NCO Parking LLC.pdf

Nco Parking LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002805-TT

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Honieman LLP 

COSTS ADVANCED ACCOUNT 

I 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

6/2/25 

[ 

99997/997594/SLM 

#45§600,00%+* 

Filing Fee for Petition — NCO Parking 

Parcel 04001536-40 

RECEIVE" 

JUN 04 20. 

MICHIGAN TAX TRIBL 

TranInfo:4606 

 26021217-1 

06/03/25 

Chik: 

040621 

At: $600.00 

ID: 

HONIGHAN LLP 

21074678.1

RECEIVED 

wT 

JUN 09 2025 

™ 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Parking LLC, 

Petitioner, 

MTT Docket No. 

v. 

Parcel No. 04001536-40 

City of Detroit, 

Respondent, 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Petition 

NCO Parking LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1. 

Petitioner's principal office address is 

31700 Middlebelt Rd., Suite 225, Farmington 

Hills, MI 48334. Petitioner is a party in interest with respect to property taxes on tax parcel number 

04001536-40 ("Petitioner's Property"), with an address of 2943 W. Grand Blvd., Detroit, located 

in Wayne County, Michigan. 

2; 

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

Property.

4. 

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: 

(a) valuation, (b) assessment, and (c) 

uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

The 2025 assessment imposed on Petitioner's Property is invalid and unlawful for 

the reasons that: 

(a) 

The assessment, including state equalized value, exceeds the amount 

permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, is at a higher percentage 

of true cash value than permissible under the Michigan Constitution and applicable statutes; 

(©) 

The assessment, including 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 

assessment, 

including 

state 

equalized 

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 and state equalized value of Petitioner's Property from $11,859,400 to

Dated: June 2, 2025 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L, Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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