02017105.pdf
Gnt Holdings LLC And Tlf Holdings LLC, Petitioner Vs. City Of Detroit, Respondent · 25-003265-TT
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Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL GNT HOLDINGS, LLC; and TLF HOLDINGS, LLC, Docket No. 25- Petitioners, Parcel No. 23031300.14N v. CITY OF DETROIT, Respondent. Jason C. Long (P59244) WILLIAM WILLIAMS RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Petition Under MCL 211.53a Petitioners GNT Holdings, LLC, and TLF Holdings, LLC, by and through their attorneys, Williams Williams Rattner & Plunkett, PC, state as follows for their Petition Under MCL 211.53a. The Parties 1. Petitioner GNT Holdings, LLC, is a Michigan limited liability company with its registered offices located at 51410 Milano Drive, Suite 115, Macomb, Michigan 48042.
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Page 2 2. Petitioner TLF Holdings, LLC, is a Michigan limited liability company with its registered offices located at 51410 Milano Drive, Suite 115, Macomb, Michigan 48042. 3. Respondent City of Detroit is a Michigan municipal corporation with its offices located at 2 Woodward Ave., Detroit, Michigan 48226. The Subject Property 4. Petitioners are parties in interest in property identified as tax parcel number 23031300.14N, which is commonly known as 139 Cadillac Square, Detroit, Michigan 48226. 5. The Subject Property is used for, and to Petitioner’s knowledge was designed to be used for, mixed use purposes. 6. The Subject Property is located in Wayne County and is within the Detroit Community Schools public school district. 7. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2022 Tax Bill 8. During 2022, Respondent issued a bill for the summer taxes for the Subject Property. A copy of the bill is attached to this Petition as Exhibit A (the “2022 Tax Bill”). 9. The 2022 Tax Bill identified the Subject Property’s taxable value in the amount of $2,317,100. See Exhibit A.
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Page 3 10. The 2022 Tax Bill identified the total amount of tax and attendant charges due as $54,026.85, which amount was calculated based on the identified taxable value of $2,317,100. See Exhibit A. 11. The 2022 Tax Bill was directed to Petitioners with directions for Petitioners to pay the amount due as identified on the 2022 Tax Bill. 12. Petitioners paid the amount due as identified on the 2022 Tax Bill, including a partial payment submitted during August 2022 and another partial payment submitted during January 2023, such that the total amount paid equaled $54,026.85. The 2022 Tax Bill Was in Excess of the Correct and Lawful Amount 13. The taxable value for the Subject Property identified on the 2022 Tax Bill was in excess of the correct and lawful amount due. 14. Under the Michigan Constitution, the General Property Tax Act, MCL 211.1 et seq., and other Michigan law, the correct and lawful taxable value for the Subject Property for 2022 did not exceed $1,328,570. This is based on application of the 2022 inflation rate multiplier promulgated under MCL 211.27a, which was 3.3%, to the Subject Property’s correct and lawful 2021 taxable value, which was $1,286,128. See Exhibit B. 15. The 2022 Tax Bill equated the Subject Property’s taxable value to its assessed value, which is a clerical error and-or a mistake of fact.
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Page 4 16. Respondent submitting the 2022 Tax Bill, identifying the Subject Property’s taxable value as equaling $2,317,100, was a clerical error or mistake of fact. 17. Petitioners’ payment under the 2022 Tax Bill was based on a clerical error and-or a mistake of fact, which became mutual when Petitioners submitted their payments based on the 2022 Tax Bill. Petitioners are Entitled to a Refund for Excess Tax Paid Under the 2022 Tax Bill 18. Under the General Property Tax Act, any taxpayer who is assessed and pays taxes in excess of the correct and lawful amount due because of a clerical error or mutual mistake of fact made by the assessing officer and the taxpayer may recover the excess so paid, without interest, if suit is commenced within 3 years from the date of payment, notwithstanding that the payment was not made under protest. See MCL 211.53a. 19. Petitioners were assessed and paid taxes under the 2022 Tax Bill, in excess of the correct and lawful amount due, because the 2022 Tax Bill contained a clerical error and-or a mistake of fact in that the taxable value was incorrectly equated with the assessed value. 20. The correct taxable value for 2022 for the Subject Property would result in taxes and attendant charges due that do not exceed $31,020.38. 21. Petitioners are entitled to a refund of taxes paid under the 2022 Tax Bill in the amount of $23,006.47 and all other applicable relief.
