Full record / motion for recon 25-002995 12-3-2025.pdf

motion for recon 25-002995 12-3-2025.pdf

Half Moon Road Holdings Inc., Petitioner V City Of Detroit, Respondent · 25-002995-TT

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Page 1

RECEIVED 

DEC 08 2025 

MICHIGAN TAX TRIBUNAL 

David E. Nykanen 

Direct: (248) 406-6089 

December 2, 2025 

Via Overnight Courier 

Samantha M. Welton, Chief Clerk 

Michigan Tax Tribunal 

611 W. Ottawa, 2 Floor 

P.O. Box 30232 

Lansing, MI 48913 

Re: Half Moon Road Holdings Inc. v City of Detroit, MTT Docket 25-002996 

Dear Ms. Welton: 

Enclosed please find the following documents for filing in the above-referenced matter: (i) 

Motion and Incorporated Brief for Reconsideration of Order of Dismissal; (ii) a check for the 

filing fee; and (iii) Proof of Service. 

Thank you for your attention to these matters. Should you have any questions or issues which 

would preclude the immediate filing of these documents, please call. 

Sincerely, 

i 

David E. Nykanen 

dnykanen@fnrplc.com

Page 2

4. 

On October 8, 2025, Petitioner filed a response to the Order of Default. See 

Exhibit A. 

5. 

In that response, Petitioner provided evidence that it timely appeared before 

the Board of Review. However, the Board of Review refused to issue any notice of action 

taken. 

6. 

Notwithstanding Petitioner's timely appearance before the Board of Review, 

the Tribunal dismissed this matter pursuant to an Order dated November 12, 2025. 

7. 

In that Order, the Tribunal claimed that “Petitioner failed to protest the 

assessment to Respondent's March Board of Review, as required by MCL 205.735a". 

See Exhibit B. 

8. 

That statement 

is factually incorrect, and constitutes palpable and legal 

error, requiring the Tribunal to set aside its Order of Dismissal and reinstate this matter. 

9. 

The Tribunal has conflated the statutory obligation to appear before the 

Board of Review, which Petitioner did, with the issuance of a Notice of Action by the Board 

of Review, which Respondent failed and refused to issue. 

10. 

In the Notice of Assessment issue by Respondent, which 

is the only 

document provided directly to the taxpayer, the Respondent identifies the dates upon 

which the Board of Review would meet. Those meeting dates commenced on March 10, 

2025, and concluded on March 29, 2025. 

11. 

Petitioner appeared before the Board of Review on March 17, 2025, two

Page 3

Respondent claimed, for the first time, that the deadline for filing before the Board of 

Review was March 10, 2025. 

13. 

This correspondence also claims that the deadline for filing was “specified 

in all public notices”. This is untrue. The only notice provided to the taxpayer is the Notice 

of Assessment, which contains no such deadline. See Exhibit D. 

14. 

Put simply, 

Petitioner appeared 

before the Board 

of Review and has 

satisfied all statutory jurisdictional obligations to pursue this appeal. 

WHEREFORE, Petitioner respectfully requests that this Honorable Tribunal enter 

an Order Setting Aside Order of Dismissal, reinstate this matter, and set it for hearing. 

Respectfully submitted, 

FRIEDLAENDER NYKANEN 

& ROGOWSKI, PLC 

"Dat d 

E/|Nykanen (P47763) 

Dayld 

r Petitioner 

Dated: December 2, 2025

Page 4

EXHIBIT A

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

HALF MOON ROAD HOLDINGS INC., 

Petitioner, 

MTT Docket No. 25-002995 

v. 

CITY OF DETROIT, 

Respondent. 

FRIEDLAENDER NYKANEN & 

ROGOWSKI PLC 

By: David E. Nykanen (47763) 

1700 W. Big Beaver Road 

Suite 220 

Troy, Michigan 48084 

(248) 629-0880 

Attorneys for Petitioner 

CURE OF ORDER 

OF DEFAULT 

Petitioner, HALF MOON ROAD HOLDINGS INC., (“Petitioner”) through 

its 

attorneys, FRIEDLAENDER NYKANEN & ROGOWSKI PLC, 

states 

as 

follows for its cure of the default:

Page 6

2. 

The Notice of Assessment from the City listed numerous available 

Board of Review dates through March 24, 2025. See attached. 

3. 

However, the City takes the position, unsupported by its Notice of 

Assessment, that the deadline was two weeks prior to the last listed Board of 

Review date. Correspondence from the City is attached. 

4. 

Petitioner timely appeared before the Board of Review and the City 

rejected 

its 

appeal. 

The 

correspondence 

from 

the 

City 

serves 

as 

the 

final 

determination of the City and is the basis for this appeal. 

WHEREFORE, Petitioner requests 

a hearing before 

the Michigan Tax 

Tribunal for a determination of the assessed and taxable value for the subject 

properties and reduce the assessed, state equalized and taxable values of the subject 

property and order a refund with interest as provided by Michigan law. 

Respectfully Submitted, 

FRIEDLAENDER NYKANEN & 

ROGOWSKI PLLC 

By: 7) 

DatidA. NyJfanen (P47763)

Page 7

ose 

THIS IS NOT A TAX BILL 

L-4400 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c¢, as amended, This 

is a model assessment notice to be used by the local assessor, 

FROM: 

PARCEL IDENTIFICATION 

OT 

SSESSOR 

PARCEL NUMBER: 27220090. 

E 

Pp 

DDRESS: 17 

3 WOODWARD AVE. SUITE 804 

ROPERTY ADDR 

381 PONTCHARTRAIN 

DETROIT, Mi 48226 

OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL 

PRINCIPAL RESIDENCE EXEMPTION 

1472891005517 11315 

% Exempt As "Homeowners Principal 

0.0000% 

" 

a 

(J 

Pehle 

bo JRO] FEO 

[Uppy HE! 

