Chelsea Clocktower Building LLC.pdf
Chelsea Clocktower Building LLC, Petitioner Vs. City Of Chelsea, Respondent · 25-002844-TT
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Page 1
RECEWEP
RECEIVED
A 2009
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JN 092055
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STATE OF MICHIG AREAIGAN
MICHIGAN TAX TRIBUNAL
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS,
MICHIGAN TAX TRIBUNAL
Chelsea Clocktower Building LLC,
Petitioner,
Vv.
MTT Docket No.
Parcel No. 06-06-12-111-001
City of Chelsea,
Respondent.
Stewart L. Mandell (P33781)
Daniel L. Stanley (P57052)
Honigman LLP
Attorneys for Petitioner
39400 Woodward Avenue, Suite 101
TranInfo:6606
26021220-1
06/03/25
Bloomfield Hills, MI 48304-5151
Chki=
040627
Amt: $600.00
(313) 465-7420
ID:
HONIGMAN LLP
slmandell@honigman.com
Petition
Chelsea Clocktower Building LLC (“Petitioner”), through its attorneys, Honigman LLP,
says:
1.
Petitioner's principal office address is 320 N. Main St., Suite 200, Ann Arbor, MI
48104. Petitioner is a party in interest with respect to property taxes on tax parcel number 06-06-
12-111-001 ("Petitioner's Property"), with an address of 310 N. Main St., located in Washtenaw
County, Michigan.Page 2
3. In 2025, Respondent determined the taxable value of Petitioner's Property to be $1,299,000 and assessed Petitioner's Property at $1,299,000, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 4. Petitioner's Property is classified as commercial. Petitioner's Property is presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 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) uniformity. 6. At this time, Petitioner believes, 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 Petitioner’s Property. 8. The 2025 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 reasons that: (a) The 2025 assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 2025 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 2025 assessment, including taxable value and/or state equalized value,
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(d) The 2025 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 2025 taxable value of Petitioner's Property from $1,299,000 to $650,000; (ii) reducing the 2025 assessed value and state equalized value of Petitioner's Property from $1,299,000 to $650,000; (iii) requiring payment to Petitioner of the refunds attributable to the foregoing relief, plus interest and costs; and (iv) awarding Petitioner any other relief to which it is entitled. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner Stewart L. Mandell (P33781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, Michigan 48304-5151 (313) 465-7420 simandell@honigman.com Dated: June 2, 2025
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Hontgman LLP COSTS ADVANCED ACCOUNT Invoice Date Invoice Number Invoice Narrative 6/2/25 BB 99997/997594/SLM 21074678.1 Filing Fee for Petition for Chelsea Clocktower Parcel 06-06-12-1111-001 Payment Amount