NCO Acquisition LLC.pdf

Nco Acquisition LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002808-TT

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MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Acquisition LLC, 

Petitioner, 

MTT Docket No. 

Vv. 

Parcel No. 02001098-101 

City of Detroit, 

Respondent, 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

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sity 

pnrate 

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39400 Woodward Avenue, Suite 101 

Traninfo:4606 

2021219 1 

06/03/25 

. 

Chkit: 

040625 

Amt: $400.00 

Bloomfield Hills, MI 48304-5151 

10: 

HONTGHAN LLP 

(313) 465-7420 

slmandell@honigman.com 

Petition 

NCO Acquisition LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

15 

Petitioner's principal office address is 31700 Middlebelt Rd., Suite 225, Farmington 

Hills, MI 48334. Petitioner is a party in interest with respect to property taxes on tax parcel number 

02001098-101 ("Petitioner's Property"), with an address of 3031 W. Grand Blvd., Detroit, located 

in Wayne County, Michigan. 

2: 

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's

4. 

Petitioner's Property is classified as commercial improved. 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, and (c) 

uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

The 2025 assessment imposed on Petitioner's Property is invalid and unlawful for 

the reasons that: 

(a) 

The assessment, 

including 

state equalized 

value, exceeds 

the amount 

permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, is at a higher percentage 

of true cash value than permissible under the Michigan Constitution and applicable statutes; 

(c) 

The assessment, including 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 

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 and state equalized value of Petitioner's Property from $17,440,400 

to

Dated: June 2, 2025 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Honiaman LLP 

COSTS ADVANCED ACCOUNT 

Invoice Date 

Invoice Number 

Invoice Narrative 

6/2/25 

|] 

24254/16864/SLM 

21074678.1 

Filing Fee for Petition for Parcel 

02001098-101 

— 

Payment Amount

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