Petition Southeast Group Millender Detroit July 28 2025.pdf

Southeast Group LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002897-TT

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25-0053

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Southeast Group LLC,

Petitioner,

v.

City of Detroit,

Respondent,

MTT Docket No. ________

Parcel Nos. 01003901.002,

01003901.003, 01003913.,

01003914., 01003915., and

01003916.

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

jcook@honigman.com

Petition

Southeast Group LLC (“Petitioner”), through its attorneys, Honigman LLP, says:

1.

Petitioner's principal office is 630 Woodward Avenue, Detroit, MI 48226.

2.

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

01003901.002, 01003901.003, 01003913., 01003914., 01003915., and 01003916. (collectively,

"Petitioner's Property"), with addresses that include 333 E. Jefferson Ave. and 460 Randolph,

Detroit, located in Wayne County, Michigan.

3.

Petitioner’s Property is commonly known as being part of the Millender Center,

including the Millender Center parking deck. The tax parcels comprising Petitioner’s Property are

contiguous. Petitioner’s Property includes over 1,700 parking spots.

2

61478223.5

4.

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

Property.

5.

The values in the chart below show the 2025 assessed value, state equalized value

and taxable value of Petitioner’s Property, which values are the result of Respondent’s actions.

Also included in the chart are Petitioner’s contended and requested values for 2025.

6.

Petitioner’s Property is classified as commercial real.

7.

Petitioner’s Property is presently used or available for use for commercial purposes.

8.

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

commercial purposes.

9.

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

value, (d) due process and equal protection under the Constitutions of the United States and the

State of Michigan, (e) the assessment notice requirements of the General Property Tax Act, and

(f) uniformity.

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute

relative to the value of a loss.

11.

No board of review protest was required for Petitioner’s Property.

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61478223.5

12.

During 2024, Petitioner, i) acquired Petitioner’s Property, and ii) Petitioner filed

a property transfer affidavit, which advised Respondent of the transfer, the property’s

purchase price of approximately $32,901,540, and Petitioner’s address.

13.

Petitioner has never received any notices of assessment for Petitioner’s Property.

14.

After July 1, 2025, was the first time that Petitioner became aware of the 2025

assessments for Petitioner’s Property.

15.

Throughout this year, and even after July 1, 2025, Respondent’s records for

Petitioner’s Property had an incorrect address for mailing notices to Petitioner.

16.

Petitioner was not sent and did not receive lawful notice of the 2025 assessments

for Petitioner’s Property. Therefore, in this case Petitioner is entitled to a determination of the

lawful values of Petitioner’s Property, and the Tribunal has jurisdiction to decide this case.

17.

Each 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)

Each 2025 assessment, including state equalized value and/or taxable value,

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

(b)

Each 2025 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;

(c)

Each 2025 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,

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61478223.5

(d)

Each 2025 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 each 2025 assessed value, state equalized value, and taxable value of Petitioner’s

Property as shown in the table in paragraph five above; (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 28, 2025

Respectfully submitted,

HONIGMAN LLP

Attorneys for Petitioner

By:

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

jcook@honigman.com

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