Residence 

: 

HALF MOGN ROAD HOLDINGS INC 

% Exempt As "Qualified Agricultural Property”: 0.0000% 

113 MILMAY 

AVE 

9% Exempt As "MBT Industrial Personal": 

0.0000% 

Y 

HAUPPAUGE, NY 11788-3324 

% Exempt As "MBT Commercial Personal”: 

0.0000% 

Exempt As "Qualified Forest Property”: 

[1] Yas (XI No 

Exempt As "Development Property”: 

[J Yes XI No 

LEGAL DESCRIPTION: W PONCHARTRAIN S 4.67 FT ON E LINE & RNG TOA PTE IN S W COR 54 55 DETROIT GOLF CLUB 

SUB 130 P99-100 PLATS, W C R 2/135 104.67 IRREG. NEZ HOMESTEAD CERT #NH2008-0812 RELATED PARCEL 

ACCORDING TO MCL 211.34¢ THIS PROPERTY IS CLASSIFIED AS: RESIDENTIAL-IMPROVED 

PRIOR YEAR'S CLASSIFICATION: RESIDENTIAL-IMPROVED 

) 

JE, 

Cr 

PE 

EE 

CURRENT. 

] 

| 

The change in taxable value will increase/decrease 

PRIOR AMOUNT 

TENTATIVE 

CHANGE FROM 

your tax bill for the 2025 year by approximately: 

YEAR: 2024 

AMOUNT YEAR: 

PRIOR YEAR TO 

$543 

‘ 

2025 

‘| 

CURRENT YEAR 

1. TAXABLE VALUE: 

. 

) 

242,891 

250,420 

7,529 

2, ASSESSED VALUE: 

276,100 

262,800 

-13,300 

3. TENTATIVE EQUALIZATION FACTOR: 1.00 

3 

Bl 

] 

’ 

4. STATE EQUALIZED VALUE (SEV): 

276,100 

262,800 

-13,300 

5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: 

WAS NOT 

6. ASSESSOR CHANGE REASON: MARKET VALUE 

7. ESTIMATED TRUE CASH VALUE: 525,552 

8. EFFECTIVE AGE: 33 

9. YEAR BUILT: 1922 

The 2025 inflation Rate Multiplier is: 1.031 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed 

to the following:

Page 8

Michigan Department of Treasury 

618 (Rev. 11-12) 

Petition to Board of Review 

L-4035 

This form is issued under the authority of P.A, 206 of 1893, as amended. Filing is voluntary, however you may not appeal to the Michigan Tax Tribunal 

or the State Tax Commission unless you first protest to the Board of Review. 

TO BE COMPLETED BY OWNER OR OWNER'S AGENT 

Owner's Name (Please Print or Type) 

Petitioner's Name 

(If Olhier than Owner. Please Print or Type) 

Half Moon Road Holdings Inc 

David E. Nykanen 

Township or City 

County 

Detroit 

Wayne 

The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified 

agricultural property exemption of the following described property: 

Property Identified (Parcel code required. Property address & legal description optional) 

27220090. 

Protested Item 

[x] Assessed Value 

Tentative Taxable Value 

M Classification 

1 Qualified Agricultural 

Property Exemption 

1. PROTEST OF ASSESSMENT 

pery 

P 

(Complete this section for a protest of assessed value and/or tentative taxable value) 

Assessed Amount 

Owner's Estimate of True Cash Value 

Tentative Taxable Value 

Year 

$262,800 

$290,000 

$250,420 

2025 

2. PROTEST OF CLASSIFICATION 

{Complete this section for a request to change the classification. The Board of Review must make their decision regarding classification in 

accordance with Section 211.34¢ of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular 

classification has on that property's status as a homeowner's principal residence or qualified agricultural property.} 

Classification of property on this year's assessment roll 

Classification should be {check one of the following): 

[T] Agriculturat 

[] Industrial 

["] Timber Cutover 

[] utility (Personal Property Only) 

[1 commercial 

["] Residential 

[1 bevelopmental 

3. PROTEST OF EXEMPTION FOR QUALIFIED AGRICULTURAL PROPERTY 

(If the assessor has denied or changed the percentage of the exemption from the 18 mills of local school operating tax for qualified agricultural 

property, the owner may appeal this action to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT 

UPON THE EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.) 

Percent qualified agricultural exemption granted by assessor (Enter 0 if exemption 

Percent qualified agrlcullurat exemption requested by owner (Enter 100 1 full 

denled) 

exemption requested) 

4. REASON FOR PROTEST 

State reason(s) for protest of assessed value and/or the tentative taxable value and/or classification andfor qualified agricutiural property exemption 

Property is assessed at more than 50% of property's true cash value.

Page 9

Form 618, Page 2 

FOR BOARD OF REVIEW USE ONLY 

INSTRUCTIONS: incorporate a copy of this form and the assigned number in the Board of Review minutes. 

Petition Number 

Parcel Code 

1. ASSESSED VALUE 

Disposition by Board of Review. The Board of Review must state [reessenonte selon belo 

[J Denied 

[7] Assessed Value Changed From 

to] 

Record of vote - Beard or three member committee of board 

Chairperson: [ | Yes [_]No 

Reason for board action 

Member: [ 

[Yes 

[ 

|No 

Member: [ | Yes 

[ 

[No 

Initials 

Initials 

Initials 

If you disagree with the decision of the Board of Review regarding tentative assessed value, you may appeal that decision by filing a petition with the 

Michigan Tax Tribunal at P.O. Box 30232, Lansing, MI 48908. Commercial Real, industrial Real, Developmental Real, Commercial Personal, 

Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and Agricultural 

Personal Property may be appealed by July 31. The petition must be filed on a Michigan Tax Tribunal form or a form approved by the Michigan Tax 

Tribunal. Michigan Tax Tribunal forms are available at www.michigan.gov/taxtrib. 

