2025.05.30 - Petition 2025 - Pacific Holdings (Dembs) - A Hills.pdf

Pacific Holdings LLC, Petitioner Vs. City Of Auburn Hills, Respondent · 25-002034-TT

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60723182.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Pacific Holdings LLC, 

Petitioner, 

v. 

City of Auburn Hills, 

Respondent. 

 

 

 

MTT Docket No. ________ 

Parcel No. 02-14-04-476-014 

 

 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

 

Entire Tribunal Property Tax Petition 

Pacific Holdings LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1. 

Petitioner's principal office address is 27750 Stansbury Blvd., Suite 200, 

Farmington Hills, MI 48334. 

2. 

Petitioner is a party in interest with respect to property taxes on tax parcel number 

02-14-04-476-014 ("Petitioner's Property"). 

3. 

Petitioner’s Property has an address of 1220 Pacific Drive, Auburn Hills, MI 48326. 

4. 

Petitioner’s Property is located in Oakland County, Michigan. 

5. 

Respondent, City of Auburn Hills, assesses and collects property taxes on 

Petitioner's Property.

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60723182.1 

6. 

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

$4,733,490 and assessed Petitioner's Property at $4,787,420, which will result in a state equalized 

value in the same amount based on the tentative equalization factor. 

7. 

Petitioner's Property is classified as industrial improved. 

8. 

Petitioner's Property is presently used or available for use for industrial purposes. 

9. 

Petitioner believes that Petitioner's Property was originally designed to be used for 

industrial purposes. 

10. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

11. 

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any losses under MCL 211.27a(2)(a). 

12. 

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any additions under MCL 211.27a(2)(a). 

13. 

A board of review protest was not required for Petitioner’s Property. 

14. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected on Petitioner’s Property, are 

invalid and unlawful for the following reasons: 

(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;

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60723182.1 

(c) 

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

based on an erroneous determination of the true cash value of that portion 

of Petitioner's Property that is taxable under Michigan law, and is based on 

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 taxable value of Petitioner's Property from $4,733,490 to $203,090; (ii) reducing the 2025 

assessed and state equalized value of Petitioner's Property from $4,787,420 to $203,090; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

 

 

 

 

 

 

 

 

 

Dated: May 30, 2025 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

By: _______________________________________ 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

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