310 S Mechanic Limited Dividend Housing Association Limited Partnership Petitioner Vs. City Of Jackson 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 

310 S Mechanic Limited Dividend Housing 

MICHIGAN TAX TRIBUNAL 

Association Limited Partnership, 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000941 

 

City of Jackson, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has considered the file in this case and the submitted Stipulation for Entry 

of Consent Judgment (Stipulation) and finds that the Stipulation meets all filing and 

statutory requirements.1 As such, the Tribunal shall enter the Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 26-000941 

Page 2 of 2 

 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

(xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%, and (xx) after 

July 1, 2026, through December 31, 2026, at a rate of 7.85%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

Entered: August 25, 2026 

 

 

 

By: /s/ Marcus L. Abood 

am 

 

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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

310 S Mechanic Lofts Limited Dividend 

Housing Association Limited Partnership, 

Petitioner, 

MTT Docket No. 26-000941 

City of Jackson, 

Respondent. 

/ 

Stipulation for Entry of Consent Judgment 

The parcel is located in Jackson County. 

The case is pending in the X Entire Tribunal OR Small Claims Division. 

Property Parcel No: 4-007400000. 

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

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2026 

$1,023,600 

$511,800 

$511,800 

S. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2026 

$500,000 

$250,000 

$250,000 

If stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or 

years (attach additional page if necessary): 

List separately any special terms or conditions being proposed by the parties that would 

affect the execution of this Consent Judgment including, but not limited to, the joint 

payment of the refund, the waiver of interest, etc.: 

76733142.1

Page 2

Honigman LLP 

Attorneys for Petitioner, 

By 

fod ie J. Cook ( 

660 Woodward Avenue 

2290 First National Bldg. 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com 

Dated: August 18, 2026 

76733142.1 

Jackson City Attorney’s Office 

Attorneys for Respondent, 

By: 

Matthew M. Hagerty (P6015) 

Mark M. Porterfield (P57917) 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

Dated: August 18, 2026

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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: 26-000941

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

Party Filing Document 

Joint

Files

Document Type: Stip for Consent Judgment

Attachment File Name: Stip for CJ - 310 Mechanic Lofts LDHA Jackson (26-000941)

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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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

NOTICE OF JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

310 S Mechanic Limited Dividend 

Housing Association Limited 

Partnership,

Petitioner,

v

 

 

City Of Jackson,

Respondent.

 MTT Docket No. 26-000941

Please be advised that 26-000941 has been placed on a two-week Prehearing General 

Call commencing July 01, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website.

Page 2

MTT Docket No. 26-000941

Page 2 of 3

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by March 4, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by March 4, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 4, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

July 1, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain

Page 3

MTT

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

______________________________________________________________________________ 

 

310 S. Mechanic Lofts Limited Dividend 

Housing Association Limited Partnership, 

 

 

 

 

Petitioner, 

 

 

MTT Docket No. 26-000941 

 

 

 

 

 

 

 

Parcel No. 4-007400000 

 

 

-vs- 

 

 

 

 

 

ANSWER TO PETITION AND 

 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

City of Jackson, 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

_____________________________________________________________________________/ 

Honigman LLP 

By: Jackie J. Cook (P68781) 

Attorney for Petitioner 

2290 First National Bldg. 

660 Woodward Ave. 

Detroit, MI 48226 

(313)465-7270 

jcook@honigman.com 

JACKSON CITY ATTORNEY’S OFFICE 

By: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

____________________________________________________________________________/ 

 

RESPONDENT CITY OF JACKSON’S 

ANSWER TO PETITION 

 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and for its Answer to Petitioner’s Petition, states as follows: 

1. Respondent neither admits nor denies the allegation contained in Paragraph 1 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

2. Respondent admits the allegation contained in Paragraph 2 of Petitioner’s Petition. 

3. Respondent admits the allegations contained in Paragraph 3 of Petitioner’s Petition. 

4. Respondent admits the allegations contained in Paragraph 4 of Petitioner’s Petition.

Page 2

2 

 

5. Respondent admits the allegations contained in Paragraph 5 of Petitioner’s Petition. 

6. Respondent admits the allegations contained in Paragraph 6 of Petitioner’s Petition. 

7. Respondent admits the allegations contained in Paragraph 7 of Petitioner’s Petition. 

8. Respondent neither admits nor denies the allegation contained in Paragraph 8 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

9. Respondent neither admits nor denies the allegation contained in Paragraph 9 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

10. Respondent neither admits nor denies the allegation contained in Paragraph 10 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

11. Respondent neither admits nor denies the allegation contained in Paragraph 11 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

12. Respondent denies the allegations contained in Paragraph 12(a) through (d) of 

Petitioner’s Petition as untrue. 

