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Petition - POS.pdf

Woodward Brown Ventures LLC Petitioner Vs. City Of Birmingham Respondent · 26-001315-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Woodward Brown Ventures LLC 

 

Petitioner, 

 

vs. 

 

City of Birmingham, 

Respondent.

 

 

 

MTT Docket No. 26-001315 

 

_____________________________________________________________________________/ 

 

 

PROOF OF SERVICE 

(Property Tax Petition) 

 

On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: 

 

City Assessor 

City of Birmingham 

151 Martin Street 

P.O. Box 3001 

Birmingham, MI 48012

City Clerk 

City of Birmingham 

151 Martin Street 

P.O. Box 3001 

Birmingham, MI 48012

 

On the date below I sent by first class mail a copy of the Petition to: 

 

Equalization Director 

Oakland County 

250 Elizabeth Lake Road, Suite 1000W 

Pontiac, MI 48341 

County Clerk 

Oakland County 

1200 N. Telegraph Rd, Bldg 12E 

Pontiac, MI 48341 

Secretary, Board of Education 

Birmingham Public Schools 

31301 Evergreen Rd 

Beverly Hills, MI 48025

State Treasurer 

Department of Treasury 

430 W. Allegan Street 

Lansing, MI 48922

 

I declare that the statements above are true to the best of my information, knowledge and belief. 

 

 

 

/s/ Laura M. Hallahan 

 

Dated: September 17, 2026

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

Woodward Brown Ventures LLC, 

 

Petitioner, 

v 

City of Birmingham, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-001315_______ 

Parcel No. 08-19-36-202-019 

_____________________________________________________________________________/ 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1.

☒ The property that is the subject of this appeal is one real property parcel:

Parcel Number 

08-19-36-202-019

Address 

298 S. Old Woodward 

Classification 

201 COMM IMP 

Use 

Hotel 

County 

Oakland 

Sch Dist Birmingham 

2.

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s:

☐March, ☐ July, ☐ December Board of Review.

3.

Respondent, identified above, assesses and collects taxes on the subject property.

4.

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject

property.

5.

The Petitioner’s principal office/legal residence address is: 390 Park Street, Suite 201,

Birmingham, MI 48009-3400.

6.

This appeal involves issues related to:

☒

the subject property’s true cash and taxable values

☐

the subject property’s taxable value only

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No

☐

uniformity of the subject property’s assessment

☐

the subject property’s exemption from ad valorem taxation under MCL ______

7.

The tax year at issue is 2026.

Page 3

Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

08-19-36-202-019 

31,051,540 

15,525,770 

14,121,250 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

08-19-36-202-019 

24,000,000 

12,000,000 

12,000,000 

10. 

The values1 in dispute are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

08-19-36-202-019 

7,051,540 

3,525,770 

2,121,250 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioner’s property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

and 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

constitutional rights of uniformity, equal protection and due process of law. 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 4

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 23, 2026 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

Filing Fee: $600

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