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Chelsea Main Street Building LLC.pdf

Chelsea Main Street Building LLC, Petitioner Vs. City Of Chelsea, Respondent · 25-002845-TT

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Page 1

Honigman LLP 

COSTS ADVANCED ACCOUNT 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

6/2/25 

] 

99997/997594/SLM 

*4%$400.00%** 

Filing Fee for Petition for Chelsea Main 

Parcel 06-06-12-111-003 

RECEIVED 

JUN 04 2025 

MICHIGAN TAX TRIBUNAL 

TranInfo:dé06 

26021222-1 

06/03/25 

Chit: 

040626 

Ant: $400.00 

ID: 

HONIGHAN LLP 

21074678.1

Page 2

ep RECEIVED 

RECEN 

ass 

7 

: 

JUN 0% 

wn oan 

A 

STATE OF MICHIGAN 

+ TRUBGRAGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGUL ARGRSENFXIRS 

MICHIGAN TAX TRIBUNAL 

Chelsea Main Street Building LLC, 

Petitioner, 

v. 

MTT Docket No. 

Parcel No. 06-06-12-111-003 

City of Chelsea, 

Respondent. 

Stewart L.. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Petition 

Chelsea Main Street Building LLC (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1. 

Petitioner's principal office address is 320 N. Main St., Suite 200, Ann Arbor, MI 

48104. Petitioner is a party in interest with respect to property taxes on tax parcel number 06-06- 

12-111-003 ("Petitioner's Property"), with an address of 311 N. Main St., located in Washtenaw 

County, Michigan.

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3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$862,900 and assessed Petitioner's Property at $862,900, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4. 

Petitioner's Property is classified as commercial. Petitioner's Property is presently 

used or available for use for commercial purposes. 

Petitioner believes that Petitioner's Property 

was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (¢) taxable 

value, and (d) uniformity. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7. 

No board of review protest was required for Petitioner’s Property. 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The 2025 assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The 2025 assessment, including state equalized value and/or taxable value, 

is at a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The 2025 assessment, including taxable value and/or state equalized value,

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(d) 

The 2025 assessment, including state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $862,900 to $400,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $862,900 to $400,000; (iii) 

requiring payment to Petitioner of the refunds attributable to the foregoing relief, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, Michigan 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Dated: June 2, 2025

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