Petition - Amended - POS.pdf
Hartland Towne Square LLC Petitioner Vs. Township Of Hartland Respondent · 26-000560-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
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS Hartland Towne Square LLC, Petitioner, vs. Hartland Township, Respondent. MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL MTT Docket No. 26-000560 _____________________________________________________________________________/ PROOF OF SERVICE (Property Tax Petition) On the date below I sent by certified mail, return receipt requested, a copy of the Amended Petition to: Township Assessor Hartland Township 2655 Clark Rd Hartland, MI 48353 Township Supervisor Hartland Township 2655 Clark Rd Hartland, MI 48353 On the date below I sent by first class mail a copy of the Amended Petition to: Equalization Director Livingston County 304 E Grand River Ave Howell, MI 48843 County Clerk Livingston County 200 E Grand River Ave Howell, MI 48843 Secretary, Board of Education Hartland Consolidated Schools 9525 E. Highland Rd Howell, MI 48843 State Treasurer Department of Treasury 430 W. Allegan Street Lansing, MI 48922 I declare that the statements above are true to the best of my information, knowledge and belief. /s/ Laura M. Hallahan Dated: June 29, 2026
Page 2
1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS Hartland Towne Square LLC, Petitioner, v Hartland Township, Respondent. MICHIGAN TAX TRIBUNAL Docket No. 26-000560 Parcel No.: 4708-21-400-069, and additional parcels _____________________________________________________________________________/ AMENDED PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) This Amended Property Tax Petition is being filed as the Petition filed April 10, 2026, incorrectly identified the School District as Okemos Public School District. The School District is Hartland Consolidated Schools and is correctly identified below. Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use 4708-21-400-069 Highland Road 202 Comm Retail 4708-21-402-001 Hartland Square Dr 202 Comm Retail 4708-21-402-003 Hartland Square Dr 202 Comm Retail 4708-21-402-004 Hartland Square Dr 202 Comm Retail 4708-21-401-008 Highland Road 202 Comm Retail 4708-21-400-076 Hartland Road 202 Comm Retail 2. ☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: ☐ March, ☐ July, ☐ December Board of Review. 3. Respondent, identified above, assesses and collects taxes on the subject property. 4. The subject property is located in the County of Livingston and school district of Hartland Consolidated Schools. 5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property.
Page 3
2 6. The Petitioner’s principal office/legal residence address is: 32820 Woodward Ave., Suite 200, Royal Oak, MI 48073. 7. This appeal involves issues related to: ☒ the subject property’s true cash and taxable values ☐ the subject property’s taxable value only there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No ☐ uniformity of the subject property’s assessment ☐ the subject property’s exemption from ad valorem taxation under MCL ______ 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values are based upon an erroneous determination of the true cash value of that portion of Petitioner’s property that is taxable under Michigan law and are based upon the application of wrong principles; and d. The assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection and due process of law. Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable to the reductions, with interest, as provided by the Tax Tribunal Act.
Page 4
3 HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 Dated: June 18, 2026 lhallahan@hallahanlaw.com Filing Fee: $725
Page 5
4 ATTACHMENT TO PETITION (Subject Property) VALUES Respondent’s Board of Review -and- Petitioner’s Contention Parcel Number Respondent Petitioner TCV SEV TV TCV SEV TV 4708-21-400-069 5,337,800 2,668,900 2,668,900 1,130,000 565,000 565,000 4708-21-402-001 743,000 371,500 371,500 100,000 50,000 50,000 4708-21-402-003 743,000 371,500 371,500 100,000 50,000 50,000 4708-21-402-004 51,400 25,700 25,700 20,000 10,000 10,000 4708-21-401-008 999,600 499,800 499,800 200,000 100,000 100,000 4708-21-400-076 3,791,000 1,895,500 1,895,500 1,000,000 500,000 500,000 Totals 11,665,800 5,832,900 5,832,900 2,550,000 1,275,000 1,275,000 VALUES IN DISPUTE Parcel Number TCV SEV TV 4708-21-400-069 4,207,800 2,103,900 2,103,900 4708-21-402-001 643,000 321,500 321,500 4708-21-402-003 643,000 321,500 321,500 4708-21-402-004 31,400 15,700 15,700 4708-21-401-008 799,600 399,800 399,800 4708-21-400-076 2,791,000 1,395,500 1,395,500 Totals 9,115,800 4,557,900 4,557,900