Petition 2025 - Midtown Hotel Group Detroit.pdf

Midtown Hotel Group, LLC, Petitioner Vs. City Of Detroit, Respondent · 25-003116-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Midtown Hotel Group, LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. 

Parcel No. 01004205.001 

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 

Petitioner Midtown Hotel Group, LLC (“Petitioner”), through its attorneys, Honigman 

LLP, says: 

1.

Petitioner's principal office address is 31100 Stephenson Highway, Madison 

Heights, MI 48071. 

2.

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

01004205.001 ("Petitioner's Property"). Petitioner’s Property has an address of 4 E. Alexandrine 

Street, Detroit, MI, located in Wayne County, Michigan. 

3.

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

Property.

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4.

For the 2025 tax year, Respondent’s March Board of Review set the assessed value 

and taxable value of Petitioner’s Property at $2,799,500, and that has resulted in a state equalized 

value of $2,799,500. 

5.

Petitioner’s Property is classified as commercial real. 

6.

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

7.

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

commercial purposes. 

8.

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. 

9.

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

relative to the value of a loss. 

10.

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

11.

After July 6, 2025, was the first time that Respondent provided, and Petitioner 

received, a proper and correct notice of the 2025 taxation of Petitioner’s Property. 

12.

Under the due process and equal protection guarantees of the Constitution of the 

United States, the Michigan Constitution, and precedent that includes and is not limited to 

Parkview Mem Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (1990) and Michigan 

State University v City of Lansing, unpublished opinion per curiam of the Court of Appeals, issued 

February 15, 2005 (Docket No. 250813), the Tribunal has jurisdiction over this case. 

13.

In Michigan State University v City of Lansing, unpublished opinion per curiam of 

the Court of Appeals, issued February 15, 2005 (Docket No. 250813), the taxpayer was entitled to

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pursue its Tribunal appeal where it filed its Tribunal Petition within thirty-five days of receiving 

its summer tax bill in July because that was the first notice it received of the assessment. Here, 

Petitioner also is filing this Petition within thirty-five days of receiving its summer tax bill and 

notice of the property’s taxation, and therefore Petitioner is entitled to pursue this appeal. 

14.

The 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) 

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

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

(b) 

The 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) 

The 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, 

(d) 

The 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 the 2025 assessed value, state equalized value, and taxable value of Petitioner’s 

Property from $2,799,500 to $1,000,000; (ii) requiring payment to Petitioner of the refunds

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attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief 

to which it is entitled. 

Dated: August 7, 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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