Response to Order of Default.pdf

Half Moon Road Holdings Inc., Petitioner V City Of Detroit, Respondent · 25-002995-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

HALF MOON ROAD HOLDINGS INC., 

Petitioner, 

MTT Docket No. 25-002995 

v. 

CITY OF DETROIT, 

Respondent. 

FRIEDLAENDER NYKANEN & 

ROGOWSKI PLC 

By: David E. Nykanen (P47763) 

1700 W. Big Beaver Road 

Suite 220 

Troy, Michigan 48084 

(248) 629-0880 

Attorneys for Petitioner 

CURE OF ORDER 

OF DEFAULT 

Petitioner, HALF MOON ROAD HOLDINGS INC., (“Petitioner”) through 

its 

attorneys, FRIEDLAENDER NYKANEN & ROGOWSKI PLC, 

states 

as 

follows for its cure of the default: 

1. 

On March 17, 2025, Petitioner timely filed its March Board of Review 

Petition with the City of Detroit. The Petition is attached hereto and was timely 

transmitted to the City of Detroit.

2. 

The Notice of Assessment from the City listed numerous available 

Board of Review dates through March 24, 2025. See attached. 

3. 

However, the City takes the position, unsupported by its Notice of 

Assessment, that the deadline was two weeks prior to the last listed Board of 

Review date. Correspondence from the City is attached. 

4. 

Petitioner timely appeared before the Board of Review and the City 

rejected 

its 

appeal. 

The 

correspondence 

from 

the 

City 

serves 

as 

the 

final 

determination of the City and is the basis for this appeal. 

WHEREFORE, Petitioner requests 

a hearing before 

the Michigan Tax 

Tribunal for a determination of the assessed and taxable value for the subject 

properties and reduce the assessed, state equalized and taxable values of the subject 

property and order a refund with interest as provided by Michigan law. 

Respectfully Submitted, 

FRIEDLAENDER NYKANEN & 

ROGOWSKI PLLC 

ST 

Datid4. NyWanen (P47763) 

1700 W. Big 

Beaver Road 

Suite 2 

Troy, MI 48084 

(248) 629-0880 

Attorneys for Petitioner 

Dated: October 8, 2025

ois te aay 

THIS IS NOT A TAX BILL 

L-4400 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c, as amended. This 

is a model assessment notice to be used by the local assessor. 

FROM: 

PARCEL IDENTIFICATION 

CITY OF DETROIT 

PARCEL NUMBER: 27220090. 

OFFICE OF THE ASSESSOR 

P 

ADDRESS: 17381 PON 

2 WOODWARD AVE., SUITE 804 

ROPERTY 

ONTCHARTRAIN 

DETROIT, MI 48226 

OWNER’S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL 

PRINCIPAL RESIDENCE EXEMPTION 

117289006517 / 1316 

% Exempt As "Homeowners Principal 

0.0000% 

C0 

LY [YRC RCE 

{LLL {Lee 

ree 

Lf 

LT 

LU 

Residence": 

% Exempt As "Qualified Agricultural Property": 0.0000% 

HALF MOON ROAD HOLDINGS INC 

113 MILMAY AVE 

% Exempt As "MBT Industrial Personal”: 

0.0000% 

HAUPPAUGE, NY 11788-3324 

% Exempt As "MBT Commercial Personal”: 

0.0000% 

Exempt As "Qualified Forest Property”: 

 [] Yes X No 

Exempt As "Development Property": 

[J Yes X No 

LEGAL DESCRIPTION: W PONCHARTRAIN S 4.67 FT ON E LINE & RNG TO A PTE IN 

S W COR 54 55 DETROIT GOLF CLUB 

SUB L30 P99-100 PLATS, W C R 2/135 104.67 IRREG. NEZ HOMESTEAD CERT #NH2008-0812 RELATED PARCEL 

ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: RESIDENTIAL-IMPROVED 

PRIOR YEAR'S CLASSIFICATION: RESIDENTIAL-IMPROVED 

; 

i 

CURRENT 

The Snes " reap ws 

PRIOR AMOUNT 

TENTATIVE 

imple 

your 

tax 

bill 

for 

the 

year by approximately: 

