25-002295.pdf
Home Depot USA Inc, Petitioner Vs. City Of Warren, Respondent · 25-002295-TT
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RECEIVED _ Way 15 2006 WV s@ STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Home Depot USA, Inc., Petitioner, V. Warren, Respondent. Daniel L. Stanley (P57052) Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 222 North Washington Square Suite 400 Lansing, MI 48933-1800 (517)377-0714 (313) 465-7270 dstanley@honigman.com jcook@honigman.com MICHIGAN TAX TRIBUNAL MTT Docket No. 25-002295 024606 C 040714 1D: HONIGHAN LLP 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 and Taxable Values Petitioner, Home Depot USA, Inc., through its attorneys, Honigman LLP, moves to amend the Petition in this matter to include the following: 1. In 2026, Respondent determined the taxable value of Petitioner’s Property to be $3,042,801 and Respondent assessed Petitioner’s Property at $3,694,400, which will result in a state equalized value of the same amount, based upon the tentative equalization factor.
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(a) The assessment, including state equalized value and/or taxable value, exceeds the amounts permitted by the Michigan Constitution and applicable statutes; (b) The 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 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 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 moves that this Motion be granted, and Petitioner requests that the Tribunal enter an Order: (i) reducing the 2026 assessed and state equalized value from $3,694,400 to $1,983,000; (ii) reducing the 2026 taxable value from $3,042,801 to $1,983,000; (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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Dated: May 15, 2026 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: /s/ Daniel L. Stanley Daniel L. Stanley (P57052) Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 222 North Washington Square Suite 400 Lansing, MI 48933-1800 (517) 377-0714 (313) 465-7270 dstanley@honigman.com jcook@honigman.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL HOME DEPOT USA, INC., Petitioner, Vv. MTT Docket No. 25-002295 WARREN, Respondent. / Proof of Service Lisa Joseph affirms that on May 15, 2026 she served a copy of Petitioner's Motion to Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service in connection with the above-entitled cause upon the following: Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com via electronic mail. Dated: May 15, 2026 /s/ Lisa Joseph Lisa Joseph
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Honigman LLP COSTS ADVANCED ACCOUNT 040714 Invoice Date Invoice Number Invoice Narrative Payment Amount 5/14/26 040714 DLS/260739/547711 300.00 Motion to Amend 25-002295 24559387.1