assessed value due to transfer of ownership on 

12/28/2023. 2024 Taxable Value change from $1,110,822 to $2,360,000. 

The action of the December Board of Review may be appealed to the Michigan Tax Tribunal within 35 days after 

the final decision, ruling or determination. To appeal to the Michigan Tax Tribunal, file a petition with the 

Michigan Tax Tribunal that can be obtained from their website: 

http://www.michigan.gov/taxtrib 

| 

If you have any questions regarding the above changes, please do not hesitate to contact us at (586)446-2340. 

Sincerely, 

City of Sterling Heights 

Board of Review

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