26-000048.pdf

Plymouth United Church Of Christ, Petitioner Vs. City Of Detroit, Respondent · 26-000048-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RECEIVED 

FEB 

¢ 6 2026 

PLYMOUTH UNITED CHURCH OF CHRIST, 

Petitioner, 

MICHIGAN Tax TRIBUNAL 

MOAHR Docket No. 26-000048 

Vv. 

£ 

i 

CITY OF DETROIT, 

Respondent. 

PETITIONER’S MOTION FOR RECONSIDERATION 

I. INTRODUCTION AND STANDARD 

Petitioner, Plymouth United Church of Christ, moves for reconsideration of the Tribunal’s 

January 14, 2026, Order of Dismissal, which dismissed this appeal for lack of jurisdiction based 

on an alleged failure to comply with MCL 205.735a(6). 

Reconsideration is warranted because the Tribunal misapprehended both the nature of the 

appeal and the operative notice date, resulting in a clear error of law. Specifically, the Tribunal 

assumed that Petitioner received timely notice of the 2025 assessment or taxable value sufficient 

to trigger the May 31 statutory deadline. That assumption is incorrect. 

This Motion does not seek equitable relief. It identifies a jurisdictional and constitutional 

defect in the dismissal order. 

II. MATERIAL FACTS MISAPPREHENDED BY THE TRIBUNAL

2. 

The December 9, 2025, notice was issued in connection with the Ji uly 2025 Board 

of Review and expressly stated that a further appeal to the Michigan Tax Tribunal could be filed 

within 35 days of the date of the notice. (See Exhibit 1) 

3. 

That notice reflected substantive Board of Review action, including: 

a. 

Grant of a property exemption, 

b. 

Correction based on clerical error or mutual mistake of fact, and 

¢. 

A 

tax status change (BOR Reason Codes 14, 15, and 21). 

4. 

Petitioner filed their Tribunal petition on January 8, 2026, within the appeal 

period stated in the notice and within 30 days of receipt of the first notice of the 2025 assessment 

or taxable value. (See Exhibit 2) 

5: 

That this Honorable Court dismissed the Petition on January 14, 2026, for the 

following reasons: 

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

The petition was not filed by May 31 or the next business day after the Tribunal 

offices were closed. See MCL 205.735a(6). As such, and inasmuch as the Tribunal 

has 

no 

equitable 

power 

to 

waive 

or 

otherwise 

disregard 

statutory 

filing 

requirements and deadlines, it has no authority to hear the appeal or grant the relief 

requested. See Sixarp, LLC v Byron Twp, _Mich_; _NW3d_(2025). (See Exhibit 

3) 

6. 

That this Honorable Court did not have the opportunity 

to consider that the 

Petitioner did not receive notice of the 2025 assessment or taxable value until December 9, 2025. 

7. 

That this Honorable Court not having the full benefit to consider that the Petitioner 

did not receive notice of the 2025 assessment or taxable value until December 9, 2025, was a 

palpable defect.

9. 

That 

it would be fundamentally unfair for this case to be dismissed when the 

Petitioner did not receive notice of the 2025 assessment or taxable value until December 9, 2025 

III. CONCLUSION 

This Motion identifies a clear error of law arising from the Tribunal’s misapprehension of 

the notice date and the nature of the appeal. Because jurisdictional deadlines cannot run before 

notice is provided, reconsideration is required to prevent a due-process violation and an unlawful 

dismissal. 

IV. RELIEF REQUESTED 

For the foregoing reasons, Petitioner respectfully requests that the Tribunal: 

a. 

Vacate the January 14, 2026, Order of Dismissal; 

b. 

Find that the appeal was timely based on the December 9, 2025, notice; 

¢. 

Determine that MCL 205.735a(6) does not bar jurisdiction under these facts; and 

d. 

Reinstate this matter for adjudication on the merits. 

Respectfully Submitted, 

DARWYN P. FAIR LAW PLLC 

/s/ Darwyn P. Fair 

DARWYN P. FAIR (P31266) 

Attorney for Petitioner 

535 Griswold, Ste. 111-554 

Detroit, Michigan 48226 

Dated: February 2, 2026 

(313) 967-0595

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PLYMOUTH UNITED CHURCH OF CHRIST, 

Petitioner, 

MOAHR Docket No. 26-000048 

Vv. 

