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G4 Detroit Holdings LLC.pdf

G4 Detroit Holdings, LLC Petitioner Vs. City Of Detroit Respondent · 26-002647-TT

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Page 1

RECEIVED 

MAY 15 2006 00” 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

G4 Detroit Holdings, LLC, 

Petitioner, 

MTT Docket No. 

Ve 

Parcel Nos. 01000122. and 

City of Detroit, 

01000123-4 

Respondent. 

Stewart L. Mandell (P33781) 

Honigman LLP 

Traninfo: 460k 

Attorneys for Petitioner 

Chit: 

040718 

A 

2290 First National Building 

ID: 

HONIGHAN LLP 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

Petition 

G4 Detroit Holdings, LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

L 

Petitioner's principal office address is 37 Willow Lane, Grosse Pointe Farms, MI 

48236. 

2% 

Petitioner is a party in interest with respect to property taxes on two contiguous tax 

parcels with parcel numbers 01000122. and 01000123-4 (collectively, "Petitioner's Property"). 

Petitioner’s Property has addresses that include 440 E. Congress, Detroit, MI and the property is 

56

Page 2

4. 

In 2026, Respondent’s March Board of Review set the taxable value and assessed 

value of Petitioner's Property as shown in the chart below: 

Respondent's Board of 

Petitioner's 

Review 2026 values 

contended 2026 values 

Parcel No. 

| Assessed 

Taxable 

Assessed 

Taxable 

01000122. 

| $1,836,900 

$878,368 

$700,000 

$700,000 

01000123-4 

$756,600 

$756,600 

$300,000 

$300,000 

TOTALS 

$2,593,500 | $1,634,968 | $1,000,000 | $1,000,000 

5. 

Each above assessed value will result in a state equalized value in the same amount 

based upon the tentative equalization factor. 

6. 

Petitioner's Property 

is classified as commercial real. 

Petitioner's Property 

is 

presently used or available for use for commercial purposes. 

7 

This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable 

value, and (d) due process, equal protection, and uniformity. 

8. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

9. 

March Board of Review protests for Petitioner’s Property were not required, but 

were filed in March, 2026. 

10. 

Each 2026 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the following reasons:

Page 3

(b) 

Each 2026 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) 

Each 2026 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) 

Each 2026 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 requests that the Tax Tribunal enter an Order: (i) reducing the 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property to the values 

contended per the table in paragraph four above; (ii) requiring payment to Petitioner of the refunds 

attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief 

to which it is entitled. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: 

Stewart L. Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506

Page 4

FONIGMAN LLP 

COSTS ADVANCED ACCOUNT 

040718 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

5/15/26 

040718 

272093/492530/JJCO 

#HEG625,00%H* 

Petition Filing Fee 

21074678.1

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