26-000133 abey.pdf

Denso International America Inc Petitioner Vs. City Of Southfield Respondent · 26-000133-TT

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STATE OF MICHIGAN 

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

Denso International America Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000133 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER DENYING PETITIONER’S MOTION TO HOLD CASE IN ABEYANCE 

 

ORDER OF DISMISSAL 

 

On June 30, 2026, Petitioner filed a motion requesting that the Tribunal hold this case in 

abeyance pending resolution of Docket No. 25-003802 and 26-000133, which are 

currently pending before the Tribunal.1 In the motion, Petitioner states that the parties 

and property at issue in the cases are the same, and resolution of Docket No. 25-

003802 and 26-000133 will most likely help resolve this case. 

 

On July 21, 2025, Respondent filed a response to the motion. In the response, 

Respondent states that this appeal pertains to alleged arithmetic errors or mistakes in 

the 2024 and 2025 tax bills and Petitioner failed to state or provide any explanation as 

to how a Final Opinion and Judgment in Docket no. 25-003802, which involves a State 

Tax Commission (STC) determination of omitted property for the 2020-2022 tax years, 

will resolve this case. 

 

The Tribunal has considered the motion, the response, and the case file and finds that 

the petition filed in this case states that “this appeal is limited solely to correcting 

arithmetic errors or mistakes in the Contested Tax Bills and is not a valuation appeal,” 

but goes on to state that “the Contested Tax Bills indicate mistaken calculations of 

taxable value for the subject property of $14,442,223 for 2024 and $14,889,932 for 

2025.” Thus, despite Petitioner’s attempt to frame the issue in this case as an appeal of 

a contested tax bill, it is evident that it is actually disputing Respondent’s taxable value 

(TV) calculation for the 2024 and 2025 tax year, which is plainly a valuation issue. 

 

MCL 205.735a(6) specifically states that “an appeal of a contested tax bill . . . is limited 

solely to correcting arithmetic errors or mistakes and is not a basis of appeal as to 

disputes of valuation of the property, the property's exempt status, or the property's 

equalized value resulting from equalization of its assessment by the county board of 

 

1 Petitioner erroneously references the instant docket in paragraphs 5 through 8 and 10 of its motion, and 

appears to be referring to Docket No. 26-000958, which is a pending valuation appeal for the subject 

property for the 2026 tax year.

MTT Docket No. 26-000133 

Page 2 of 3 

 

commissioners or the state tax commission.”2 Further, the documentation submitted 

with the petition, which includes correspondence from the Oakland County Treasurer 

dated December 19, 2025, indicates that the revised values are not the result of an 

“arithmetic error or mistake.” Rather, the December Board of Review changed the 

property’s values on December 9, 2025, which change resulted in issuance of the 

revised tax bills in dispute. The change is likely the result of the State Tax Commission 

Order referenced in Docket No. 25-003802, as per that order, the property’s 2022 TV 

was increased to $13,099,522, which would result in revised TVs as follows: 

$13,754,488 for 2023, $14,442,212 for 2024, and $14,889,920 for 2025. 

 

Though the TVs listed in the tax bills for 2024 and 2025 differ slightly from those 

calculated by the Tribunal for purposes of this order, Petitioner cannot collaterally attack 

the December BOR decision by way of a contested tax bill appeal. An appeal of the 

December BOR decision would have had to have been filed with the Tribunal no later 

than January 13, 2026, and this appeal was not filed until January 21, 2026.3 

Importantly, any redetermination of TV in Docket No. 25-003802 will necessarily result 

in recalculation of the property’s TV for both the 2024 and 2025 tax years.4 Therefore, 

 

IT IS ORDERED that Petitioner’s Motion to Hold Case in Abeyance is DENIED. 

 

IT IS FURTHER ORDERED that the case is DISMISSED. 

 

This order resolves all pending claims in this matter and closes this case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal. 

 

2 Id. (emphasis added). 

3 See MCL 205.735a(6). 

4 See STC Bulletin 18 of 2017.

MTT Docket No. 26-000133 

Page 3 of 3 

 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

 

 

Entered: August 6, 2026 

 

 

 

 

By: /s/ Patricia L. Halm 

ejg/am 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

 

By: Tribunal Clerk

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