CITY OF DETROIT, 

Respondent. 

BRIEF IN SUPPORT OF 

PETITIONER’S MOTION FOR RECONSIDERATION 

Unless 

another 

rule 

provides 

a 

different 

procedure, 

motions 

for 

rehearing 

or 

reconsideration must be filed and served not later than 21 days after entry of an order deciding the 

motion, and no response or oral argument will occur unless the court directs otherwise. MCR 7.215 

and MCR 2.119(F)(3) MCR 2.119(F)(3) requires 

a party bringing 

a motion for rehearing or 

reconsideration to show “palpable error.” However, the “palpable error” language in MCR 

2.119(F)(3) is not mandatory and only provides guidance to a court for when it may be appropriate 

to consider a motion for rehearing or reconsideration. See, e.g., Prentis Family Found, Inc v 

Barbara Ann Karmanos Cancer Inst, 266 Mich App 39, 698 NW2d 900 (2005). It is always within 

the trial court’s discretion to grant “a second chance” to a motion that it has previously denied. 

Kokx v Bylenga, 241 Mich App 655, 659, 617 NW2d 368 (2000).

Honorable Court had the full benefit to consider that the Petitioner did not receive notice of the 

2025 assessment or taxable value until December 9, 2025, it would have resulted in a different 

disposition of the case. 

It would be fundamentally unfair for this case to be dismissed when the 

Petitioner did not receive notice of the 2025 assessment or taxable value until December 9,2025. 

I. THE TRIBUNAL MISAPPLIED MCL 205.735a(6) 

A. MCL 205.735a(6) cannot apply absent timely notice 

MCL 205.735a(6) presupposes that the taxpayer received timely notice of assessment or 

taxable value early enough in the tax year to permit: 

¢ 

A March Board of Review protest, and 

e 

A May 31 appeal to the Tribunal. 

Where no such notice is given, the statutory deadline cannot constitutionally run. A filing 

deadline that expires before notice is provided violates procedural due process and cannot 

divest the Tribunal of jurisdiction. 

The Order of Dismissal makes no finding as to when notice was provided. Instead, it 

assumes notice sufficient to trigger the May 31 deadline and dismisses on that basis alone. That 

assumption is factually and legally erroneous. 

B. This appeal is not a “standard valuation appeal” 

The Tribunal further erred by classifying this case as a routine valuation appeal governed 

by MCL 205.735a(6). The July Board of Review did not merely reaffirm a March assessment; it 

affirmatively altered the property’s tax status, including granting an exemption and correcting 

errors.

are materially distinct from ordinary valuation disputes and are not properly dismissed under a 

statute designed for March valuation protests. 

IL. THE DECEMBER 9, 2025, NOTICE TRIGGERED THE APPEAL PERIOD 

The December 9, 2025, Board of Review notice expressly advised Petitioner that it could 

appeal to the Tribunal within 35 days. Because this was the first notice of the 2025 assessment 

or taxable value: 

a. 

It was the only legally operative notice; 

b. 

It triggered the appeal period as a matter of due process; and 

c. 

Detitioner’s January 8, 2026, filing was timely. 

The Tribunal’s dismissal effectively renders the notice meaningless and extinguishes appeal rights 

before they could be exercised. 

III. CONCLUSION 

This Motion identifies a clear error of law arising from the Tribunal’s misapprehension of 

the notice date and the nature of the appeal. Because jurisdictional deadlines cannot run before 

notice is provided, reconsideration is required to prevent a due-process violation and an unlawful 

dismissal. 

IV. RELIEF REQUESTED 

For the foregoing reasons, Petitioner respectfully requests that the Tribunal: 

a. 

Vacate the January 14, 2026, Order of Dismissal; 

b. 

Find that the appeal was timely based on the December 9, 2025, notice; 

¢. 

Determine that MCL 205.735a(6) does not bar jurisdiction under these facts; and

DARWYN P. FAIR (P31266) 

Attorney for Petitioner 

535 Griswold, Ste. 111-554 

Detroit, Michigan 48226 

Dated: February 2, 2026 

(313) 967-0595

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PLYMOUTH UNITED CHURCH OF CHRIST, 

Petitioner, 

MOAHR Docket No. 26-000048 

v. 