WHEREFORE, Respondent City of Jackson requests this Honorable Tribunal dismiss 

Petitioner’s Petition in its entirety, that it assess actual costs and attorney fees against Petitioner 

for costs incurred in responding to the Petition, and further requests all other relief the Tribunal 

deems to be just and equitable. 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

 

DATED: May 28, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

Page 3

3 

 

 

 

 AFFIRMATIVE DEFENSES 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and states the following Affirmative Defenses alternatively and consecutively: 

1. 

The subject property’s assessed, true cash, and taxable values are levied in 

accordance with the Michigan General Property Tax Act and Michigan Constitution. 

2. 

The subject property is assessed in accordance with generally accepted assessing 

standards. 

3. 

The subject property is assessed at no more than 50% of its true cash value. 

4. 

Petitioner has failed to state a claim upon which relief can be granted. 

5. 

Respondent reserves the right to amend its affirmative defenses through the 

conclusion of discovery. 

Respectfully submitted, 

 

 

 

DATED: May 28, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

Page 4

4 

 

 

 

CERTIFICATE OF SERVICE 

 

STATE OF MICHIGAN 

 

) 

) ss 

COUNTY OF JACKSON 

 

) 

 

The undersigned certifies under penalty of perjury that on May 28, 2026 he served copies of 

Respondent City of Jackson’s Answer to Petition and Affirmative Defenses upon the 

Petitioner by first class mail with postage fully prepaid to the following address: 

 

 Jackie J. Cook (P68781) 

 Attorney for Petitioner 

 2290 First National Bldg. 

660 Woodward Ave. 

Detroit, MI 48226 

 

 

 

 

 

 

 

 

 

 

 

 

DATED: May 28, 2026 

 

 

 

________________________________ 

 

Matthew M. Hagerty (P66015) 

 

Office of

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Page 1

26-0014 

75573363.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

310 S Mechanic Lofts Limited Dividend 

Housing Association Limited Partnership, 

Petitioner, 

v 

City of Jackson,

Respondent. 

MTT Docket No. ________ 

Parcel No. 4-007400000 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

310 S Mechanic Lofts Limited Dividend Housing Association Limited Partnership 

(“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1.

Petitioner's principal office address is 2627 E. Beltline Ave. SE, Suite 200, Grand 

Rapids, MI 49546. 

2.

The subject real property, tax parcel number 4-007400000, is located at 310 S. 

Mechanic, Jackson, MI, in Jackson County ("Petitioner's Property"). 

3.

Respondent, City of Jackson, assesses and collects property taxes on Petitioner's 

Property.

Page 2

2 

75573363.1 

4.

In 2026, Respondent’s board of review set the taxable value of Petitioner's Property 

at $511,800 and assessed Petitioner's Property at $511,800. 

5.

The assessment 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 commercial purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

commercial 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.

No board of review protest was required for Petitioner’s Property. 

12.

The 2026 assessment – including the state equalized and taxable values – imposed 

on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode 

of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, 

because they 

(a) 

Exceed amounts permitted by the Michigan Constitution and applicable statutes; 

(b) 

Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

(c) 

Are based on the application of wrong principles and an erroneous determination 

of the true cash value of that portion of Petitioner's Property that is taxable under 

Michigan law, if any; and

Page 3

3 

75573363.1 

(d) 

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 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property from 

$511,800 to $200,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 14, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Respondent 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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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