2. TENTATIVE TAXABLE VALUE 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[JDenied 

[] Tentative Taxable Value Changed From 

to 

Record of vote - Board or three member committee of board 

Chairperson: [_] Yes 

[ | No 

Member: [ 

]Yes 

[ | No 

Member: [| Yes 

{ 

[No 

Initials 

Initials 

initlals 

Reason for board action 

If you disagree with the decision of the Board of Review regarding tentative taxable value, you may appeal that decision by fling a pelition with the 

Michigan Tax Tribunal at P.O. Box 30232, Lansing, MI 48909. Commerciat Real, industrial Real, Developmental Real, Commercial Personal, 

Industrial Personal and Utility Personal Properly may be appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and 

Agricultural Personal Property may be appealed by July 31. The petition must be filed on a Michigan Tax Tribunal form or a form approved by the 

Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan.govitaxtrib. 

3. CLASSIFICATION 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[IDenied 

[] Classification Changed From 

to 

Record of vote - Board or three member commitlee of board 

Chairperson: [_] Yes 

[_] No 

Reason for board action 

Member: [ | Yes [No 

Member: [| Yes [No 

Initials 

Initials 

initials 

If you disagree with the decision of the Board of Review regarding classification, you may appeal by sending Form 2167 to the State Tax Commission 

at P.O, Box 30471, Lansing, MI 48909 by June 30. 

4. QUALIFIED AGRICULTURAL PROPERTY EXEMPTION 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[] Exemption Request Denied 

[1 Exemption percent modified from 

% to 

% 

Record of vote - Board or three member committee of board 

Chairperson: [| Yes 

[| No 

Member: | 

Yes 

| 

No 

Member: [Yes [|No

Page 10

CITY OF DETROIT - PROPERTY APPEAL 

LETTER OF AUTHORIZATION 

yweHalf Moon Road Holdings Inc. 

as the legal owner of the property stated 

herein, authorize the following individual or business: 

Name: David E. Nykanen 

Self Prepared 

ADDRESS: 1700 W. Big Beaver Road, Suite 220 

crry; Troy 

STATE: MI 

71p;48084 

PHONE: 2487912110 

FAX: 

EMAIL: dnykanen@fnrpic.com 

To act as my sole and designated representative on my behalf regarding the assessment 

appeal of the following property: 

PARCEL: 27220090 

ADDRESS: 

6/0 1700 W. Big Beavere Road, Suite 220 

cry: Troy 

STATE MI 

71p; 48084 

I further understand that the decision from my appeal is required to be provided in writing 

and hereby expressly assign to my representative the authority to receive such writing on 

my behalf. 

OWNER: Half Moon Road Holdings Inc. 

SIGNATURE; Lg] 

DATE: 3/17/2025 

ADDRESS: ¢/0 1700. "Big Beavere Road, Suite 220 

crry: Troy 

sTaTE:MI 

71p48084 

PHONE: 2487912110 

FAX: 

EMAIL: dnykanen@fnrplc.com 

All companies, LLC’s and/or corporations must provide organization documents along with title and 

name of authorized person to speak on behalf of company. 

Any appeals not meeting the minimum requirements of the Michigan Treasury Form L-4035 and not

Page 11

Filed by Corporations Division Administrator 

Filing Number: 221482160190 

Date: 12/10/2021 

MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

FILING ENDORSEMENT 

This is to Certify that the 

ARTICLES OF INCORPORATION 

for 

HALF MOON ROAD HOLDINGS INC 

received by electronic transmission on 

December 10, 2021 

|, is hereby endorsed. 

Filed on 

December 10, 2021, by the Administrator. 

The document is effective on the date filed, unless a subsequent effective date within 90 days after 

received date is stated in the document. 

In testimony whereof, | have hereunto set my 

hand and affixed the Seal of the Department, 

in the City of Lansing, this 10th day 

of December, 2021.

Page 12

Filed by Corporations Division Administrator 

Filing Number: 221482160190 

Date: 12/10/2021 

sn 

Corporati 

LARA online Filing system 

Form Revision Date 07/2016 

ARTICLES OF INCORPORATION 

For use by DOMESTIC PROFIT CORPORATION 

Pursuant to the provisions of Act 284, Public Acts of 1972, the undersigned executes the following Articles: 

ARTICLE I 

The name of the corporation is: 

HALF MOON ROAD HOLDINGS INC 

ARTICLE II 

Unless the articles of incorporation otherwise provide, all corporations formed pursuant to 1972 PA 284 have the purpose of engaging in 

any activity within the purposes for which corporations may be formed under the Business Corporation Act. You may provide a more 

specific purpose: 

ARTICLE III 

1, State the total authorized shares of each class of stock that the corporation is authorized to issue. All corporations must 

authorize stock.* 

If there is more than one class or series of shares, state the relative rights, preferences and limitations of the shares 

of each class in Article III(2). 

ARTICLE IV 

The street address of the registered office of the corporation and the name of the resident agent at the registered office (P.O. 

Boxes are not acceptable): 

1. 

Agent Name: 

PERRY BOATSWAIN 

2. Street Address: 

13324 GRIENER ST 

Apt/Suite/Other: 

20ND FLR 

City: 

DETROIT 

State: 

MI 

Zip Code: 48205

Page 13

PERRY BOATSWAIN 

13324 GREINER ST, 2ND FLR, DETROIT, MI 48205 USA 

Signed this 10th Day of December, 2021 by the incorporator(s). 

Si 

Perry Boatswain 

Incorporator 

By selecting ACCEPT, 

I hereby acknowledge that this electronic document is being signed in accordance with the Act. 

1 further certify 

that to the best of my knowledge the information provided is true, accurate, and in compliance with the Act. 

th Decline 

i Accept

Page 14

Re: [EXTERNAL] March Board of Review Petition 

(1) MBOR 

@ Mar 31, 2025 at 12:31PM 

To: 

David Nykanen 

[£1 2025 March Board of Review Petition Deadline.pdf 

Good afternoon, 

Please refer to the attached email correspondence. 

Thank you, 

Board of Review 

City of Detroit 

Detroit Board of Review 

Office of the Assessor 

Email: mbor@detroitmi.gov 

Fax: 313.224.4270 

Mailbox is monitored: Monday-Friday, 8:00 a.m.- 4:30 p.m. 

We value your input on the service you received! Please click here to share your 

feedback with our Leadership. 

