Motion to Amend 2026 and POS - Wal-Mart Warren (25-002292).pdf

Wal-Mart Real Estate Business Trust, Petitioner Vs. City Of Warren, Respondent · 25-002292-TT

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STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Wal-Mart Real Estate Business Trust,

Petitioner,

MTT Docket No. 25-002292

City of Warren,

Respondent.

Jackie J. Cook (P68781)

Daniel L. Stanley (P57052)

Honigman LLP

Attorneys for Petitioner

2290 First National Bldg.

660 Woodward Avenue

Detroit, MI 48226-3506

(313) 465-7270

jcook@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80257)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C.

Attorneys for Respondent

1750 S. Telegraph Road, Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Motion to Amend Petition to Contest

2026 Assessed Value, State Equalized Value, and Taxable Value

Petitioner, Wal-Mart Real Estate Business Trust, through its attorneys, Honigman LLP,

moves to amend the Petition in this matter to include the following:

In 2026, Respondent’s board of review determined the taxable value of

Petitioner’s Property to be $5,402,161 and Respondent’s board of review assessed Petitioner’s

Property at $6,540,130, which will result in a state equalized value of the same amount, based

upon the tentative equalization factor.

The 2026 assessment – including the state equalized and taxable values –

imposed on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and

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the mode of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on

Petitioner, because they

Exceed amounts permitted by the Michigan Constitution and applicable statutes;

b. Are calculated at or derived from higher percentages of true cash value than

permissible under the Michigan Constitution and applicable statutes;

Are based on the application of wrong principles and an erroneous determination

of the true cash value of that portion of Petitioner's Property that is taxable under

Michigan law, if any; and

d. Discriminate against Petitioner and deny Petitioner its constitutional rights to

uniformity, equal protection, and due process of law.

WHEREFORE, Petitioner moves that this Motion be granted, and Petitioner requests that

the Tribunal enter an Order: (i) reducing the 2026 assessed value and state equalized value from

$6,540,130 to $3,100,000; (ii) reducing the 2026 taxable value from $5,402,161 to $3,100,000;

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and

costs; and (iv) awarding Petitioner any other relief to which it is entitled.

Dated: May 28, 2026

Respectfully submitted,