28405 Van Dyke Owner LLC, Petitioner Vs. City Of Warren, Respondent

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

28405 Van Dyke Owner LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001777

City Of Warren,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 9, 2025

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.

By: Tribunal Clerk

Page 2

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

28405 Van Dyke Owner LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001777

City Of Warren,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 9, 2025

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.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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

28405 Van Dyke Owner LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001777

City Of Warren,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on September 4, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 9, 2025

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.

By: Tribunal Clerk

Page 2

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

28405 Van Dyke Owner LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001777

City Of Warren,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on September 4, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 9, 2025

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.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

28405 Van Dyke Owner LLC, 

Petitioner, 

MTT Docket No. 25-001777-TT 

v 

Parcel: 12-13-16-276-005 

City of Warren, 

Respondent, 

SARAH R. BELLOLI 

MARY MICHAELS (P44601) 

Ryan, LLC 

LAURA SULLIVAN (P42021) 

Representatives for Petitioner 

City of Warren 

101 W. Big Beaver Road, Suite 945 

Representatives for Respondent 

Troy, MI 48084 

One City Square, Suite 400 

(313) 230-0104 

Warren, MI 48093 

sarah.belloli@ryan.com 

(586) 574-4671 

Isullivan@cityofwarren.org 

JOINT MOTION TO DISMISS 

Petitioner and Respondent hereby stipulate to the dismissal of Petitioner’s appeal with 

prejudice and without costs or attorney fees to either party. 

/Is/l Sarah R. Belloli 

Sarah R. Belloli 

Ryan, LLC 

Laura Sullivan (P42021) 

Representatives for Petitioner 

City of Warren 

101 W. Big Beaver Road, Suite 945 

Representatives for Respondent 

Troy, MI 48084 

One City Square, Suite 400 

Warren, MI 48093 

Dated: October 8, 2025 

Dated: October 3, 2025

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

28405 VAN DYKE OWNER LLC, 

MTT Docket No. 25-001777 

Petitioner, 

Parcel ID No. 12-13-16-276-005 

v. 

CITY OF WARREN, 

Respondent. 

SARAH BELLOLI 

RYAN LLC 

Representatives for Petitioner 

101 West Big Beaver, Ste. 945 

Troy, Michigan 48084 

(313) 230-0104 

sarah.belloli@ryan.com 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Ste. 400 

Warren, Michigan 48093 

(586) 574-4671 

Isullivan@cityofwarren.org 

/ 

RESPONSE TO PETITION 

Respondent, 

City of Warren, 

by and through 

its attorneys, MARY MICHAELS, Acting 

City Attorney and LAURA SULLIVAN, Assistant City Attorney, in response to the Petition states 

as follows: 

1. 

Paragraph 

1 

is not contested. 

2. 

Paragraph 2 is not contested. 

3. 

Paragraph 3 does not require a response.

Page 2

9. 

Paragraph 9 does not require a response. 

10. 

Paragraph 10 is not contested. 

11. 

Paragraph 11 

is not contested. 

12. 

In response to Paragraph 

12, Respondent is without knowledge or information 

sufficient to form a belief as to the truth of the allegations in Paragraph 20, and leaves Petitioner 

to its proofs. 

13. 

In response to Paragraph 

13, Respondent is without knowledge or information 

sufficient to form a belief as to the truth of the allegations in Paragraph 20, and leaves Petitioner 

to its proofs. 

14. 

Paragraph 14 is not contested. 

15. 

Paragraph 15 is not applicable. 

16. 

Paragraph 16 is not contested, except that the True Cash Value on the Subject 

Property Record Card is $14,600,277.00 

17. 

In response to Paragraph 17, Respondent is without knowledge or information 

sufficient to form a belief as to the truth of the allegation in Paragraph 17 and leaves Petitioner 

to its proofs. 

18. 

In response to Paragraph 

18, Respondent is without knowledge or information 

sufficient to form a belief as to the truth of the allegation in Paragraph 18 and leaves Petitioner 

to its proofs. 

19. 