RELATED LINKS: 

MIHAF Assistance Fund 

Property Assessment Board of Review Process 

Property Transfer Affidavit (PTA) 

Principal Residence Exemption (PRE)_Affidavit 

Wayne County Treasury Office 

Property Taxes Information 

From: David Nykanen <dnykanen@fnrplc.com> 

Sent: Monday, March 17, 2025 1:47 PM 

To: MBOR <MBOR @detroitmi.gov> 

Subject: [EXTERNAL] March Board of Review Petition 

Please see attached.

Page 15

Property Assessment 

Coleman A. Young Municipal Center 

Phone: 313-628-0722 

4 

Board of Review 

2 Woodward Avenue, Suite 105 

Fax: 313-224-4576 

DETROIT 

Detroit, Michigan 48226 

www.detroitmi.gov 

[Notification of Petition] 

Hello, 

Your petition to the 2025 March Board of Review was not submitted timely. 

As specified in all public notices, the deadline for filing was March 10th, 2025, 

by 4:30 PM. 

Thank you, 

Board of Review

Page 16

EXHIBIT B

Page 17

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Half Moon Road Holdings Inc., 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

v 

MTT Docket No. 25-002995 

City of Detroit, 

Respondent. 

ORDER OF DEFAULT 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of 

action taken by Board of Review, uncapping notice, PRE denial notice, final assessment 

notice, etc.), as required by TTR 279. As such, Petitioner must submit the notice within 

14 days of the entry of this order. 

Therefore, 

IT IS ORDERED that Petitioner is HELD IN DEFAULT. 

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order] 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee). 

By: alice 

A. 

HN a lope 

Entered: September 26, 2025 

Patricia L. Halm, Tribunal Chair 

PROOF OF SERVICE 

1 certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

Page 18

MTT Docket No. 25-002995 

Page 2 of 6 

A submission through the tribunal's e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, ora 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a." TTR 225(5)

Page 19

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Half Moon Road Holdings Inc., 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

v 

MTT Docket No. 25-002995 

City of Detroit, 

Respondent. 

ORDER OF DEFAULT 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of 

action taken by Board of Review, uncapping notice, PRE denial notice, final assessment 

notice, etc.), as required by TTR 279. As such, Petitioner must submit the notice within 

14 days of the entry of this order. 

Therefore, 

IT IS ORDERED that Petitioner is HELD IN DEFAULT. 

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order. 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee). 

. 

¢ Heo 

By. 

7a Liieis 

Ao 

Nal pe 

Entered: September 26, 2025 

Patricia L. Halm, Tribunal Chair 

PROOF OF SERVICE 

| certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

Page 20

MTT Docket No. 25-002995 

Page 4 of 6 

A submission through the tribunal's e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL. 205.7353.” TTR 225(5)

Page 21

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 1. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Half Moon Road Holdings Inc., 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

v 

MTT Docket No. 25-002995 

City of Detroit, 

Respondent. 

ORDER OF DEFAULT 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

Petitioner did not submit a copy of the notice giving rise to the appeal (i.e., notice of 

action taken by Board of Review, uncapping notice, PRE denial notice, final assessment 

notice, etc.), as required by TTR 279. As such, Petitioner must submit the notice within 

14 days of the entry of this order. 

Therefore, 

IT IS ORDERED that Petitioner is HELD IN DEFAULT. 

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee). 

a 

J. 

~ 

R 

By: Galicia 

Nan. 

Entered: September 26, 2025 

Patricia L. Halm, Tribunal Chair 

PROOF OF SERVICE 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

Page 22

MTT Docket No. 25-002995 

Page 6 of 6 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal's e-filing system by 11:58 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

Page 23

EXHIBIT C

Page 24

March Board of Review Petition 

§) 

David Nykanen 

& Mar 17, 2025 at 1:47PM 

4 

To: mbor@detroitmi.gov 

+. 

2025 BOR Appeal.pdf 

+ 

Articles of Inc.pdf 

Please see attached. 

The appellant does not request an in person hearing or zoom hearing. 

Dave 

David E. Nykanen 

Friedlaender Nykanen & Rogowski PL.C 

1700 W. Blg Beaver Road, Suite 220 

Troy, Michigan 48084 

(248) 629-0880

Page 25

Michigan Department of Treasury 

618 (Rev, 11-12) 

Petition to Board of Review 

L-4035 

This form Is Issued under the authority of P.A. 206 of 1893, as amended. Filing is voluntary, howsver you may not appeal to the Michigan Tax Tribunal 

or the State Tax Commission unless you first protest to the Board of Review. 

TO BE COMPLETED BY OWNER OR OWNER'S AGENT 

Owner's Name (Please. Pririt or Type) 

Petitioner's Name 

(if Other than Owner. Please Print or Type) 

Half Moon Road Holdings Inc 

David E. Nykanen 

Township or City 

County 

Detroit 

Wayne 

The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified 

agricultural property exemption of the following described property: 

Property Identified {Parce! code required, Properly address & legal description optional) 

27220090. 

Protested Item 

Assessed Value 

Tentative Taxable Value 

I; Classification 

4 Qualified Agricultural 

Property Exemption 

1. PROTEST OF ASSESSMENT 

per 

Exempt 

(Complete this section for a protest of assessed value and/or tentative taxable value) 

Assessed Amount 

Owner's Estimale of True Cash Value 

Tenlalive Taxable Value 

Year 

$262,800 

$290,000 

$250,420 

2025 

2. PROTEST OF CLASSIFICATION 

{Complete this section for a request fo change the classlfication. The Board of Review must make their decision regarding classification in 

accordance with Section 211.34¢ of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular 

classification has on that property's status as a-homeowner's principal residence or qualified agriculiural property.) 

Classification of property on this year's assessment roff 

Classification should be {check one of the following): 

I! Agricultural 

industrial 

I! Timber Cutover 

I! Utility (Personal Property Only) 

[I] Commercial 

Ml Residential 

0 Developmental 

3. PROTEST OF EXEMPTION FOR QUALIFIED AGRICULTURAL PROPERTY 

(Ifthe assessor has denied or changed the percentage of the exemption from the 18 mills of local school operating tax for qualified agricultural 

property, the owner may appeal this.actfon to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT 

UPON THE EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.) 

