Petition 2025 - Auto Owners Delta Twp. (6200 Anacapri).pdf
Auto-Owners Life Insurance Company, Auto-Owners Insurance Company, Petitioners Vs. Township Of Delta, Respondent · 25-002139-TT
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Page 1
25-0029
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
Auto-Owners Life Insurance Company and
Auto-Owners Insurance Company,
Petitioners,
v.
Delta Township,
Respondent.
MTT Docket No. ________
Parcel No. 23-040-080-000-285-00
Stewart L. Mandell (P33781)
Daniel L. Stanley (P57052)
Honigman LLP
Attorneys for Petitioners
39400 Woodward Avenue, Suite 101
Bloomfield Hills, MI 48304-5151
(313) 465-7420
slmandell@honigman.com
dlstanley@honigman.com
Petition
Auto-Owners Life Insurance Company and Auto-Owners Insurance Company
(collectively, “Petitioners”), through their attorneys, Honigman LLP, says:
1.
Petitioners principal office address is 6101 Annacapri Blvd., Lansing, MI 48909.
Each Petitioner is a party in interest with respect to property taxes on tax parcel number 23-040-
080-000-285-00 ("Petitioners’ Property"), with an address of 6200 Annacapri, Delta Township,
located in Eaton County, Michigan.
2.
Respondent, Delta Twp., assesses and collects property taxes on Petitioners’
Property.Page 2
2 60722488.1 3. In 2025, Respondent determined the taxable value of Petitioners’ Property to be $5,622,200 and assessed Petitioners’ Property at $5,622,200, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 4. Petitioners’ Property is classified as commercial improved. Petitioners’ Property is presently used or available for use for commercial purposes. Petitioners believe that Petitioners’ Property was originally designed to be used for commercial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) due process, equal protection, and uniformity. 6. At this time, Petitioners believe, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. No board of review protest was required for Petitioners’ Property. 8. The 2025 assessment, including state equalized value and taxable value, imposed on Petitioners’ Property, and the taxes to be levied and collected thereon, are invalid and unlawful for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 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 assessment, including taxable value and/or state equalized value, is based upon an erroneous determination of the true cash value of that portion of Petitioners' Property that is taxable under Michigan law, and is based upon the application of wrong principles; and
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3 60722488.1 (d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioners and deny Petitioners their constitutional rights to uniformity, equal protection, and due process of law. WHEREFORE, Petitioners request that the Tax Tribunal enter an Order: (i) reducing the 2025 assessed value, state equalized value, and taxable value of Petitioners’ Property from $5,622,200 to $2,659,000; (ii) requiring payment to Petitioners of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioners any other relief to which they are entitled. Dated: May 31, 2025 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioners By: Stewart L. Mandell (P33781) Daniel L. Stanley (P57052) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7420 slmandell@honigman.com dlstanley@honigman.com