Petition 2025 (per Sever Order) Partridge Creek Clinton Twp. (25-002498).pdf

Partridge Creek Senior Living LLC, Petitioner Vs. Township Of Clinton, Respondent · 25-002498-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Partridge Creek Senior Living, L.L.C., 

Petitioner, 

v. 

Clinton Twp., 

Respondent. 

MTT Docket No. 25-002498 

Parcel No. 16-11-05-100-060 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Rd., Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Petition 

Partridge Creek Senior Living, L.L.C. (“Petitioner”), through its attorneys, HONIGMAN 

LLP, says: 

1. 

Petitioner is filing this Petition for the 2025 tax year, pursuant to the Tribunal’s 

June 25, 2025 Order entered in MTT Docket No. 24-001683. Petitioner's principal office address 

is 38525 Woodward Avenue, Bloomfield Hills, MI 48304. Petitioner is a party in interest with 

respect to property taxes on tax parcel number 16-11-05-100-060 ("Petitioner's Property"), also 

known as Partridge Creek Senior Living at 44003 Partridge Creek Blvd. located in Macomb 

County, Michigan.

61094611.2 

2. 

Respondent, Clinton Twp., assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$13,224,100 and assessed Petitioner's Property at $13,224,100, which has resulted in a state 

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

4. 

Petitioner's Property is classified as commercial real. 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, (c) 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 March 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 assessment, including state equalized value and/or taxable value, 

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

(b) 

The 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;

61094611.2 

(c) 

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

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and, 

(d) 

The 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 assessed value, state equalized value and taxable value of Petitioner's Property from 

$13,224,100 to $9,500,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: July 1, 2025 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioners 

By:

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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