Percent qualified ‘agricultural exemption granted by assessor (Enter 0 if exemption 

Percent qualified agricisitural exemption requested by owner (Enter 100 if full 

denied) 

exemption requested) 

4. REASON FOR PROTEST 

Stale reason(s) for protest of assessed value and/or the tentative taxable value and/or classification and/or qualified agricultural property exemption 

Property is assessed at more than 50% of property's true cash value.

Page 26

Form 618, Page 2 

FOR BOARD OF REVIEW USE ONLY 

INSTRUCTIONS: Incorporate a copy of this form and the assigned number in the Board of Review minutes. 

Petition Number 

Parcel Code 

1. ASSESSED VALUE 

Disposition by Board of Review. The Board of Review must ooo freozson ori 

acton el 

[IDenied 

|| Assessed Value Changed From 

Record of vote - Board or three member committee of board 

Chairperson: [] Yes [ 

J No re 

Member: [| Yes 

[ 

| No 

Initials 

to] 

| 

Member: [Yes [No 

Initials 

Initials 

Reason for board action 

If you disagree with the decision of the Board of Review regarding tentative assessed value, you may appeal that decision by filing a petition with the 

Michigan Tax Tribunal at P.O. Box 30232, Lansing, Ml 48909. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, 

Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Real, Residential Real, Timber-Cutover Real and Agricultural 

Personal Property may be appealed by July 31, The petition must be filed on a Michigan Tax Tribunal form or a form approved by the Michigan Tax 

Tribunal. Michigan Tax Tribunal forms are available at www.michigan.gov/taxtrib. 

2. TENTATIVE TAXABLE VALUE 

Disposition by Board of Review. The Board of Review must state the reason for its. action below. 

[Denied 

 [] Tentative Taxable Value Changed From 

to 

Record of vote - Board or three member committee of board 

Chairperson: [_] Yes 

[| No 

Member: [| Yes [|No 

Member: [| Yes [No 

Initials 

Initials 

Initials 

Reason for board action 

If you disagree with the decision of the Board of Review regarding tentative taxable value, you may appeal that decision by filing a petition with the 

Michigan Tax Tribunal at P.O. Box 30232, Lansing, M! 48909. Commercial Real, Industrial Real, Developmental Real, Commercial Personal, 

Industrial Personal and Utility Personal Property may be appealed by May 31. Agricultural Réal, Residential Real, Timber-Cutover Real and 

Agricultural Personal Property may be appealed by July 31. The petition must be filed on a Michigan Tax Tribunal form or a form approved by the 

Michigan Tax Tribunal. Michigan Tax Tribunal forms are available at www.michigan.govitaxtrib. 

3. CLASSIFICATION 

Disposition by Board of Review. The Board of Review must state the reason for its action below. 

[1 penied 

[Classification Changed From 

to 

Record of vote - Board or three member commiitiee of board 

Chairperson: [_] Yes [| No ~ 

Member: [Yes 

[_]No 

ae 

Member: [Ives [Ino 

“Tita 

Reason for board action 

If you disagree with the decision of the Board of Review regarding classification, you may appeal by sending Form 2167 to the State Tax Commision 

at P.O. Box 30471, Lansing, Mi 48909 by June 30. 

4. QUALIFIED AGRICULTURAL PROPERTY EXEMPTION 

Disposition by Board of Review. The Board of Review must state the reason for Its action below. 

[] Exemption Request Denied 

[1 Exemption percent modified from 

% to 

% 

Record of vote - Board or three member committee of board

Page 27

CITY OF DETROIT - PROPERTY APPEAL 

LETTER OF AUTHORIZATION 

ywgHalf Moon Road Holdings Inc. 

as the legal owner of the property stated 

herein, authorize the following individual or business: 

NaMme:David E. Nykanen 

Self Prepared 

ADDRESS: 1700 W. Big Beaver Road, Suite 220 

cry; Troy 

state: MI 

z1p;48084 

PHONE; 2487912110 

FAX: 

EMAIL: dnykanen@1nrplc.com 

To act as my sole and designated representative on my behalf regarding the assessment 

appeal of the following property: 

PARCEL: 27220090 

ADDRESS: 

€/0 1700 W. Big Beavere Road, Suite 220 

cry: Troy 

staTe:Ml 

zip; 48084 

I further understand that the decision from my appeal is required to be provided in writing 

and hereby expressly assign to my representative the authority to receive such writing on 

my behalf. 

owner: Half Moon Road Holdings Inc. 

SIGNATURE; “Lp 4 

DATE; 3/17/2025 

ADDRESS: C/0 1700. 

Big Beavere Road, Suite 220 

crry: Troy 

state: M! 

71p48084 

PHONE: 2487912110 

FAX: 

EMAIL: dnykanen@fnrplc.com 

All companies, LLC’s and/or corporations must provide organization documents along with title and 

name of authorized person to speak on behalf of company.

Page 28

Filed by Corporations Division Administrator 

Filing Number: 221482160190 

Date: 12/10/2021 

MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

FILING ENDORSEMENT 

This is to Certify that the 

ARTICLES OF INCORPORATION 

for 

HALF MOON ROAD HOLDINGS INC 

received by electronic transmission on 

December 10, 2021 

|, js hereby endorsed. 

Filed on 

December 10, 2021, by the Administrator. 

The document is effective on the date filed, unless a subsequent effective date within 90 days after 

received date is stated in the document. 

In testimony whereof, | have hereunto set my 

hand and affixed the Seal of the Department, 

in the City of Lansing, this 10th day 

of December, 2021.

