Petition 2025 (per Sever Order) Target v Clinton Twp. - (25-002276).pdf
Target Corporation, Petitioner Vs. Township Of Clinton, Respondent · 25-002276-TT
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25-0013 60809402.2 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Target Corporation, Petitioner, v. Clinton Twp., Respondent. MTT Docket No. 25-002276 Parcel No. 16-11-34-328-004 Michael B. Shapiro (P20282) Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com jcook@honigman.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea A. Melcher (P85821) Hallahan & Associates, P.C. Attorneys for Respondent 1750 S. Telegraph Rd., Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com Entire Tribunal Property Tax Petition Target Corporation (“Petitioner”), through its attorneys, Honigman LLP, says: 1. Petitioner hereby files this Entire Tribunal Property Tax Petition pursuant to and as required by Michigan Tax Tribunal Order Severing 2025 Tax Year and Assigning it to Docket No. 25-002276, dated June 5, 2025. 2. Petitioner's principal office address is P.O. Box 9456, TPN-0950, Minneapolis, MN 55440.
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60809402.2
3.
Petitioner is a party in interest with respect to property taxes on tax parcel number
16-11-34-328-004 ("Petitioner's Property"), with an address of 33860 Gratiot Ave., Clinton Twp.,
located in Macomb County, Michigan.
4.
Respondent, Clinton Township, assesses and collects property taxes on Petitioner's
Property.
5.
Respondent’s March Board of Review set the 2025 taxable value of Petitioner's
Property at $3,283,962 and set the 2025 assessed value of Petitioner's Property at $4,872,900,
which will result in a state equalized value in the same amount based upon the tentative
equalization factor.
6.
Petitioner's Property is classified as commercial real.
7.
Petitioner's Property is presently used or available for use for retail purposes.
8.
Petitioner believes that Petitioner's Property was originally designed to be used for
retail purposes.
9.
This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable
value and (d) uniformity.
10.
At this time, Petitioner believes, as it relates to taxable value, that there is a dispute
relative to the value of a loss.
11.
A Board of Review protest was not required for Petitioner’s Property.
12.
The 2025 assessment, including state equalized value and taxable value, imposed
on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful
and operate as a fraud upon the taxpayer for the reasons that:Page 3
3 60809402.2 (a) The 2025 assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 2025 assessment, including state equalized value and/or taxable value, is at a higher percentage of true cash value than permissible under the Michigan Constitution and applicable statutes; (c) The 2025 assessment, including taxable value and/or state equalized value, is based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and is based upon the application of wrong principles; and (d) The 2025 assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection, and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 2025 taxable value of Petitioner's Property from $3,283,962 to $2,127,000; (ii) reducing the 2025 assessed value and state equalized value of Petitioner's Property from $4,872,900 to $2,127,000; (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.
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4 60809402.2 Dated: June 11, 2025 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: _______________________________________ Michael B. Shapiro (P20282) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com Dated: June 11, 2025 HONIGMAN LLP Attorneys for Petitioner By: _______________________________________ Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com