YEAR: 2024 

AMOUNT YEAR: 

$543 

2025 

CURRENT YEAR 

1. TAXABLE VALUE: 

242,891 

250,420 

7,529 

2. ASSESSED VALUE: 

276,100 

262,800 

-13,300 

3. TENTATIVE EQUALIZATION FACTOR: 

1.00 

4. STATE EQUALIZED VALUE (SEV): 

276,100 

262,800 

-13,300 

5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: 

WAS NOT 

6. ASSESSOR CHANGE REASON: MARKET VALUE 

7. ESTIMATED TRUE CASH VALUE: 525,552 

8. EFFECTIVE AGE: 

33 

9. YEAR BUILT: 1922 

The 2025 Inflation Rate Multiplier is: 1.031 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed 

to the following: 

"Y 

Name: 

Telephone Number: 

Email Address: 

Office of the Assessor 

313-224-3011 

AsktheAssessor@detroitmi.gov 

| 

[March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: 

Wednesday, March 5th, 6th, 7th and 8th, 2025, from 9:00 a.m. to 12:00 p.m. & 1:00 p.m. to 4:30 p.m. 

March 10th, 11th, 12th, 14th and 15th, 2025, from 9:00 a.m. to 12:00 p.m. & 1:00 p.m. to 4:30 p.m. 

March 17th, 18th, 19th, 20th, 21st and 22nd, 2025, from 9:00 a.m. to 12:00 p.m. & 1:00 p.m. to 4:30 p.m. 

March 24th, 25th, 26th, 28th, and 29th, 2025, from 9:00 a.m. to 12:00 p.m. & 1:00 p.m. to 4:30 p.m. 

March 13th and March 27th, 2025, from 9:00 a.m. to 12:00 p.m. & 1:00 p.m. to 4:30 p.m. & 6:00 p.m.-9:00 p.m.

Michigan Department of Treasury 

618 (Rev. 11-12) 

Petition to Board of Review 

L-4035 

This form is issued under the authority of P.A. 206 of 1893, as amended. Filing is voluntary, however you may not appeal to the Michigan Tax Tribunal 

or the State Tax Commission unless you first protest to the Board of Review. 

TO BE COMPLETED BY OWNER OR OWNER'S AGENT 

Owner's Name (Please Print or Type) 

Petitioner's Name 

(If Other than Owner. 

Please Print or Type) 

Half Moon Road Holdings Inc 

David E. Nykanen 

Township or City 

County 

Detroit 

Wayne 

The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified 

agricultural property exemption of the following described property: 

Property Identified (Parcel code required. Property address & legal description optional) 

27220090. 

Protested Item 

[x] Assessed Value 

Tentative Taxable Value 

] Classification 

OJ Qualified Agricultural 

Property Exemption 

1. PROTEST OF ASSESSMENT 

(Complete this section for a protest of assessed value and/or tentative taxable value) 

Assessed Amount 

Owner's Estimate of True Cash Value 

Tentative Taxable Value 

Year 

$262,800 

$290,000 

$250,420 

2025 

2. PROTEST OF CLASSIFICATION 

(Complete this section for a request to change the classification. The Board of Review must make their decision regarding classification in 

accordance with Section 211.34c of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular 

classification has on that property's status as 

a homeowner's principal residence or qualified agricultural property.) 

Classification of property on this year's assessment roll 

Classification should be (check one of the following): 

] Agricultural 

] Industrial 

J Timber Cutover 

] Utility (Personal Property Only) 

OJ Commercial 

] Residential 

] Developmental 

3. PROTEST OF EXEMPTION FOR QUALIFIED AGRICULTURAL PROPERTY 

(If the assessor has denied or changed the percentage of the exemption from the 18 mills of local school operating tax for qualified agricultural 

property, the owner may appeal this action to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT 

UPON THE EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.) 

Percent qualified agricultural exemption granted by assessor (Enter 0 if exemption 

Percent qualified agricultural exemption requested by owner (Enter 100 if full 

denied) 

exemption requested) 

4. REASON FOR PROTEST 

State reason(s) for protest of assessed value and/or the tentative taxable value and/or classification and/or qualified agricultural property exemption 

Property is assessed at more than 50% of property's true cash value.