CITY OF DETROIT, 

Respondent. 

CERTIFICATE OF SERVICE 

I certify that on February 3, 2026, I served the Petitioner’s Notice of Filing Petition and 

Notice of Filing Motion for Reconsideration upon Respondent City of Detroit by first-class U.S. 

Mail, addressed to the Corporation Counsel, City of Detroit Law Department, at 2 Woodward 

Ave., Suite 500, Detroit, MI 48226. 

/s/ Darwyn P. Fair 

Darwyn P. Fair (P31266) 

Attorney for Petitioner 

535 Griswold, Ste. 111-554 

Detroit, MI 48226 

Date: February 2, 2026 

(313) 967-0595

EXHIBIT 1

CITY OF DETROIT 

2025 DECEMBER BOR AFFIDAVIT OF CORRECTION 

Parcel Number: 

03001349, 

[i 

Owner Name / Address: 

PLYMOUTH UNITED CHURCH OF CHRIST 

600 

E WARREN AVE 

DETROIT MI 48201 

Capture Districts: 

FOR 2025 ASSESSMENTS 

Property Class: 

Property Address: 

School District: 

Tax Billing / Special Acts Info: 

District: 

05 

Petition 

#: D-06156 

Current Assessed Value: 

Current Taxable Value: 

Current Principal Residence Exemption: 

0 

Corrected Assessed Value: 

0 

Cormected Taxable Value: 

00% 

Corrected Principal Residence Exemption: 

201 

4901 CHRYSLER 

DETROIT PUBLIC SCHOOLS 

Ad Valorem 

285,200 

128,581 

00% 

BOARD OF REVIEW REASON CODE NUMBER [See below for description/explanation of code number]: 16,14 

Description of Code Numbers: 

0 

NARKETVALUE 

2 

02 

APPEAL DENIED 

24 

03 

DIDNOTAPPEAR 

AT MBOR 

2A 

GF 

SU 

PARTIAL POVERTYERIY GRAN 

TLD 

20 

SIA 

SI 

DEVIATED 

PARTIAL POVERTY GRANTED 

kJ 

[CURR 

FECIAL PARTIAL POVERTY GRANTED 

or 

WIC 

23 

PARTIAL POVERTY GRANTILD 

LLY 

HD 

23% 

DEVERARTIAL POVERTY GRANTED 

2B 

Hl. 

ECIAL HANDLING PAREN POVERTY GRANTED 

ts 

HF 

"ARTIAL POVERTY GRAN TLD 

H 

HG 

TE PARTIAL 

POVERTY GRANTED 

25 

© 

FULL POVERTY 

GRANTED 

Ka 

NIA 

DEVIATED TULL POVERTY GRANTLD 

260 

OS 

SPECIAL HANDUNG 

FUEL POVERTY GRAN LED 

S40) 

60 

POVERTY DENIED 

pt 

GOA 

SPECIAL HANDING POVERIY DENIED 

he 

OT 

PRINCIPAL RESIDENCE 

ENENIPTION REINSTATED BY TREASE RY 

0 

ON 

PRINCIPAL RESIDENCE 

NENIPTION APPROYED 

3 

a 

PRINCIPAL RESIDENCE LXENIPTION DENIED BY TREASURY 

Be 

PRINCIPAL RESIDENCE 

FXEMPHON RESCINDED) 

