Full record / Petition 2025 (per Sever Order) - Wal-Mart Warren (25-002292).pdf

Petition 2025 (per Sever Order) - 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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Page 1

25-0013 

60869504.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Wal-Mart Real Estate Business Trust, 

Petitioner, 

v. 

City of Warren, 

Respondent. 

MTT Docket No. 25-002292 

Parcel No. 12-13-10-353-009 

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 

Wal-Mart Real Estate Business Trust (“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. 

25-002292, dated June 5, 2025. 

2.

Petitioner's principal office address is 2608 SE J Street, Suite 2, Bentonville, AR 

72716-0555.

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2 

60869504.1 

3.

Petitioner is a party in interest with respect to property taxes on tax parcel number 

12-13-10-353-009 ("Petitioner's Property"), with an address of 29176 Van Dyke Ave, Warren, 

located in Macomb County, Michigan. 

4.

Respondent, City of Warren, 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 $5,260,138 and set the 2025 assessed value of Petitioner's Property at $6,761,660, 

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:

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60869504.1 

(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 $5,260,138 to $3,800,000; (ii) reducing the 2025 

assessed and state equalized value of Petitioner's Property from $6,761,660 to $3,800,000; 

(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 

60869504.1 

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

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