310 S Mechanic Limited Dividend Housing Association Limited 

Partnership

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

2627 E. Beltline Ave. SE

City or Town

Grand Rapids

State

Michigan

ZIP Code

49544

Telephone Number

2485668300

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detriot

State

Michigan

ZIP Code

48226

Telephone Number

3134657270

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

jcook@honigman.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]

310 S. Mechanic

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Jackson

Michigan

49201

Taxing Authority (City or Township)

City Of Jackson (JACKSON) 

County

Jackson

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:

4-007400000

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:

511800

Current Taxable Value as established by the Board of Review:

511800

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

400000

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

200000

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/ Jackie J. Cook

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051485369084

Supporting Waiver Documents:

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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

310 S Mechanic Limited Dividend Housing Association Limited Partnership, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000941

City Of Jackson, 

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: June 25, 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.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

310 S Mechanic Lofts Limited Dividend 

Housing Association Limited Partnership, 

Petitioner, 

MTT Docket No. Alo ) Oo oF o ( 

Parcel No. 4-007400000 

Vv 

City of Jackson, 

Respondent. 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com 

Proof of Service 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

that on s/ 

/ S/ “b 

, she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

5 Ae A Q Fey 4 

1/4 

7 

Lisa Joseph 

26-0014 

75573363.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

JACKSON 

161 W. MICHIGAN AVENUE 

JACKSON, MI 49201-1324 

ASSESSOR 

JACKSON 

161 W. MICHIGAN AVENUE 

JACKSON, MI 49201-1324 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

JACKSON COUNTY 

120 WEST MICHIGAN 

JACKSON, MI 49201 

DIRECTOR OF EQUALIZATION 

JACKSON COUNTY 

120 WEST MICHIGAN 

JACKSON, MI 49201 

SECRETARY OF SCHOOL BOARD 

JACKSON PUBLIC SCHOOLS 

522 WILDWOOD AVENUE 

JACKSON, MI 49201-1013 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0022 

75573363.1

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Page 1

1 of 1

Docket #: 26-000941

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

26-0014 

75573363.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

310 S Mechanic Lofts Limited Dividend 

Housing Association Limited Partnership, 

Petitioner, 

v 

City of Jackson,

Respondent. 

MTT Docket No. ________ 

Parcel No. 4-007400000 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

310 S Mechanic Lofts Limited Dividend Housing Association Limited Partnership 

(“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1.

Petitioner's principal office address is 2627 E. Beltline Ave. SE, Suite 200, Grand 

Rapids, MI 49546. 

2.

The subject real property, tax parcel number 4-007400000, is located at 310 S. 

Mechanic, Jackson, MI, in Jackson County ("Petitioner's Property"). 

3.

Respondent, City of Jackson, assesses and collects property taxes on Petitioner's 

Property.

Page 2

2 

75573363.1 

4.

In 2026, Respondent’s board of review set the taxable value of Petitioner's Property 

at $511,800 and assessed Petitioner's Property at $511,800. 

5.

The assessment 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 commercial purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

commercial 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.

No board of review protest was required for Petitioner’s Property. 

12.

The 2026 assessment – including the state equalized and taxable values – imposed 

on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode 

of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, 

because they 

(a) 

Exceed amounts permitted by the Michigan Constitution and applicable statutes; 

(b) 

Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

(c) 

Are based on the application of wrong principles and an erroneous determination 

of the true cash value of that portion of Petitioner's Property that is taxable under 

Michigan law, if any; and

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3 

75573363.1 

(d) 

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 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property from 

$511,800 to $200,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 14, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Respondent 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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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

310 S Mechanic Limited Dividend Housing Association Limited 

Partnership

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

2627 E. Beltline Ave. SE

City or Town

Grand Rapids

State

Michigan

ZIP Code

49544

Telephone Number

2485668300

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detriot

State

Michigan

ZIP Code

48226

Telephone Number

3134657270

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

jcook@honigman.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]

310 S. Mechanic

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Jackson

Michigan

49201

Taxing Authority (City or Township)

City Of Jackson (JACKSON) 

County

Jackson

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:

4-007400000

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:

511800

Current Taxable Value as established by the Board of Review:

511800

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

400000

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

200000

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/ Jackie J. Cook

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051485369084

Supporting Waiver Documents:

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