1 

PRINCIPAL RESIDENCE 

EXFMIPHION DENIED BY CHIY 

H 

TEA 

PRINCIPAL RESIDENCE 

EXEMPTION DENIED BY COUNTY 

w 

12 

PRINCIPAL RESIDENCE ENENIPTION WHIIDRAWN 

ih 

13 

DINMOOFSTRUCTURE 

37 

HE 

TRRORCTERICAL 

MUTUAL MISTARL 

Ww 

HA 

FRROR-CALCULATION 

| CORRECTION 

Bi 

1 

NONPROFIT ENENIPTHION GRAN TLD 

an 

16 

NON PROFIFENENIPYION DENIED 

41 

17 

PREVIOUSLY OMITTED PROPIRTY 

RY 

FAN STATUS CHANGE 

TORIN Z0N1 

TOREN 20M] 11] 257, 

TOREN ZONE 

IFT 3 

TO RIN ZONE IFT 730, 

NEZLAND VALLE 

NEZRUIDING VALLL 

NCAR 

RECAP 

EZ REMOVED 

RETIRED 

IN 

ERROR 

PERSONAL PROPLRIN NOTREPORITD 

ANENDED 

PERSONAL PROPERTY RETURNED 

TRANSHER PERSONAL PROPERTY 1OCATION 

NW BESINE SS 

OUTOEIESINGSS 

OUALIFILD PLRSONAL PROPLRIY NOT REPORTED 

SEIN 

TOT HUD STNNITD 

SEVEENIEN 

FILED LATE AFHER ASSESSMENT NOTICES VAILLD 

SEXTEMEN 

FLED INIELY 

of \IBOR 

INTERNAL OBSOLESCENCE 

FUNCHON AL OBSOLESCENCE 

OBNOLESCINCE 

MIT 

SIC 

MFT STCCARRY TOWARD 

HC 

ADIESTER DUE 

TO AUDIT RESULTS 

45 

10 0PRY 

3A 

TRONMOPRY 

ho 

TOPOL 

6A 

FROM PILOT 

Tobby 

FROM DIA 

100 (RY 

TROMCFT (RY 

MBOR PROPERTY 

(1 ASS GRANTED. 

MBOR PROPERTY CLASS DENITD 

BOARD 

OF REVIEW 

- OPINION (DFNEALY 

BOARD 

OF REVIEW 

= 

NO CONSIDERATION 

1010F 

TRONCIE) 

TORN ZONE 1001 

DIE: 

FROM REN ZONE 1001. & DIE 

TO POSTS IFL TODL 

& DIL RZ 

FROM POSTUEIT TOOL & DIE RZ 

$1 

TOREN ZONE ENVISION 

PRONREN ZONE EXTENTION 

S85 

TONNORCHIZIN 

PILOT 

TRONESINIOR CITIZEN PLOY 

VEHRANSENTMPHON GRANTED 

NLHRANS 

ENEVMPHON DENIED 

S 

0 EMPPSENTE DENIAL 

SC 

RNTEON IANNTION 

or 

COURTORDLR 

oF 

OUALIHED AGRICULTURAL 

- GRANTLD

Parcel Number: 

[a 

CITY OF DETROIT 

2025 DECEMBER BOR AFFIDAVIT OF CORRECTION 

03001350. 

Owner Name / Address: 

PLYMOUTH UNITED CHURCH OF CHRIST 

FOR 2025 ASSESSMENTS 

District: 

05 

Petition #: 

D-06157 

600 

E WARREN 

DETROIT MI 48201 

Property Class: 

~~ 201 

Capture Districts: 

Property Address: 

~~ 4801 CHRYSLER 

School District: 

DETROIT PUBLIC SCHOOLS 

Tax Billing / Special Acts Info: 

Ad Valorem 

Current Assessed Value: 

0 

Corrected Assessed Value: 

305,300 

Current Taxable Value: 

0 

Corrected Taxable Value: 

111,435 

Current Principal Residence Exemption: 

00% 

Corrected Principal Residence Exemption: 

00% 

BOARD OF REVIEW REASON CODE NUMBER [See below for description/explanation of code number]: 16,14 

Description of Code Numbers: 

OF 

VARI 

ALLE 

21 

TANSTATUS CHANGE 

A 

ADUSTED DUETO AUDIT RESULTS 

or 

APPEAL DENIED 

2 

TORIN ZONE 

45 

T0OPRA 

03 

DIDNOTAPPEAR AT MBOR 

TOREN ZONE 

25 

ISN 

FROMOPRY 

0S 

PARTIAL POVERTYERTY GRANTED 

TO REN ZONI 

4 

ToPIot 

WEA 

SE 

DENINTED PARTIAL POVERTY GRANTED 

TOREN Z0N1 

7 

6X 

FROM PILOT 

1) 

