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 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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3 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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4 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