Michigan

13 Mile & Mound LLC Petitioner Vs. City Of Warren Respondent

Petitioner: 13 Mile & Mound LLC
Respondent: City Of Warren

Case overview

Docket number: 26-001331-TT
Status: Answer Due
CaseType: ET Property
Division: ET
County: Macomb
Judge: No judge assigned

Docket history

Line #	Subject	Filer	Line Ref	Enter Date/Post Mark	Fee	Related Item
5	Answer was received	RESP	Not recorded	10/16/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
4	Proof of service of petition was received.	Not recorded	Not recorded	09/18/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
3	Petition has been verified	PET	1	08/06/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
2	Notice of Docket Number ET	Not recorded	Not recorded	08/06/2026	Not recorded	Download
1	A petition was received.	PET	Not recorded	05/24/2026	$400.00	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download

Documents

Answer_NW & Franklin_FINAL.pdfRead complete document text →

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NW & FRANKLIN LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF SOUTHFIELD, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001332 

Parcel No. 76-24-18-276-043 

 

 

 

 

_____________________________________________________________________________/ 

 

STEVE JOHNSON 

MICHIGAN TAX APPEAL SERVICES 

Representative for Petitioner 

436 N. Center Street 

Northville, MI 48167 

(248) 392-4342 

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 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Southfield, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent neither admits nor denies the allegations in Paragraph 3 as no claim is 

made.

Page 2

Respondent denies any implication a parcel of personal property has been identified

as under appeal.

Respondent admits only one parcel of real property has been identified as under

appeal.

Respondent admits the allegations in Paragraph 6.

Respondent neither admits nor denies the allegations in Paragraph 7 as no claim is

made.

Respondent neither admits nor denies the necessity of a protest to the Board of

Review as the General Property Tax Act speaks for itself.

Respondent neither admits nor denies the timeliness of Petitioner’s Petition as

Petitioner’s Petition and the General Property Tax Act speak for themselves.

10.

Respondent admits the allegations in Paragraph 10.

11.

Respondent admits the allegations in Paragraph 11.

12.

Respondent lacks the information and knowledge necessary to respond to the truth

of the allegations set forth in Paragraph 12 and, therefore, leaves Petitioner to its proofs.

13.

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but

denies that those issues have merit and further denies any implication Petitioner is entitled to relief.

14.

Respondent acknowledges Petitioner’s belief as to an issue with the 2026 tax year

but denies any issue with said year.

15.

Respondent admits only the 2026 tax year has been identified as under appeal.

16.

The values for the property identified above as established by Respondent’s Board

of Review are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2026

$757,820

$378,910

Page 3

3 

 

 

17. 

Respondent contends that the values for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$757,820 

$378,910 

$378,910 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

19. 

Respondent acknowledges the relief requested by Petitioner in Paragraph 19 but 

denies that Petitioner is entitled to said relief as Petitioner’s amounts do not reflect an accurate 

valuation of this property as of tax day. Furthermore, the assessed, state equalized and/or taxable 

values do not exceed permitted amounts, do not exceed the percentage of true cash value permitted 

by law, were correctly determined and are based upon correct application of proper principles, and 

the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 

20. 

Respondent denies the allegation set forth in Paragraph 20 for the reason that the 

same is untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed 

permitted amounts, do not exceed the percentage of true cash value permitted by law, were 

correctly determined and are based upon correct application of proper principles, and the values 

and Respondent’s mode of assessment are non-discriminatory and constitutional. 

WHEREFORE, Respondent, City of Southfield, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees.

Page 4

HALLAHAN & ASSOCIATES, P.C.

/s/ Seth A. O’Loughlin______________

LAURA M. HALLAHAN (P42101)

SETH A. O’LOUGHLIN (P80257)

KELSEA M. MELCHER (P85821)

Attorneys for Respondent

1750 S. Telegraph Road, Suite 202

Bloomfield Hills, MI 48302

Dated: October 16, 2026

(248) 731-3089

AFFIRMATIVE DEFENSES

Respondent, City of Southfield, asserts the following affirmative defenses:

Petitioner fails to allege specific and sufficient facts to set forth a cause of action

against Respondent and to support its claim for relief.

The Tribunal is charged with finding a property’s true cash value to determine the

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981).

Petitioner has the burden of establishing the property’s true cash value. See

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974).

Petitioner has failed to allege specific and sufficient facts to establish fraud, error

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or

its agents.

Petitioner has failed to allege that the mode and method of assessing the subject

property fails to conform to the mode and method applied in the case of all other properties in

Respondent’s taxing unit for the year in question.

Petitioner has failed to show that any factor other than fifty percent (50%) was

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the

Page 5

5 

 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its

Page 6

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EntireTribunalCaseISAnswer.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001331

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Warren (MACOMB)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

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

mtt@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

/s/Kelsea M. Melcher

/s/

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Proof of Service_13 Mile & Mound LLC_26-001331.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

13 Mile & Mound LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 26-001331 

City of Warren 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Rebecca Adler 

states that on 

9/18/26 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. 

Assessor (via certified mail): 

Jennifer M. Czeiszperger, Assessor, City of Warren Assessing Office, One City Square, STE 

310, Warren, MI 48093 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

Sonja Djurovic Buffa, City Clerk, City of Warren Clerk's Office, One City Square, Warren, Mi 

48093 

3. 