Form 618, Page 2 

FOR BOARD OF REVIEW USE ONLY 

INSTRUCTIONS: Incorporate a copy of this form and the assigned number in the Board of Review minutes. 

Petition Number 

Parcel Code 

1. ASSESSED VALUE 

Disposition by Board of Review. The Board of Review must oo 

[enon ors actan elon 

[| Denied 

[| Assessed Value Changed From 

to] 

Record of vote - Board or three member committee of board 

Chairperson: [| Yes 

[_] No 

Reason for board action 

Member: [ | Yes 

[| No 

Member: [_] Yes 

[J No 

Initials 

Initials 

Initials 

If you disagree with the decision of the Board of Review regarding tentative assessed value, you may appeal that decision by filing a petition with the 

Michigan Tax Tribunal at P.O. Box 30232, Lansing, MI 48909. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, 

Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and Agricultura) 

Personal Property may be appealed by July 31. The petition must be filed on a Michigan Tax Tribunal form or a form approved by the Michigan Tax 

Tribunal. Michigan Tax Tribunal forms are available at www.michigan.gov/taxtrib. 

2. TENTATIVE TAXABLE VALUE 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[| Denied 

[ ] Tentative Taxable Value Changed From 

to 

Record of vote - Board or three member committee of board 

Chairperson: [| Yes 

[ | No 

Member: [_] Yes 

[ | No 

Member: [_] Yes 

[ |] No 

Initials 

Initials 

Initials 

Reason for board action 

If you disagree with the decision of the Board of Review regarding tentative taxable value, you may appeal that decision by filing a petition with the 

Michigan Tax Tribunal at P.O. Box 30232, Lansing, MI 48909. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, 

Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and 

Agricultural Personal Property may be appealed by July 31. The petition must be filed on a Michigan Tax Tribunal form or a form approved by the 

Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan.gov/taxtrib. 

3. CLASSIFICATION 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[| Denied 

[|] Classification Changed From 

to 

Record of vote - Board or three member committee of board 

Chairperson: [| Yes [ 

| No 

Reason for board action 

Initials 

Member: 0 Yes 

OJ No 

Initials 

Member: 0 Yes 

0 No 

Initials 

If you disagree with the decision of the Board of Review regarding classification, you may appeal by sending Form 2167 to the State Tax Commission 

at P.O. Box 30471, Lansing, MI 48909 by June 30. 

4. QUALIFIED AGRICULTURAL PROPERTY EXEMPTION 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[] Exemption Request Denied 

["] Exemption percent modified from 

% to 

% 

Record of vote - Board or three member committee of board

CITY OF DETROIT - PROPERTY APPEAL 

LETTER OF AUTHORIZATION 

yweHalf Moon Road Holdings Inc. 

as the legal owner of the property stated 

herein, authorize the following individual or business: 

NAME: David E. Nykanen 

Self Prepared 

ADDRESS: 1700 W. Big Beaver Road, Suite 220 

cry: Troy 

STATE:MI 

71p- 48084 

PHONE: 2487912110 

FAX: 

EMAIL-dnykanen@fnrplc.com 

To act as my sole and designated representative on my behalf regarding the assessment 

appeal of the following property: 

PARCEL: 27220090 

ADDRESS: 

¢/0 1700 W. Big Beavere Road, Suite 220 

cIry:_Troy 

sTaTE:MI 

71p; 48084 

I further understand that the decision from my appeal is required to be provided in writing 

and hereby expressly assign to my representative the authority to receive such writing on 

my behalf. 

ownNER: Half Moon Road Holdings Inc. 

SIGNATURE; TV] 

DATE: 3/17/2025 

ADDRESS: C/0 1700. %/Big Beavere Road, Suite 220 

city: Troy 

sTATE:MI 

71p48084 

PHONE: 2487912110 

FAX: 

EMAIL: dnykanen@fnrplc.com 

All companies, LLC’s and/or corporations must provide organization documents along with title and 

name of authorized person to speak on behalf of company.

MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

 

FILING ENDORSEMENT 

 

 

This is to Certify that the 

 

for 

 

 

 

 

 ID Number: 

 

 

 

 

 

received by electronic transmission on , is hereby endorsed. 

Filed on , by the Administrator. 

 

 

The document is effective on the date filed, unless a subsequent effective date within 90 days after 

received date is stated in the document. 

 

 

 

 

 

 

 

 In testimony whereof, I have hereunto set my 

 hand and affixed the Seal of the Department, 

 

 

 

HALF MOON ROAD HOLDINGS INC

ARTICLES OF INCORPORATION

802776745

December 10, 2021

December 10, 2021

in the City of Lansing, this 10th day

in the City of Lansing, this 10th day

in the City of Lansing, this 10th day

in the City of Lansing, this 10th day

of December, 2021.

of December, 2021.

of December, 2021.

of December, 2021.

Filed by Corporations Division Administrator Filing Number: 221482160190 Date: 12/10/2021

Linda Clegg, Director

Linda Clegg, Director

Linda Clegg, Director

Linda Clegg, Director

Corporations, Securities & Commercial Licensing Bureau

Corporations, Securities & Commercial Licensing Bureau

Corporations, Securities & Commercial Licensing Bureau

Corporations, Securities & Commercial Licensing Bureau

Form Revision Date 07/2016 

ARTICLES OF INCORPORATION 

For use by DOMESTIC PROFIT CORPORATION 

Pursuant to the provisions of Act 284, Public Acts of 1972, the undersigned executes the following Articles: 

ARTICLE I

 

The name of the corporation is:

HALF MOON ROAD HOLDINGS INC

 

 

ARTICLE II 

Unless the articles of incorporation otherwise provide, all corporations formed pursuant to 1972 PA 284 have the purpose of engaging in 

any activity within the purposes for which corporations may be formed under the Business Corporation Act. You may provide a more 

specific purpose:

 

 

ARTICLE III 

1. State the total authorized shares of each class of stock that the corporation is authorized to issue. All corporations must 

authorize stock.* If there is more than one class or series of shares, state the relative rights, preferences and limitations of the shares 

of each class in Article III(2). 

Class of Stock

Total authorized 

number of shares

COMMON 

200 

 

ARTICLE IV 

The street address of the registered office of the corporation and the name of the resident agent at the registered office (P.O. 

Boxes are not acceptable):

 

1. Agent Name: 

PERRY BOATSWAIN

 

2. Street Address: 

13324 GRIENER ST

 

Apt/Suite/Other: 

2ND FLR

 

City: 

DETROIT

 

State:

MI 

Zip Code: 48205

 

3. Registered Office Mailing Address: 

P.O. Box or Street 

Address: 

13324 GREINER ST

 

Apt/Suite/Other:

2ND FLR

 

City: 

DETROIT

 

State: 

MI

MI

 

Zip Code: 48205

 

ARTICLE V 

The name(s) and address(es) of the incorporator(s) is (are) as follows:

Name

Residence or Business Address

Filed by Corporations Division Administrator Filing Number: 221482160190 Date: 12/10/2021

PERRY BOATSWAIN

13324 GREINER ST, 2ND FLR, DETROIT, MI 48205 USA 

Signed this 10th Day of December, 2021 by the incorporator(s). 

Signature

Title

Title if ''Other'' was selected 

Perry Boatswain 

Incorporator 

 

 

By selecting ACCEPT, I hereby acknowledge that this electronic document is being signed in accordance with the Act. I further certify 

that to the best of my knowledge the information provided is true, accurate, and in compliance with the Act.

 

nmlkj Decline nmlkji Accept

Coleman A. Young Municipal Center Phone: 313-628-0722 

 2 Woodward Avenue, Suite 105 Fax: 313-224-4576 

 Detroit, Michigan 48226 www.detroitmi.gov 

 

[Notification of Petition] 

 

 

 

Hello, 

 

Your petition to the 2025 March Board of Review was not submitted timely. 

As specified in all public notices, the deadline for filing was March 10th, 2025, 

by 4:30 PM. 

 

 

Thank you, 

 

Board of Review

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