Page 29

Filed by Corporations Division Administrator 

Filing Number: 221482160190 

Date: 12/1 0/2021 

Corporati 

Online Filings 

Department of Licensing and Regulatory 

Affairs 

Form Revision Date 07/2016 

ARTICLES OF INCORPORATION 

For use by DOMESTIC PROFIT CORPORATION 

Pursuant to the provisions of Act 284, Public Acts of 1972, the undersigned executes the following Articles: 

ARTICLE I 

The name of the corporation Is: 

HALF MOON ROAD HOLDINGS INC 

ARTICLE II 

Uniess the articles of incorporation otherwise provide, all corporations formed pursuant to 1972 PA 284 have the purpose of engaging in 

any activity within the purposes for which corporations may be formed under the Business Corporation Act. You may provide a more 

specific purpose: 

ARTICLE III 

1. State the total authorized shares of each class of stock that the corporation is authorized to issue. All corporations must 

authorize stock. * 

If there is more than one class or series of shares, state the relative rights, preferences and limitations of the shares 

of each class in Article IT11(2). 

COMMON 

ARTICLE IV 

The street address of the registered office of the corporation and the name of the resident agent at the registered office (P.O. 

Boxes are not acceptable): 

1, 

Agent Name: 

PERRY BOATSWAIN 

2. Street Address: 

13324 GRIENER ST 

Apt/Suite/Other: 

2ND FLR 

City: 

DETROIT

Page 30

PERRY BOATSWAIN 

13324 GREINER ST, 2ND FLR, DETROIT, MI 48205 USA 

Signed this 10th Day of December, 2021 by the incorporator(s). 

Incorporator 

Perry Boatswain 

By selecting ACCEPT, 

I hereby acknowledge that this electronic document is being signed In accordance with the Act. 

I further certify 

that to the best of my knowledge the information provided 

is true, accurate, and in compliance with the Act. 

i) Decline 

if Accept

Page 31

Neen 

THIS IS NOT A TAX BILL 

L-4400 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of Public Act 206 of 1893, Sec, 211.24c and Sec.211.34c, as amended. This 

is a model assessment notice to be used by the local assessor, 

FROM: 

PARCEL IDENTIFICATION 

OT 

SSESSOR 

PARCEL NUMBER: 27220090. 

OFF 

[4 

ADDRESS: 17381 PONTCHARTR 

2 WOODWARD AVE,, SUITE 804 

ROPERTY 

AIN 

DETROIT, Mi 48226 

OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL 

PRINCIPAL RESIDENCE EXEMPTION 

1172691006517 11315 

% Exempt As "Homeowners Principal 

0.0000% 

Boban Hs fg 

get 

Residence: 

% Exempt As "Qualified Agricultural Property”: 0.0000% 

HALE MOON ROAD HOLDINGS INC 

A 

113 MILMAY AVE 

% Exempt As "MBT Industrial Personal™: 

0.0000% 

HAUPPAUGE, NY 11788-3324 

9% Exempt As "MBT Commercial Personal”: 

0.0000% 

Exempt As "Qualified Forest Property": 

[7] Yes (Xl No 

Exempt As "Development Property”; 

[1 Yes (X] No 

| TEGAL DESCRIPTION: W PONCHARTRAIN S 4.67 FT ON E LINE. & RNG TOA PTE IN 5 

W COR 54 55 DETROIT GOLF CLUB 

SUB L30 P99-100 PLATS, W C R 2/135 104.67 IRREG, NEZ HOMESTEAD CERT #NH2008-0812 RELATED PARCEL 

ACCORDING TO MCL 211.34¢ THIS PROPERTY IS CLASSIFIED AS: RESIDENTIAL-IMPROVED 

PRIOR YEAR'S CLASSIFICATION: RESIDENTIAL-IMPROVED 

The change in taxable value will hcrease/decredse 

"PRIOR AMOUNT 

Riv 

"CHANGE FROM 

your tax bill for the 2025 year by approximately: 

YEAR: 2024 

AMOUNT YEAR: 

PRIOR YEAR TO 

$543 

* 

2025 

*| 

CURRENT YEAR 

1. TAXABLE VALUE: 

: 

242,891 

250,420 

7,529 

2. ASSESSED VALUE: 

276,100 

262,800 

-13,300 

3. TENTATIVE EQUALIZATION FACTOR: 1.00 

N 

" 

) 

B 

: 

A 

4. STATE EQUALIZED VALUE (SEV): 

276,100 

262,800 

-13,300 

5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: 

WAS NOT 

6. ASSESSOR CHANGE REASON: MARKET VALUE 

7. ESTIMATED TRUE CASH VALUE: 525,552 

8. EFFECTIVE AGE: 33 

9. YEAR BUILT: 1922 

The 2025 Inflation Rate Muitiplier Is: 1.031 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed 

to the following:

Page 32

0003414110 101INO 

Property Address: 

17381 PONTCHARTRAIN 

2024 CITY OF DETROIT 

WINTER TAX BILL 

MAIL PAYMENT TO: 

CITY OF DETROIT—PROPERTY TAX 

PO BOX 33193 

DETROIT MICHIGAN 48232-5193 

Half Moon Road Holdings Inc 

113 Miimay Ave 

OF - IRY1thew JUNE30 

COUNTY 

- OCT 

1 thru SEPT 30 

Hauppauge, NY 11788-3324 

SCHOOL 

+ JULY 1 thru JUNE 30 

STATE 

- OCT 1 thru SEPT 30 

TAXING UNIT 

RATE 

TAX AMOUNT 

{IMPORTANT INFORMATION --SEE REVERSE SIDE, 

WAYNE COUNTY 

0.9785 

1050 

" 

W.C JAILS 

0.9327 

999 | PARCEL 

E 

02062771. 

W C PARKS 

0.2433 

280 

a 

WC HCMA 

0.2062 

2.21 

WC RESA 

0.0952 

1.02 

| SCHOOL DISTRICT 

WC RESA SP ED 

33328 

3573 | SEV 

R 

+ 

lwW.G.COMM COLLEGE 

“32048 

| 

- won 3495 

TAXABLE VALUE 

+ 

: 

we 200 

0.0988 

1.05 | PRE/MBT% 

WCDIA 

0.1979 

212 | PROP CLASS". 

SCHOOL OPERATING 

1.3968 

1497 | TIEOISTRIGT. 

ENDER". 

