Petition for Greyhound Lines and Indian Trails(29149544.1).pdf
Indian Trails LLC F/K/A Indian Trails Inc Petitioner Vs. City Of Detroit Respondent · 26-001466-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL INDIAN TRAILS, LLC f/k/a INDIAN TRAILS, INC., Petitioners, MTT Docket No. _______________ v. Parcel Nos. 24000640. CITY OF DETROIT, Respondent. Adam J. Brody (P62035) Deborah I. Ondersma (P55907) VARNUM LLP Attorneys for Petitioner 333 Bridge Street, N.W. P.O. Box 352 Grand Rapids, MI 49501-0352 (616) 336-6000 ajbrody@varnumlaw.com diondersma@varnumlaw.com _____________________________________ PETITION Petitioner, Indian Trails, LLC, by and through it attorneys, VARNUM, LLP, states the following for its Petition against Respondent, City of Detroit: 1. Petitioner, Indian Trails, LLC (“Petitioner”), is a Delaware limited liability company that was converted from and formerly known as Indian Trails, Inc., a Michigan corporation. Petitioner’s principal place of business is located at 109 E. Comstock Street, Owosso, MI 48867. 2. The subject real property is owned by the State of Michigan, Michigan Department of Transportation.
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2
3.
Petitioner is a party-in-interest with respect to the subject real property (the "subject
property") as it is the lessee of the subject property. Petitioner also has been authorized by
Greyhound Lines, Inc. to pursue the subject appeal.
4.
Respondent, City of Detroit ("Respondent"), assesses, levies and collects the
property taxes on the subject property.
5.
Respondent has assessed the subject property under MCL 211.181 for tax year
2026.
6.
The “subject property,” located in City of Detroit, classified as 201 commercial,
improved real property and is more particular described as:
Parcel No.
Property Address
24000640.
1000 W. Lafayette, Detroit, Michigan
7.
The subject property is classified as commercial real property and so no appeal to
the March Board of Review was required.
8.
The subject property is located in Wayne County and is the Detroit Public Schools
Community District.
9.
The subject property is used as a public bus terminal in the City of Detroit.
10.
This matter involves issues relating to assessment, true cash value, taxable value,
and exemption.
11.
The tax year(s) at issue are: 2026.
12.
The Tax Year 2026 values for the subject property identified above as established
by the Notice of Assessment (and affirmed by the Board of Review) are:
Tax Year
Parcel/Address
True
Cash
Value
Assessed/State
Equalized Value
Taxable Value
2026
24000640.
1000 W. Lafayette
$576,500
$576,500
$576,500Page 3
3 13. Petitioner contends the correct values for the subject property are: Tax Year Parcel/Address True Cash Value Assessed/State Equalized Value Taxable Value 2026 24000640. 1000 W. Lafayette -0-/exempt -0-/exempt -0-/exempt 14. The values in dispute for the subject property are: Tax Year Parcel/Address True Cash Value Assessed/State Equalized Value Taxable Value 2026 24000640. 1000 W. Lafayette $576,500 $576,500 $576,500 15. The 2026 values imposed on the subject property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reason that the subject property is owned by the State of Michigan and is exempt from property taxes under MCL 211.7. Further, the subject property is used as a public concession and is also not taxable under MCL 211.181(1) pursuant to MCL 211.181(2)(b). Therefore, the subject property is exempt from property taxation under General Property Tax Act. 16. Petitioner requests the reduction of the property's true cash, assessed, state equalized and taxable value to $0/EXEMPT. Petitioner further requests a refund with interest of taxes paid due to the original, incorrect assessment and any other relief this Tribunal deems appropriate. WHEREFORE, Petitioner requests that the Tribunal grant the following relief: A. Reduce the assessed, state equalized and taxable values to $0/EXEMPT and order a refund with interest; and
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4 B. Provide such additional relief to Petitioner as this Tribunal shall deem appropriate. VARNUM, LLP Attorneys for Petitioner Dated: May 26, 2026 By:_/s/ Deborah I. Ondersma ________________ Adam J. Brody (P62035) Deborah I. Ondersma (P55907) Business Address/Telephone: 333 Bridge Street, N.W. P.O. Box 352 Grand Rapids, MI 49501-0352 (616) 336-6000 ajbrody@varnumlaw.com diondersma@varnumlaw.com 29149544.1