24-003458.pdf

Alnamer Investment LLC, Petitioner V City Of Detroit, Respondent · 24-003458-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 

Alnamer Investment LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 24-003458 

 

City of Detroit, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal issued a Proposed Order of Dismissal (POJ) on August 21, 2025. The 

POJ states, in pertinent part, “[t]he parties have 20 days from the ‘Entered’ date below 

to notify the Tribunal in writing, by mail or by electronic filing, if they do not agree with 

the POJ and to state in writing why they do not agree with the POJ (i.e., file exceptions 

to the POJ).” 

 

On September 11, 2025, Petitioner filed exceptions to the POJ. In the exceptions, 

Petitioner states that, after conferring with Respondent’s representative, Petitioner 

believed that the parties had reached a settlement agreement. However, one week 

prior to the scheduled hearing, Petitioner’s representative was advised that a stipulation 

would not be executed. As a result, there was not sufficient time for Petitioner to submit 

evidence of the property’s true cash value (TCV). Petitioner’s exceptions further state 

that, “[a]t the June 27 hearing, [Respondent’s representative] testified that although she 

did initially agree to the stipulation, the subject property was i[n] better condition than 

she thought. Respondent[‘s representative] testified that she declined to agree to the 

stipulation because she had visited the site a ‘few weeks’ prior to the hearing.” Since 

the appeal involves the value of the subject as of December 31, 2023, the condition of 

the property, and its corresponding value in the summer of 2025, has no bearing on this 

appeal. 

 

Respondent has not filed exceptions to the POJ or a response to Petitioner’s 

exceptions. 

 

The Tribunal has considered the exceptions and the case file and finds that the 

Administrative Law Judge (ALJ) properly considered the testimony and evidence 

submitted in rendering the POJ. Specifically, the claims made within Petitioner’s 

exceptions were considered and rejected by the ALJ in the rendering of the POJ. The 

POJ summarized Petitioner’s contentions as follows: 

 

Petitioner’s representative did not have an opportunity to submit any 

evidence in this case because they believed that a settlement had been 

reached. The parties’ representatives spoke on the phone a few times and

MTT Docket No. 24-003458 

Page 2 of 4 

 

Petitioner’s representative forwarded Respondent the numbers that they 

had agreed to, but was subsequently informed that its representative would 

no longer agree to those numbers. Petitioner’s representative was 

blindsided by the last-minute reversal and seeks a rehearing. Upon inquiry 

from the Tribunal, Petitioner’s representative testified that they believed the 

parties had come to an agreement on settlement on or around June 10, 

2025; Petitioner’s representative was not able to provide any testimony on 

the facts and circumstances surrounding the 2022 sale of the property. 

 

The POJ indicated that Petitioner did not provide a value contention for the 2025 tax 

year or offer any exhibits in support of the appeal. 

 

The POJ also pointed out that the condition of the property was the primary basis for 

Petitioner’s appeal but explained that there was no documentary evidence offered 

establishing the property’s condition as of the relevant valuation dates at issue. The 

POJ concluded that Petitioner’s testimony was insufficient to meet Petitioner’s burden of 

going forward with the evidence as it related to the condition of the property. 

Furthermore, the POJ found that Petitioner failed to provide “documentary evidence of 

sales or other market-based evidence establishing the quantitative impact, if any, the 

asserted condition would have on the property’s TCV, and its representative could not 

testify to the facts and circumstances surrounding the 2022 sale of the property, which 

Respondent’s office deemed to be a non-arms-length transaction.” Thus, the Tribunal 

concludes that the ALJ’s determination that Petitioner did not meet their burden of going 

forward with the evidence is supported by the record in this case and applicable 

statutory authority. 

 

In terms of Petitioner’s claim that it had insufficient time to submit documentary 

evidence in this case, the POJ also addressed and rejected these same claims. The 

POJ noted that Petitioner had sufficient notice and opportunity to file evidence and 

prepare its case for hearing. The POJ determined that Petitioner filed the appeal on 

May 31, 2024, and the Tribunal issued a Notice of Filing on October 4, 2024, which 

indicated that the case was ready to be scheduled for hearing and the parties were 

required to submit their evidence to the Tribunal and to the opposing party at least 21 

days in advance of the hearing. The POJ further stated that the April 15, 2025 hearing 

notice also notified the parties that they were required to submit evidence to both the 

Tribunal and the opposing party at least 21 days in advance of the hearing. Although 

not specifically referenced by the POJ, TTR 289(1) also provides that “[a] copy of all 

evidence, other than rebuttal evidence, to be offered in support of a party’s contentions 

must be filed with the tribunal and served on the opposing parties not less than 21 days 

before the date of the scheduled hearing, unless otherwise ordered by the tribunal.” 

Most importantly, the POJ recognized that, “[w]hile the parties may have been engaged 

in settlement discussions, this does not negate the requirement of preparing their 

respective cases for hearing.” Upon inquiry from the ALJ, “Petitioner’s representative 

testified that the tentative settlement agreement was reached on or around June 10, 

2025, which was several days beyond the evidentiary filing deadline.” 

 

Given the above, Petitioner failed to show good cause to justify modifying the POJ or

MTT Docket No. 24-003458 

Page 3 of 4 

 

granting a rehearing.1 As such, the Tribunal adopts the POJ as the Tribunal’s final 

decision in this case.2 The Tribunal also incorporates by reference the Findings of Fact 

and Conclusions of Law contained in the POJ in this Final Opinion and Judgment. The 

Tribunal finds that dismissal of this case is warranted.3 

 

IT IS ORDERED that the case is DISMISSED. 

 

This Order resolves the last pending claim and closes this case. 

 

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. 

 

 

 

 

 

 

 

 

 

By _____________________________ 

Entered: October 31, 2025 

smm/gc 

 

 

 

 

1 See MCL 205.762. 

2 See MCL 205.726. 

3 Id.

MTT Docket No. 24-003458 

Page 4 of 4 

 

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

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