01201 LERETA LLC 

- PARTIAL PROPERTY DESCRIPTION ~ 7 

FOR COMPLETE PROPERTY DESCRIPTION, SEE ASSESSMENT ROLL AT ASSESSON'S OFFICE 

w PONCHARTRAIN 54:67 FT ONE LINES RNG TOAPTEINSW 

col 54 85 DETROIT GOLF CLUB SUB L30 £99100 

Total Winter Rate 

Total Winter Taxes 

WINTER TAXES PAYABLE IN FULL DECEMBER 1, 2024 

- JANUARY 15, 2025 

WITHOUT INTEREST AND PENALTY. 

SUMMER 2ND PAYMENT IS DUE JANUARY 15, 2025 WITHOUT INTEREST 

AND PENALTY. 

Admin Fee 

Yotal Winter Due 

Summer Tax Balance 

\ 

. 

: 

. 

Summer Interest Balance’ 

St 

0.00 

Summer Penalty Balance 

~ 

Summer Total Balance 

TOTAL DUE 

cL 

519,47 

YOUR BILL HAS BEEN SENT TO YOUR LENDING INSTITITUTION FOR 

PAYMENT. THIS COPY IS FOR YOUR FILE. 

5. 

2024 CITY OF DETROIT 

v 

WINTER TAX BILL 

PARCEL # 

02002771. 

i 

EE 

MAIL PAYMENT TO: 

TOTAL DUE 

519.47 

I 

: 

CITY OF DETROIT 

PROPERTY TAX 

PO BOX 33193 

men 1] 

DETROIT MICHIGAN 48232-5193 

DUE DATE 

January 15, 2025

Page 33

0003415/4110101/INO 

Property Address: 

17381 PONTCHARTRAIN 

2024 CITY OF DETROIT 

A 2 

MA 

WINTER TAX BILL 

Na) 

x 

MAIL PAYMENT TO: 

AP 

x 

AL 

CITY OF DETROIT —PROPERTY TAX 

< 

PO BOX 33193 

D 

A 

DETROIT MICHIGAN 48232-5193 

Hail Moon Road Holdings Inc 

113 Milmay Ave 

Hauppauge, NY 11788-3324 

CTV - HAY 

thes AINE 30 

COURTY 

- OCT 1 thew SEPT 30 

SCHOOL 

- AY 11hu 

JUNE 20 

STATE 

« OCT 1 thrur SEPT 30 

TAXING UNIT 

RATE 

TAX AMOUNT 

IMPORTANT INFORMATION—-SEE REVERSE SIDE. 

WAYNE COUNTY 

0.4897 

118.94 

WCALS 

09327 

22654 

| PARCEL # 

27230090. 

WC PARKS 

0.2433 

58.09 

' 

WC HOMA 

0.2062 

5008 

WC RESA 

0.0952 

2342 | SCHOOL DISTRICT 

82010 

Vv! GC RESA SP ED 

3.3328 

809.50 | SEV 

276,100 

¥! C COMM COLLEGE 

3.2043 

778.29 | TAXABLE VAWE 

- 

widest 

LL 

242891 

WC 200 

0.0988 

2399 | PRE/MBTH 

Pas 

oT 

WCDIA 

0.4979 

48.05 

| PROP CLASS 

SCHOOL OPERATING 

1.3968 

33927 | TIFDISTRIGT 

te SLENDER 

: 

03201 LERETA LLC 

PARTIAL PROPERTY DESCAIPTION 

i 

Ch 

"FOR COMPLETE PROPERTY DESCRIPTION, SEE ASSESSMENT ROLL 

AT ASSESSOR'S OFFICE 

Ps 

W PONCHARTRAIN § 4.67 FT ON E LINE & RNG TO APTE IN SW 

COR 54 55 DETROIT GOLF CLUB SUB £30 P99-100 

Total Winter Rate 

Le 

oy 

Total Winter Taxes 

Admin Fee 

Total Winter Due 

7,952.70 

Summer Tax Balance 

0.00 

Summer interest Balance 

0.00 

Summer Penalty Balance 

7,962.70 

Summer Total Balance 

TOTAL DUE 

10,454.34 

YOUR BILL HAS BEEN SENT TO YOUR LENDING INSTITUTION FOR 

PAYMENT. THIS COPY IS FOR YOUR FILE. 

] 

mm 

ine 2028 WINTER BRORERTY TAX = RETAIN-THISCORY FOR YOUR RECORDS 

» 

2024 CITY OF DETROI 

WINTER TAX BILL 

MAIL PAYMENT 

TO: 

CITY OF DETROIT— PROPERTY TAX 

PO BOX 33193 

DETROIT MICHIGAN 48232-5193 

error — 

DETROIT 

WINTER TAXES PAYABLE IN FULL DECEMBER 1, 2024 

- JANUARY 15, 2025 

WITHOUT INTEREST AND PENALTY. 

SUMMER 2ND PAYMENT IS DUE JANUARY 15, 2025 WITHOUT INTEREST 

AND PENALTY. 

PARCEL # 

27220090. 

TOTAL DUE 

10,454.34 

memo —] 

DUE DATE 

January 15, 2025

Page 34

HL 

CHA a 

THIS IS NOT A TAX BILL 

L-4400 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c¢, as amended. This 

is a model assessment notice to be used by the local assessor. 

FROM: 

PARCEL IDENTIFICATION 

ETH 

sSESSOR 

PARCEL NUMBER: 02002771. 