County Equalization Director (via first class mail or personal service): 

Equalization Director, Macomb County Equalization Department, 

1 S Main St, 6th Floor, Mount 

Clemens, MI 48043 

4. 

County Clerk (via first class mail or personal service): 

Macomb County Clerk's Office, 120 N. Main St, Mount Clemens, MI 48043 

5. 

Secretary of the local school board (via first class mail or personal service): 

School Board Secretary, Warren Consolidated Schools, 31300 Anita Drive, Warren, MI 48093 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

/s/ Rebecca Adler 

Rebecca Adler 

[Signature of person who is serving/mailing copy] 

[Print/type name of person serving/mailing copy] 

MICHIGAN TAX TRIBUNAL 

- 611 W. OTTAWA ST., LANSING, MI 48933 

- 517-335-9760 

PO BOX 30232, LANSING, MI 48909 

- Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

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SubsequentFiling.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001331

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Proof of Service_13 Mile & Mound LLC_26-001331

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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13 Mile & Mound LLC 2026 ET-Petition-Prop-fillable.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARLON I. BROWN, DPA

GOVERNOR

DIRECTOR

LANSING

_____________________________,

MICHIGAN TAX TRIBUNAL

Petitioner(s)

MTT Docket No.

_____________________________,

Respondent(s)

ENTIRE TRIBUNAL PROPERTY TAX PETITION

Property Parcel No: _____________________________________________

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition

Form addressing all other parcels at issue.)

The property identified above is ___real ___personal.

If more than one parcel of real property is under appeal, are the properties

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non

contiguous parcel.)

Are all of the parcels of personal property located on a parcel of real property

under appeal? ___Yes ___No. (If no, separate Petitions are required for each

parcel of personal property not located on a parcel of real property under

appeal.)

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

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

The property identified above is classified as _________________________

If the assessment or assessments at issue were protested, the protest was made

to Respondent’s ___ March ___ July ___December Board of Review.

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

13 Mile & Mound LLC

City of Warren

12-13-05-476-006

N/A

Commercial

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

8.

If a protest was required and no protest was made, 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):

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):

10.

The property or properties at issue are located in _______________County. The

property or properties’ address is:

11.

The assessment or assessments at issue were established by the (applicable

local governmental unit): ________________________________________

12.

Petitioner’s legal residence or principal office address is:

13.

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

________the property or properties’ true cash and taxable values

________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? ___ Yes ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

under MCL ______ 

14.

The tax year(s) at issue are: _______________________________________

N/A

N/A

Macomb

5823 13 Mile, Warren, MI 48092

City of Warren

5550 Hampshire Dr, West Bloomfield, MI 48322

X

2026

Page 3

MTT Docket No. _________________ 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior 

tax year or years (attach additional page if necessary): 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

16. 

The values for the property identified above as established by Respondent’s 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value

Taxable Value 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value

Taxable Value 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value

Taxable Value 

19. 

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

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

N/A

2026

6,048,700

3,024,350

3,024,350

3,024,350

5,750,000

2,875,000

2,875,000

2026

298,700

149,350

149,350

Petitioner requests the Tribunal reduce the assessed, state equalized, and taxable 

values from 3,024,350 to 2,875,000 and order a refund with interest as provided in 

the Tax Tribunal Act.

Our initial review of the subject property indicates the assessment exceeds 50% of 

the true cash value.

Page 4

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

MTT Docket No. _________________ 

Page 4 of 4 

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

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Email Address: _________________________________________________________ 

Mailing Address: 

Telephone Number: _____________________________________________________ 

Date: _________________________________________________________________ 

/s/ Steve Johnson

Steve Johnson

info@mitaxappeal.com

436 N Center St, Northville, MI 48167

248-392-4342

May 23, 2026

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EntireTribunalCaseISPetition.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

13 Mile & Mound LLC

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

5550 Hampshire Dr

City or Town

West Bloomfield

State

Michigan

ZIP Code

48322

Telephone Number

248-392-4342

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

info@mitaxappeal.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Steve

M.I.

Last Name

Johnson

Firm Name (if any)

Michigan Tax Appeal Services

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

436 N. Center Street

City or Town

Northville

State

Michigan

ZIP Code

48167

Telephone Number

248-392-4342

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

info@mitaxappeal.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

5823 13 Mile

Warren

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48092

Taxing Authority (City or Township)

City Of Warren (MACOMB) 

County

Macomb

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

12-13-05-476-006

Classification of Property: Real (check one)

Commercial (check one)

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

3024350

Current Taxable Value as established by the Board of Review:

3024350

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

5750000

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

2875000

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

Fee Information

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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: 

/s/ Steve Johnson

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052486728761

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-08-06_17-56-37.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

13 Mile & Mound LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

MTT Docket No.: 26-001331

City Of Warren,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted

docket number has been assigned to that petition. This docket number shall be noted

on the petition and the petition shall be served within 45 days of the issuance of

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the

issuance of this notice evidencing the service of the petition.

If you submitted a proof of service with the petition, you must still serve the petition and

file a second proof of service including the docket number, pursuant to this notice.

Failure to serve the petition and file a proof of service within 45 days of the issuance of

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28

days after the date of service of the petition with noted docket number.” Failure to do so

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this

case. Further, the assignment of the docket number does not mean that the Tribunal

has authority over the petition or that the petition complies with statutory requirements

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: August 6, 2026

PROOF OF SERVICE

I 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.