SPECIAL PARTIAL POVERTY GRANTED 

[OREN ZONE 

IEE 

47 

TODA 

"e 

PARTIAL POVERTY GRAN TID 

TOREN Z0N 

1 

ATA 

TRONEDDA 

{h) 

VEPARTIAL POVERTY GRANTED 

FOREN ZONE IFT 

I 

TOCFT (RY 

oi 

ALTANDLING PARTI POVERTY GRANTED 

OREN ZONE HFT 

757 

ASN 

FRONCEL CRY 

MEI 

PARTIAL POVERTY GRANTED 

NEZEANDVALLL 

49 

MBOR PROPERTY CLASS GRANTED 

MG 

TL PARTAL POVLRIY GRAN TLD 

SONIZBEIDING YALL 

SON 

NIBOR PROPEREY CLASS DENIED 

05 

FULL POVERTY GRANTED 

Jo 

INCAR 

St 

BOARD 

OF REVILW 

- OPINION (DENIAL) 

OSA 

DEVIATED TELL POVERTY GRANTED 

260 

RECAP 

SUN 

BOARD 

OF REVIEW «NO CONSIDERATION 

GSE 

SPECIAL TANDENG ULE PONTRIY GRANTED 

27 

NZ RENIOVED 

Soom 

te 

POVERTY DENIED 

28 

RETIRED IN ERROR 

SIA 

TROVE 

BA 

SPECIAL HANDING POVERTY DENIED 

29 

PERSONAE PROPLRTY NOT REPORTED 

2 

OREN ZONE 1001 & DIE 

#7 

PRINCIPAL RESIDENCE ENTVIPHON REINSTATED BY TREASURY 

ANIENDED PERSONAL PROPERTY RETLRNED. 

FROM REN ZONE TOOL & DIE 

8 

PRINCIPAL RESIDENCE EXEMPTION APPROVED 

3 

IRANSHLR PERSONAL PROPERTY 

LOCATION 

10 POSTS TEL 1001 X DIL RZ 

#0 

PRINCIPAL RESIDENCE TNPMPTION DENIED BY TREASURY 

ONIW BUSINESS 

FROM POSTE TOO] & DIF RZ 

[0 

PRINCIPAL RESIDENCE ENTNIPHON RESCINDED 

SO 

OUTOFBESINESS 

TOREN ZONE 

EXTENSION 

HE 

PRINCIPAL RESIDENCE 

EXEMPTION DENIED BY (11Y 

4 

OUALIED 

PERSONAL PROPERTY NOT REPORTID 

FROVEREN ZONF EXTENTION 

FEA 

PRINCIPAL RESIDENCE TXEMPTION DENIED 

BY (COPNTY 

SOSINEEMENTNOTHLED 

ESTA TED 

TOSENIOR CENZEN LOT 

12 

PRINCIPAL RESIDENCE EXEMPTION WITHDRAWN 

Fo 

SENTEMEN FIED LATE 

- AFTER ASSESSMENT NOTICES 

EXILED 

TROMSINIOR CHIZEN PHOT 

15 

DEMO OFSIRUCTURY 

STONTXTEMIEN 

FEED DINIEY 

a MOR 

$6 

VETERANS TXEMPHON GRANTED 

F 

FRROR-CLERICAL 

MIETUAL MISTAKE 

3 

INTERNAL OBSOLESCENCE 

ST 

NFIERANSENLMIPHON DENIED 

HA 

LRROR-CALCULATION 

CORRECTION 

Ho 

FENCHONAL OBSOLESCENCE 

SX 

LMPP STATE DENIAL 

15 

NONPROFIT EXEMPTION GRANTED 

In 

OBSOLESCENCE 

0 

RATEOF 

DATION 

Ih 

NONPROFIT 

EXEMPTION DENIED 

A 

MEST 

oi 

COURT ORDER 

17 

PRENTOUSLY OMITTED PROF RY 

ALN 

NET 

STCCARRY TOWARD

EXHIBIT 2

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

Entire Tribunal Case Information Sheet - Petitioner 

MOAHR DOCKET NO. 26-000048 

Section 1: Petitioner’s Contact Information 

Filer type: Organization 

First Name/Company Name 

ML 

Last Name 

Plymouth United Church of Christ 

Home Address (No., Street, P.O. Box or Rural Route) 

