25-002276.pdf
Target Corporation, Petitioner Vs. Township Of Clinton, Respondent · 25-002276-TT
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RECEIVED MAY 142026 x: Wo STATE OF MICHIGAN MICHIGAN Tax TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Target Corporation, Petitioner, V. MTT Docket No. 25-002276 Clinton Twp. - Macomb, Respondent. / Daniel L. Stanley (P57052) Laura M. Hallahan (P42101) Jackie J. Cook (P68781) Seth A. O’Loughlin (P80257) Honigman LLP Hallahan & Associates, P.C. Attorneys for Petitioner Attorneys for Respondent 222 N. Washington Square 1750 S. Telegraph Rd., Suite 202 Suite 400 Bloomfield Hills, MI 48302 Lansing, MI 48933 (248) 731-3089 (517) 377-0714 lhallahan@hallahanlaw.com (313) 465-7270 soloughlin@hallahanlaw.com dstanley@honigman.com jcook@honigman.com Motion to Amend Petition to Contest 2026 Assessed and Taxable Values Petitioner, Target Corporation, through its attorneys, Honigman LLP, moves to amend the Petition in this matter to include the following: I. In 2026, Respondent determined the taxable value of Petitioner’s Property to be $3,372,628 and Respondent assessed Petitioner’s Property at $5,545,100,which will result in a state equalized value of the same amount, based upon the tentative equalization factor. 2. The 2026 assessment, including state equalized value and taxable value,
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(a) The assessment, including state equalized value and/or taxable value, exceeds the amounts 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 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/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 moves that this Motion be granted, and Petitioner requests that the Tribunal enter an Order: (i) reducing the 2026 assessed and state equalized value from $5,545,100 to $2,127,000; (ii) reducing the 2026 taxable value from $3,372,628 to $2,127,000; (iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iv) awarding Petitioner any other relief to which it is entitled.
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Dated: 5/14/26 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: /s/ Daniel L. Stanley Daniel L. Stanley (P57052) Attorneys for Petitioner 222 N. Washington Square Suite 400 Lansing, MI 48933 (517) 377-0714 (313) 465-7270 dstanley@honigman.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, Vv. MTT Docket No. 25-002276 CLINTON TWP. - MACOMB, Respondent. / Proof of Service Lisa Joseph affirms that on 5/14/26 she served a copy of Petitioner's Motion to Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service in connection with the above-entitled cause upon the following: Laura Hallahan Attorneys for Respondent lhallahan@hallahanlaw.com via electronic mail. Dated: 5/14/26 /s/ Lisa Joseph Lisa Joseph
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Honigman LLP COSTS ADVANCED ACCOUNT Nn A A748 RECFTVED MAY 14 026 Re 0 Ye MICHIGAN TAX TRIBUNAL Invoice Date Invoice Number Invoice Narrative Payment Amount 5/14/26 040716 DLS/203729/43036 300.00 Motion to Amend 25-002276 24559387.1