Full record / Petition 2025 - Auto Owners Delta Twp. (6200 Anacapri).pdf

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.

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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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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

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