OFFICE 

TY ADDRESS: 

17381 

IN 

2 WOODWARD AVE, SUITE 804 

PROPER 

SS: 

17381 

PONTCHARTRA 

DETROIT, Mi 48226 

OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL 

PRINCIPAL RESIDENCE EXEMPTION 

7 

E 

As 

"H 

Pri 

171997006512 

1315 

% 

xempt As 

omeowners 

Principal 

0.0000% 

Tall 

ttl 

U 

ig p El 

dag 

Residence": 

o 

wAuali 

: 

, 

9 

HALF MOON ROAD HOLDINGS INC 

% Exempt As 

"Qualified Agricultural Property”: 0.0000% 

113 MILMAY AVE 

% Exempt As "MBT industrial Personal™: 

0.0000% 

HAUPPAUGE, NY 11788-3324 

% Exempt As “MBT Commercial Personal”: 

0.0000% 

Exempt As "Qualified Forest Property”: 

[7] Yes Xi No 

Exempt As "Development Property”: 

1 Yes ® No 

LEGAL DESCRIPTION: W PONCHARTRAINS 4.67 FT ON E LINE & RNG TO A PTE IN SW COR 54 55 DETROIT GOLF CLUB 

SUB L30 P99-100 PLATS, 

W C R 2/135 104.67 IRREG. NEZ HOMESTEAD CERT #NH2008-0812 RELATED PARCEL 

ACCORDING TO MCL 211.34¢ THIS PROPERTY IS CLASSIFIED AS: RESIDENTIAL-IMPROVED 

PRIOR YEAR'S CLASSIFICATION: RESIDENTIAL-IMPROVED 

The change in taxable value will increase/decrease 

PRIOR AMOUNT 

TIVE 

‘CHANGE FROM 

your tax bill for the 2025 year by approximately: 

| 

PRIOR YEARTO 

YEAR: 2024 

AMOUNT YEAR: 

$28 

2025 

CURRENT YEAR 

1. TAXABLE VALUE: 

10,721 

11,053 

332 

2. ASSESSED VALUE: 

17,500 

11,700 

-5,800 

3, TENTATIVE EQUALIZATION FACTOR: 

1.00 

k 

4, STATE EQUALIZED VALUE (SEV): 

17,500 

11,700 

-5,800 

5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: 

WAS NOT 

6. ASSESSOR CHANGE REASON: MARKET VALUE 

7. ESTIMATED TRUE CASH VALUE: 23,378 

8. EFFECTIVE AGE: 

0 

9. YEAR BUILT: 

0 

The 2025 Inflation Rate Multiplier is: 1,031 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed 

to the following:

Page 35

EXHIBIT D

Page 36

Re: [EXTERNAL] March Board of Review Petition 

(v1) MBOR 

@ Mar 31, 2025 at 12:31PM 

To: 

David Nykanen 

[4 2025 March Board of Review Petition Deadline.pdf 

Good afternoon, 

Please refer to the attached email correspondence. 

Thank you, 

Board of Review 

City of Detroit 

Detroit Board of Review 

Office of the Assessor 

Email: mbor@detroitmi.gov 

Fax: 313.224.4270 

Mailbox is monitored: Monday-Friday, 8:00 a.m.- 4:30 p.m. 

We value your input on the service you received! Please click here to share your 

feedback with our Leadership. 

RELATED LINKS: 

MIHAF Assistance Fund 

Property Assessment Board of Review Process 

Property Transfer Affidavit (PTA). 

Principal Residence Exemption (PRE) Affidavit 

Wayne County Treasury Office 

Property Taxes Information 

From: David Nykanen <dnykanen@fnrplc.com> 

Sent: Monday, March 17, 2025 1:47 PM 

To: MBOR <MBOR @detroitmi.gov> 

Subject: [EXTERNAL] March Board of Review Petition 

Please see attached.

Page 37

Property Assessment 

Coleman A. Young Municipal Center 

Phone: 313-628-0722 

Board of Review 

2 Woodward Avenue, Suite 105 

Fax: 313-224-4576 

DETROIT 

Detroit, Michigan 48226 

www.detroitmi.gov 

Hello, 

Your petition to the 2025 March Board of Review was not submitted timely. 

As specified in all public notices, the deadline for filing was 

Thank you, 

Board of Review

Page 38

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

HALF MOON ROAD HOLDINGS INC, 

Petitioner, 

MTT Docket No. 25-002996 

V. 

Parcel I.D. Nos. 27220090 

CITY OF DETROIT, 

Respondent. 

FRIEDLAENDER NYKANEN 

& ROGOWSKI PLC 

By: David E. Nykanen (P47763) 

1700 W. Big Beaver Road, Suite 220 

Troy, MI 48084 

(248) 629-0880 

Attorneys for Petitioner 

PROOF OF SERVICE 

The undersigned certifies that copies of: (i) Petitioner's Motion and Incorporated Brief For 

Reconsideration 

of Order of Dismissal; and 

(ii) this Proof of Service were served upon the 

attorney(s) and/or representatives of record of all the party(ies) in this action by serving same at 

the business address(es) as disclosed by the pleadings of record herein on the 2nd day of 

December, 2025, by: 

_X 

1st Class U.S. Mail 

Facsimile 

Hand Delivery 

Overnight Mail 

Dated: December 2, 2025 

Eh 

£ 

Denise Carlini 

State of Michigan 

)

Page 39

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

HALF MOON ROAD HOLDINGS INC, 

Petitioner, 

MTT Docket No. 25-002996 

v. 

Parcel 1.D. Nos. 27220090 

CITY OF DETROIT, 

Respondent. 

FRIEDLAENDER NYKANEN 

& ROGOWSKI PLC 

By: David E. Nykanen (P47763) 

1700 W. Big Beaver Road, Suite 220 

Troy, Ml 48084 

(248) 629-0880 

Attorneys for Petitioner 

PROOF OF SERVICE 

The undersigned certifies that copies of: (i) Petitioner's Motion and Incorporated Brief For 

Reconsideration of Order of Dismissal; and 

(ii) this Proof of Service were served upon the 

attorney(s) and/or representatives of record of all the party(ies) in this action by serving same at 

the business address(es) as disclosed by the pleadings of record herein on the 2nd day of 

December, 2025, by: 

_X 

1st Class U.S. Mail 

Facsimile 

Hand Delivery 

Overnight Mail 

Dated: December 2, 2025 

Denise Carlini 

State of Michigan 

)

Page 40

Do not ship liquids, blood, or clinical 

This envelope is only 

You can help us get yo

items securely. Need h

® 

} 

WED 

- 

03 

DEC 5:00P 

STANDARD OVERNIGHT 

[or] 8866 5519 5460 

om 

68 LANA 

r-us ORR. 

WIR

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