In 

response 

to 

Paragraph 

19, 

Respondent 

does 

not 

contest 

that 

this 

is 

Petitioner's request, 

but denies that any excess taxes, fees, penalties, interest or costs are 

owing to Petitioner.

Page 3

THEREFORE, Respondent City of Warren requests this Tribunal deny the requested 

relief, dismiss the Petition with prejudice, and award Respondent costs it incurred in the defense 

of this appeal. 

Respectfully submitted, 

By: 

/[s/Laura Sullivan 

LAURA SULLIVAN (P42021) 

Assistant City Attorney III 

Attorneys for Respondent 

Dated: September 11, 2025 

LS/vIt Response to Petition, Affirmative Defenses and POS — 28405 Van Dyke Owner ID 114373

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

28405 VAN DYKE OWNER LLC, 

MTT Docket No. 25-001777 

Petitioner, 

Parcel ID No. 12-13-16-276-005 

V. 

CITY OF WARREN, 

Respondent. 

SARAH BELLOLI 

RYAN LLC 

Representatives for Petitioner 

101 West Big Beaver, Ste. 945 

Troy, Michigan 48084 

(313) 230-0104 

sarah.belloli@ryan.com 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Ste. 400 

Warren, Michigan 48093 

(586) 574-4671 

Isullivan@cityofwarren.org 

/ 

AFFIRMATIVE DEFENSES 

Respondent, City of Warren, by and through 

its attorneys, MARY MICHAELS, Acting 

City Attorney and LAURA SULLIVAN, Assistant City Attorney, submit the following Affirmative 

Defenses: 

1. 

Petitioner failed 

to allege specific and sufficient facts 

to set forth 

a cause 

of 

action. 

2. 

Petitioner failed to allege specific and sufficient facts to establish illegality on part

Page 5

4, 

Petitioner 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. 

5. 

Petitioner 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. 

6. 

Petitioner 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 respective 

assessments appearing 

on the 

roll, and also failed 

to allege specific and sufficient facts to 

support its allegations that the property's taxable value is improper. 

7. 

Petitioner failed to submit any evidence warranting relief from the assessments to 

the Board of Review. 

8. 

Petitioner, 

in essence, seeks by petition to challenge the process of county and 

state equalization as to which it has no legal standing and cannot maintain a cause of action. 

9. 

Respondent reserves the 

right 

to 

raise additional defenses 

as may become 

known to it during the course of these proceedings. 

Respectfully submitted, 

By: 

/s/Laura Sullivan 

LAURA SULLIVAN (P42021) 

Assistant City Attorney III 

Attorneys for Respondent 

Dated: September 11, 2025 

LSNvIt Response to Petition, Affirmative Defenses and POS — 28405 Van Dyke Owner ID 114373

Page 6

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

28405 VAN DYKE OWNER LLC, 

MTT Docket No. 25-001777 

Petitioner, 

Parcel ID No. 12-13-16-276-005 

Vv. 

CITY OF WARREN, 

Respondent. 

SARAH BELLOLI 

RYAN LLC 

Representatives for Petitioner 

101 West Big Beaver, Ste. 945 

Troy, Michigan 48084 

(313) 230-0104

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001777

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Warren (MACOMB)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Sullivan

Firm Name (if any)

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

One City Square

Suite 400

City or Town

Warren

State

Michigan

ZIP Code

48093

Telephone Number

586-574-4671

Fax Number

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

lsullivan@cityofwarren.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Laura Sullivan

/s/

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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

28405 Van Dyke Owner LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001777

City Of Warren,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: September 4, 2025

Patricia L. Halm, Tribunal Chair

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.

By: Tribunal Clerk

i “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received.

Page 2

MTT Docket No. 25-001777

Page 2 of 6

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

Page 3

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

28405 Van Dyke Owner LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001777

City Of Warren,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.ii 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: September 4, 2025

Patricia L. Halm, Tribunal Chair

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.

By: Tribunal Clerk

ii “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received.