600 E. Warren 

City or Town 

State 

ZIP Code 

Detroit 

Michigan 

48201 

Telephone Number 

Fax Number 

3139994492 

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) 

NH00996937@aol 

com 

Section 2: Attorney/Authorized Representative’s Contact Information 

First Name 

MIL 

Last Name 

Darwyn 

Fair 

Firm Name (if any) 

Address (No., Street, P.O. Box or Rural Route) 

535 Griswold 

Ste 111-554 

City or Town 

State 

ZIP Code 

Detroit 

Michigan 

48226 

Telephone Number 

Fax Number 

313-967-0595 

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) 

dpfair@dpfairlaw.com 

Section 5: Issue 

Please designate one: 

Valuation — Fill out Sections 4, 5, & 6 below 

Section 6: Subject Property Information

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

GOVERNOR 

LANSING 

ORLENE HAWKS 

DIRECTOR 

Section 7: Check which of the following you are appealing (check all that apply) 

‘True Cash and Taxable Values, Taxable Value Only (calculation), Tax Bill, Other (please explain) 

Section 8: Valuation Information for Each Parcel under Appeal 

Parcel Number: 

03001350 

Classification of Property: 

Real 

Commercial 

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 

305300 

Current Taxable Value as established by the Board of Review: 

111435 

What do you believe is the fair market value (also known as True Cash Value)? 

0 

Multiply the True Cash Value by 50% and cnter here. This is your contention of Assessed Value (also known as State Equalized Value). 

0 

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 

0 

Parcel Number: 

03001349 

Classification of Property: 

Real 

Commercial 

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 

285200 

Current Taxable Value as established by the Board of Review: 

128581 

What do you believe is the fair market value (also known as True Cash Value)? 

0 

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 

0 

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 

0 

Section 9: Assessment Information 

Type of Tax Assessment(s): 

Assessment Number(s):

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll? 

If No, please explain: 

Section 11: Classification Information 

Parcel Number: 

Current Classification of Property as established by Board of Review: 

What do you believe is the property's classification? 

Tfimproved property, hiow is the property currently being used? 

Tr improved property, for what use was the property designed? 

Fee Information 

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. 

1 you are appealing more than one parcel, the parcel with the highest 

State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed. 

If the State Equalized Value or Taxable Value in contention is: 

Your filing fee is: 

$100,000.00 and under 

$250.00 

$100,000.01 to $500,000.00 

$400.00 

$Over $500,000.00 

$600.00 

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00. 

A fee of $250.00 is required for the filing of a Special Assessment Appeal. 

A fee of $250.00 is required for the filing of 

an Equalization Tax Appeal. 

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal. 

A fee of $150.00 is required for the filing of a Classification Tax Appeal 

Electronic Signature *Typing your name below will serve as your signature 

Petitioner or Attorney/Authorized Representative’s Signature: 

Is/ Darwyn P Fair

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

PLYMOUTH UNITED CHURCH OF CHRIST, 

Petitioner, 

MOAHR Docket No. 

Vv. 

CITY OF DETROIT, 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. Property Parcel No: 03001350/03001349 

2. The property identified above is real property. The property is Commercial property. 

3. If more than one parcel of real property is under appeal, are the properties contiguous? 

NA 

4. Are all of the parcels of personal property located on a parcel of real property under appeal? 

YES 

5. If parcels of personal property are under appeal, when were the personal property statements 

filed by parcel number (attach additional page if necessary): 

NA 

6. The property identified above is classified as 

201- COMMERCIAL 

7. If the assessment or assessments at issue were protested, the protest was made to Respondents 

March 

July _ December Board of Review.

NA 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification 

or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list 

the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over 

the assessment or assessments at issue (attach additional page if necessary): 

We have timely appealed. 

10. The property or properties at issue are located in WAYNE County. The property or properties’ 

address is: 

4901 CHRYSLER 

DETROIT, MI 48201 

4901 CHRYSLER 

DETROIT, MI 48201 

11. The assessment or assessments at issue were established by the (applicable local governmental 

unit): 

CITY OF DETROIT 

12. Petitioner’s legal residence or principal office address is: 

375 LODGE 

DETROIT, MI 48214 

13. This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

X__the property or properties’ taxable value only If the property or properties’ taxable 

value 

is 

at issue, 

is there 

a dispute 

as 

to the value of an addition 

or loss? X Yes 

_ No 

uniformity of the property or properties’ assessment _ 

X 

the property or the properties’ exemption from ad valorem taxation under MCLA 

125.1415. 

