motion for recon 25-002995 12-3-2025.pdf
Half Moon Road Holdings Inc., Petitioner V City Of Detroit, Respondent · 25-002995-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
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
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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
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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
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EXHIBIT A
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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:
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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)
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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:
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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 [|NoPage 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
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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.
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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
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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
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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.
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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
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EXHIBIT B
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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.
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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)
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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.
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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)
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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.
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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)
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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.
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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
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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
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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:
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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, 2025Page 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:
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EXHIBIT D
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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.
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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
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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