Page 4

MTT Docket No. 25-001777

Page 4 of 6

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section

Page 5

STAT

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Page 1

101 West Big Beaver 

Suite 945 

Troy, Michigan 48084 

Ryan, 

A 

Tel. 313.230.0104 

innovative Solutions 

Fax 313.230.0114 

to Taxing Problems, 

www. ryan.com 

RECEIVED 

June 27, 2025 

JUN 3 6 2025 

Re: 

28405 Van Dyke Owner, LLC v City of Warren 

MICHIGAN TAX TRIBUNAL 

MOAHR Docket No.: 25-001777 

Dear Chief Clerk: 

Petitioner hereby serves all parties provided for in Michigan Tax Tribunal Rule 221 with its 

petition in this matter. Pursuant to the rule, the petition notes the docket number assigned by the 

tribunal and is served within 45-days of the issuance of the notice of docket number. 

If you have any questions regarding the enclosed pleading, please do not hesitate to contact our 

office directly at (313) 230-0104. 

Respectfully, 

aly 8. BIL 

Sarah R. Belloli 

Ryan, LI.C 

cc: 

State of Michigan Treasurer 

WARREN CONSOLIDATED SCHOOLS 

Macomb County Equalization Director 

Macomb County Clerk 

City of Warren Assessor 

City of Warren Clerk

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFARIS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

28405 Van Dyke Owner, LLC 

Petitioner, 

v 

City of Warren 

Respondent, 

MOAHR Docket No.: 25-001777 

Proof of Service 

Joan Kleiner, being duly sworn, deposes and says that on June 27, 2025 

, she served a copy of the 

Petition relative to the above-captioned matter, via first class mail, upon: 

State of Michigan Treasurer 

WARREN CONSOLIDATED SCHOOLS 

Department of Treasury 

School Board Secretary 

Treasury Building 

31300 Anita 

430 West Allegan 

Warren, MI 48093 

Lansing, MI 48922 

Macomb County Equalization Director 

Macomb County Clerk 

1 S. Main 8S, 6th Floor 

120 N Main St. 

Mount Clemens, MI 48093 

Mt Clemens, MI 48043 

and via certified mail, return receipt requested, upon: 

City of Warren Assessor 

City of Warren Clerk 

1 City Square # 310 

1 City Square 

Warren, MI 48093 

Warren, MI 48093 

With proper postage affixed thereto. 

Qoan Atriner

Page 3

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These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

GRETCHEN WHITMER 

GOVERNOR 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

Lansing 

 

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

28405 Van Dyke Owner, LLC, 

 MICHIGAN TAX TRIBUNAL 

Petitioner, 

 

v 

MTT Docket No. 

 

 

City of Warren 

, 

Respondent. 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: 12-13-16-276-005 

 

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

addressing all other parcels at issue.) 

 

2. 

The property identified above is X real 

personal. 

 

3. 

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.) 

 

4. 

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.) 

 

5. 

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

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

 

6. 

The property identified above is classified as 201 Commercial- Improved 

 

 

7. 

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

Respondent’s 

March 

July 

December Board of Review. X NA 

 

 

 

 

 

 

 

 

 

 

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

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 Macomb 

 County. The 

property or properties’ address is: 

 

 28405 VAN DYKE WARREN, MI 48092 

 

11. 

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

governmental unit): City of Warren 

 

 

12. 

Petitioner’s legal residence or principal office address is: 

ONE TOWNE SQUARE STE #1200 SOUTHFIELD, MI 48076 

13. 

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

 X 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: 2025

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):NA 

 

 

 

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

2025

$14,600,280.00

$7,300,140

$4,736,060

 

 

 

 

 

17. 

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

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 2025 

$5,000,000 

$2,500,000 

$2,500,000 

 

 

 

 

 

 

 

 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 2025 

$9,600,280 

$4,800,140.00 

$2,236,060.00 

 

 

 

 

 

 

 

 

 

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 

 

Petitioner relies on the following facts to support the relief requested: 

The subject assessments imposed on the subject property and the taxes to be levied and collected are invalid 

for the reason that: 

a. The equalized assessment thus imposed on the subject property is more than 50% of its true cash 

value in violation of the applicable statutory and constitutional limitations. 

b. The assessment is unlawful and is based upon the application of wrong principles and thereby operates 

as a fraud upon the taxpayer. 