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Page 5 Conclusion and Request for Relief Wherefore, Petitioners respectfully request that this honorable Tribunal enter Judgment awarding Petitioners a refund of the excess tax that they paid due to a clerical error in the 2022 Tax Bill and awarding Petitioners all other relief to which they are entitled under Michigan law. Respectfully Submitted, WILLIAMS WILLIAMS RATTNER & PLUNKETT, PC By: /s/ Jason C. Long Jason C. Long (P59244) Dated: August 27, 2025 Attorneys for Petitioner
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Exhibit A
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12 Property Address: 139 CADILLAC SQ ‘X, TAX AMOUNT RATE TAXING UNITS IMPORTANT INFORMATION - SEE REVERSE SIDE 23031300.14N PARCEL# Z100 (TID 1-0) DDA 23.0430 Total Summer Rate Summer Payment Options 53,392.93 Summer Taxes 100.00 533.92 Option #2 - Full Summer balance due on or before 8/31/2022 PREV. PAYMENTS Total Due 54,026.85 J jS 2022 SUMMER PROPERTY TAX - RETURN LOWER PORTION WITH YOUR REMITTANCE D 07/27/2022 0D00E02201000331I130000E3031300114N0031000S4Q2ba55 12 Property Address: 139 CADILLAC SQ DISCOVER V/SA 1st Half Payment Due 8/15/2022 2nd Half Payment Due 1/15/2023 Summer Special Fees Summer Admin Fee 27,013.43 27,013.42 Note: Payments must be received by the due date to be considered timely! GNT HOLDINGS LLC 405 LEXINGTON AVE 17TH FLOOR NEW YORK NY 10174 Pay using the DIVDAT mobile app. Visit your app store to download for free. Full Payment - August 31, 2022 1st Half Payment - August 15, 2022 STATE EDUCATION SCHOOL OPERATING INSPECTION FEE 2022 CITY OF DETROIT SUMMER TAX BILL 2022 CITY OF DETROIT SUMMER TAX BILL 6.0000 17.0430 13,902.60 39,490.33 100.00 GNT HOLDINGS LLC 405 LEXINGTON AVE 17TH FLOOR NEW YORK NY 10174 PARCEL # TOTAL DUE 07/27/2022 TAX PAID DUE DATE 290301 DETROIT PUBLIC SCHOOLS 2,317,100 2,317,100 .0000 911-COMM OPRA REHAB 23031300.14N 54,026.85 MAIL PAYMENT TO: CITY OF DETROIT - PROPERTY TAX PO BOX 33193 DETROIT Ml 48232-3193 MAIL PAYMENT TO: CITY OF DETROIT - PROPERTY TAX PO BOX 33193 DETROIT Ml 48232-3193 Bill No. School District SEV Taxable Value . PRE/MBT% Prop Class TIF Dist PARTIAL PROPERTY DESCRIPTION FOR COMPLETE PROPERTY DESCRIPTION, SEE ASSESSMENT ROLL AT ASSESSOR'S OFFICE N CADILLAC SQUARE E 40 FT 37 PLAT OF SEC 6 GOVERNOR & JUDGES PLAN L34 PS45 DEEDS, W C R 1/5 40 X 100 OPRA CERT # 3-13-0014 EFFECTIVE 12/31/2013 - 12/30/2024. 1/2 RATE EFFECTIVE TO 12/30/2018. Option #1 - 1st Half Summer installment due on or before 8/15/2022 and 2nd Half Summer installment due on or before 1/15/2023 k— CITY OF DETROIT L—-. CITY OF ——I DETROIT
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Exhibit B
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Print Tax Bill | City of Detroit | BS&A Online 8/10/2021 Parcel: 23031300.14N Property Address Owner and Taxpayer Information SEE OWNER INFORMATION Owner Legal Description Installment Information for 2021 Summer Amount $14,896.08 First Payment $14,896.07 Second Payment General Information for 2021 Summer Taxes ILF Acct. #: Not Available Mortgage Code Not Available Renaissance Zone Tax Bill Breakdown for 2021 Summer Amount Paid Amount Millage Rate Taxing Authority $0.00 $7,716.76 6.000000 STATE EDUCATION $0.00 $21,681.41 16.857900 SCHOOL OPERATING $0.00 $100.00 0.000000 INSPECTION FEE $0.00 $293.98 Admin Fees $0.00 $0.00 Interest Fees $0.00 $29,792.15 22.857900 Copyright © 2021 BS&A Software, Inc https://bsaonline.com/Tax_SiteSearch/PrintTaxBill?SearchFocus=Tax&SearchCategory=Address&SearchText=139 cadillac&uid=155&Pagelndex=1&R.. 1/1 Tax Bill Number Last Payment Date School District Taxable Value Property Class Base Tax Admin Fees Interest Fees Total Tax & Fees Base Paid Admin Fees Paid Interest Fees Paid Total Paid Last Receipt Number Number of Payments 139 CADILLAC SQ DETROIT, Ml 48226 $29,498.17 S293.98 S0.00 S29.792.15 0.0000% $1,584,000 $1,584,000 S0.00 $0.00 $0.00 $0.00 286106 No Data to Display No Data to Display 0 | Prop I. Code I Acct. #: | Control #: N CADILLAC SQUARE E 40 FT 37 PLAT OF SEC 6 GOVERNOR & JUDGES PLAN L34 P545 DEEDS, W C R 1/5 40 X 100 0PRA CERT # 3-13-0014 EFFECTIVE 12/31/2013 - 12/30/2024 1/2 RATE EFFECTIVE TO 12/30/2018. 82010 PRE/MBT $1,286,128 S.E.V. 911 - 91 1 -COMM OPRA REHAB Assessed Value •'Disclaimer: BS&A Software provides BS&A Online as a way foi municipalities to display information online and is not responsible for the content or accuracy of the data herein This data is provided foi reference only and WITHOUT WARRANTY of any kind, expressed or inferred Please contact your local municipality if you believe there are errors in the data GNT HOLDINGS LLC Taxpayer 139 CADILLAC SQUARE STE 301 DETROIT, Ml 48226-4800