14. The tax year(s) at issue are: 

2025

16. The values for the property identified above as established by Respondent’s Board of Review 

are: 

Tax Year 

Petitioner 

Assessed Value 

Taxable Value 

2025 

4801 

305300 

111435 

2025 

4901 

285200 

128581 

17. Petitioner contends that the values for the property identified above are: 

Tax Year 

Petitioner 

Assessed Value 

Taxable Value 

2025 

4801/4901 

0 

0 

18. The values in dispute for the property identified above are: 

Tax Year 

Petitioner 

Assessed Value 

Taxable Value 

2025 

4801 

305300 

111435 

2025 

4901 

285200 

128581 

19. Petitioner requests the following relief (attach additional page if necessary): 

Tax Year 

Petitioner 

Assessed Value 

Taxable Value 

2025 

4801/4901 

0 

0 

20. List the separate and specific facts upon which Petitioner relies to support the relief requested 

(attach additional page if necessary): 

“The City of Detroit Office of the Assessor has failed to establish that the Tax Payor is not 

eligible for commercial exemption under MCLA 125.1415a 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/S/DARWYN P. FAIR

DETROIT, MI 48226 

Telephone Number: 

313-967-0595 

Date: January 8, 2026

EXHIBIT 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Plymouth United Church of Christ, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

v 

MTT Docket No. 26-000048 

City of Detroit, 

Respondent. 

ORDER OF DISMISSAL 

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

The petition was not filed by May 31 or the next business day after the Tribunal offices 

were closed. See MCL 205.735a(6). As such, and inasmuch as the Tribunal has no 

equitable power to waive or otherwise disregard statutory filing requirements and 

deadlines, 

it has no authority to hear the appeal or grant the relief requested. See 

Sixarp, LLC v Byron Twp, __Mich__; 

_ NW3d__ (2025). 

Therefore, 

IT IS ORDERED that the case is DISMISSED. 

This order resolves all pending issues and closes the case. 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’'s web-based e-filing 

system; 

it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the

MTT Docket No. 26-000048 

Page 2 of 2 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. 

If the 

claim is filed within 21 days of the entry of the final decision, 

it is an “appeal of right.” 

If 

the claim is filed more than 21 days after the entry of the final decision, 

it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

al 

| 

Ta Lee Lo 

Kv 

MACH 

Patricia L. Halm, Tribunal Chair 

By: 

Entered: January 14, 2026 

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. 

By: Tribunal Clerk

DARWYN P. FAIR LAW, PLLC 

Attorney at Law 

535 Griswold, Suite 111-554 

Detroit, Michigan 48226 

(313) 967-0595 

(313) 731-0585 Fax 

(313) 407-6631 Direct Line 

dpfair@dpfairlaw.com 

January 3, 2026 

Via Federal Express 

Michigan Tax Tribunal 

611 W. Ottawa Street 

Lansing, MI 48933 

Re: 

Docket No 26-000048 

Plymouth United Church 

Docket No. 26-000046 

Eschaton LLC 

Docket No. 26-000045 

MR Non Profit Housing Corporation 

Enclosed are Motion for Reconsideration for the above-mentioned matters. 

Please file in your 

normal manner. 

I have also enclosed 

a check in the amount of $50 for each Motion for 

Reconsideration. 

If you have any questions regarding the enclosed please contact me 

at the above contact 

information. 

Very truly yours, 

DARWYN P. FAIR LAW, PLLC 

/s/ Darwyn P. Fair 

Darwyn P. Fair 

Cc: 

City of Detroit, Corporation Counsel

f 

| Darwyn P, Fajr 

| 

535 Griswold 

| 

Ste 11 1-554 

| 

Detroit, Mj 48226 

{ 

| Michigat: Tax Tribunal 

| 611 W. Ottawa Street 

Lansing, MI] 48933

nvel

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