Petitioner respectfully requests the Tax Tribunal hear this case and enter an order 

reducing the 2025 True Cash, State Equalized and Taxable Values and direct 

Respondent to refund to Petitioner any excess taxes, fees and penalties paid, plus 

interest and costs.

Page 4

MTT Docket No. 

Page 4 of 4 

 

 

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

 

 

 

Email Address: Sarah.Belloli@Ryan.com 

 

 

Mailing Address: 

 

Sarah R. Belloli 

 

101 West Big Beaver, Suite 945 

Troy, Michigan, 48084 

 

Telephone Number: (313)230-0104 

 

 

Date: 5/29/2025 

 

 

CC: Joan.Kleiner@ryan.com

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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

28405 Van Dyke Owner LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001777

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: July 23, 2025

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.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

GRETCHEN WHITMER 

GOVERNOR 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

Lansing 

 

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

28405 Van Dyke Owner, LLC, 

 MICHIGAN TAX TRIBUNAL 

Petitioner, 

 

v 

MTT Docket No. 

 

 

City of Warren 

, 

Respondent. 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: 12-13-16-276-005 

 

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

addressing all other parcels at issue.) 

 

2. 

The property identified above is X real 

personal. 

 

3. 

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.) 

 

4. 

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.) 

 

5. 

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

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

 

6. 

The property identified above is classified as 201 Commercial- Improved 

 

 

7. 

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

Respondent’s 

March 

July 

December Board of Review. X NA 

 

 

 

 

 

 

 

 

 

 

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

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 Macomb 

 County. The 

property or properties’ address is: 

 

 28405 VAN DYKE WARREN, MI 48092 

 

11. 

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

governmental unit): City of Warren 

 

 

12. 

Petitioner’s legal residence or principal office address is: 

ONE TOWNE SQUARE STE #1200 SOUTHFIELD, MI 48076 

13. 

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

 X 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: 2025

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):NA 

 

 

 

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

2025

$14,600,280.00

$7,300,140

$4,736,060

 

 

 

 

 

17. 

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

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 2025 

$5,000,000 

$2,500,000 

$2,500,000 

 

 

 

 

 

 

 

 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 2025 

$9,600,280 

$4,800,140.00 

$2,236,060.00 

 

 

 

 

 

 

 

 

 

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 

 

Petitioner relies on the following facts to support the relief requested: 

The subject assessments imposed on the subject property and the taxes to be levied and collected are invalid 

for the reason that: 

a. The equalized assessment thus imposed on the subject property is more than 50% of its true cash 

value in violation of the applicable statutory and constitutional limitations. 

b. The assessment is unlawful and is based upon the application of wrong principles and thereby operates 

as a fraud upon the taxpayer. 

Petitioner respectfully requests the Tax Tribunal hear this case and enter an order 

reducing the 2025 True Cash, State Equalized and Taxable Values and direct 

Respondent to refund to Petitioner any excess taxes, fees and penalties paid, plus 

interest and costs.

Page 4

MTT Docket No. 

Page 4 of 4 

 

 

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

 

 

 

Email Address: Sarah.Belloli@Ryan.com 

 

 

Mailing Address: 

 

Sarah R. Belloli 

 

101 West Big Beaver, Suite 945 

Troy, Michigan, 48084 

 

Telephone Number: (313)230-0104 

 

 

Date: 5/29/2025 

 

 

CC: Joan.Kleiner@ryan.com

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

28405 Van Dyke Owner, LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

Fax Number

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

sarah.belloli@ryan.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

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

101 West Big Beaver Road

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48084

Telephone Number

313-230-0104

Fax Number

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

sarah.belloli@ryan.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

Michigan

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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

12-13-16-276-005

Classification of Property: Real 

Commercial

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

7300140

Current Taxable Value as established by the Board of Review:

4736060

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

5000000

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

2500000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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.

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/ Sarah Belloli

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