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Abeyance Response_Denso_FINAL.pdf

Denso International America Inc Petitioner Vs. City Of Southfield Respondent · 26-000133-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Denso International America, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000133 

 

Parcel No. 76-24-20-326-228 

 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorney for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7270 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

RESPONDENT’S RESPONSE TO PETITIONER’S 

MOTION TO HOLD CASE IN ABEYANCE 

 

Respondent, City of Southfield, by and through its attorneys, Hallahan & Associates, P.C., 

states the following in response to Petitioner’s Motion to Hold Case in Abeyance: 

1. 

Respondent admits the allegations in Paragraph 1 as to subject parcel and parcel 

location. Respondent denies the remainder of the allegations set forth in Paragraph 1 for the reason 

that the same are untrue. Per Petitioner’s Petition, only the 2024 and 2025 tax years are identified 

to be at issue and the above captioned appeal was “limited solely to correcting arithmetic errors or 

mistakes in the Contested Tax Bills and is not a valuation appeal.”1 

 

1 Petitioner’s Petition at Paragraphs 16 & 18.

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2. 

Respondent neither admits nor denies the allegations in Paragraph 2 as MTT docket 

nos. 25-003802 and 26-000133 speak for themselves. 

3. 

Respondent neither admits nor denies the allegations in Paragraph 2 as MTT docket 

nos. 25-003802 and 26-000133 speak for themselves. 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 as the 

Prehearing General Call and Order of Procedure speaks for itself. 

5. 

Respondent neither admits nor denies the allegations in Paragraph 5 as MTT docket 

nos. 25-003802 and 26-000133 speak for themselves. 

6. 

Respondent admits that a Final Opinion and Judgment in the above captioned 

appeal would resolve the above captioned appeal (subject to any appellate proceedings). 

Respondent denies that the issuance of a Final Opinion and Judgment in MTT 25-003802 is likely 

to resolve the above captioned appeal or the parties’ desire to proceed with the above captioned 

appeal as said matters pertain to not only different tax years but claims. Nor does the above 

captioned appeal concern a sequential tax year. MTT docket no. 25-003802 pertains to an appeal 

of the State Tax Commission’s (hereinafter STC) determination that certain property had been 

omitted from the subject property’s 2020-2022 assessments. As noted above, the above captioned 

appeal pertains to alleged “arithmetic errors or mistakes” in the subject property’s 2024-2025 tax 

bills. Petitioner has failed to state or provide any explanation as to how a Final Opinion and 

Judgment in MTT docket no. 25-003802 will help the parties reach a resolution regarding the 

alleged arithmetic errors in the subject property’s 2024-2025 tax bills denoted to be at issue in the 

above captioned appeal. 

7. 

Respondent denies the allegations in Paragraph 7 for the reasons set forth above.

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8. 

Respondent denies the allegations in Paragraph 8 for the reasons set forth above. 

To the contrary, holding the above captioned appeal in abeyance pending a case that—based on 

the claims set forth in Petitioner’s Petitions—bears no relevancy to the above captioned appeal 

will only cause unreasonable and substantial delay to the above captioned appeal. 

9. 

Respondent admits that proceeding with the above captioned appeal will likely 

require the parties and the Tribunal to expend substantial resources. However, for the reasons set 

forth above there is no reason to believe that placing the above captioned appeal in abeyance will 

conserve said resources—abeyance will simply and unjustifiably delay expenditure. 

10. 

Respondent denies the allegations in Paragraph 10 for the reasons set forth above. 

11. 

Respondent acknowledges the relief requested by Petitioner via the final paragraph 

of its Motion but denies that Petitioner is entitled to its requested relief for the reasons set forth 

above. 

WHEREFORE, Respondent, City of Southfield, requests the Tribunal enter an Order 

denying Petitioner’s Motion to hold the above captioned appeal in abeyance pending the resolution 

of the above captioned appeal and MTT docket no. 25-003802. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Kelsea M. Melcher_____________ 

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 

Dated: July 21, 2026 

(248) 731-3089

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PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Response to 

Petitioner’s Motion to Hold Case in Abeyance to: 

 

Jackie J. Cook 

Honigman LLP 

jcook@honigman.com 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

/s/ Kelsea M. Melcher_______________ 

Dated: July 21, 2026 

Kelsea M. Melcher

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