588 Northwestern LLC, Petitioner Vs. City Of Southfield, 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 

588 Northwestern LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001881 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ 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, 2020, through June 30, 2022, at the rate of 4.25%, 

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) 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%, (v) after December 31, 2023, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001881 

Page 2 of 2 

 

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

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

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

of 8.66%. 

 

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. 

 

 

 

 

 

 

 

 

 

By _____________________________ 

Entered: July 28, 2025 

jc 

 

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 

588 Northwestern, LLC, 

Petitioner, 

MTT Docket No. 25-001881 

City of Southfield, 

Respondent. 

/ 

Stipulation for Entry of Consent Judgment 

The parcel is located in Oakland County. 

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

Property Parcel No: 76-24-18-226-039. 

The values for the property identified above as established by Respondents Board of 

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$5,398,120 

$2,699,060 

$2,699,060 

5. 

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 

2025 

$3,400,000 

$1,700,000 

$1,700,000 

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

Page 2

MTT Docket No. 25-001881 

Stipulation for Entry of Consent Judgment 

HONIGMAN LLP 

Attorneys for Petitioner 

By: 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Dated: June 23, 2025 

CITY OF SOUTHFIELD 

Representative for Respondent 

# 

By: 

Justin Prybylski 

City Assessor 

26000 Evergreen Rd. 

P.O. Box 2055 

Southfield, MI 48037-2055 

jprybylski@cityofsouthfield.com 

Dated: June 23, 2025

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Page 1

RECEIVED 

JON 0620053 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

588 Northwestern LLC, 

Petitioner, 

- 

MTT Docket No. A510! 

X 

5 

( 

Vv. 

Parcel No. 76-24-18-226-039 

City of Southfield, 

Respondent, 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

jcook@honigman.com 

/ 

Proof of Service 

Lisa Joseph states that on 

S / 30 [2S 

,shedid serve a copy of Petitioner's Petition, 

with docket number, upon the parties named on the attached list. 

Dated: 

S 

[29 

2S 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

SOUTHFIELD 

26000 EVERGREEN ROAD 

SOUTHFIELD, MI 48076 

ASSESSOR 

SOUTHFIELD 

26000 EVERGREEN ROAD 

SOUTHFIELD, MI 48076 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, M1 48341-0413 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

SECRETARY OF SCHOOL BOARD 

SOUTHFIELD PUBLIC SCHOOLS 

24661 LAHSER ROAD 

SOUTHFIELD, MI 48033-3238 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0052

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Page 1

25-0029 

60631836.2 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

588 Northwestern LLC, 

Petitioner, 

v. 

City of Southfield, 

Respondent, 

MTT Docket No. ________ 

Parcel No. 76-24-18-226-039 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

Petition 

588 Northwestern LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office is at 28588 Northwestern Highway, Southfield, 

Michigan 48034. Petitioner is a party in interest with respect to property taxes on tax parcel 

number 76-24-18-226-039 ("Petitioner's Property"), with an address of 28588 Northwestern Hwy., 

located in Oakland County, Michigan. 

2.

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

Property.

Page 2

2 

60631836.2 

3.

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$2,699,060 and assessed Petitioner's Property at $2,699,060, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

6.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7.

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

8.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and,

Page 3

3 

60631836.2 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $2,699,060 to $1,150,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $2,699,060 to $1,150,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: May 30, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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

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

588 Northwestern LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001881

City Of Southfield, 

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 28, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

588 Northwestern, LLC, 

Petitioner, 

MTT Docket No. 25-001881 

City of Southfield, 

Respondent. 

/ 

Stipulation for Entry of Consent Judgment 

The parcel is located in Oakland County. 

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

Property Parcel No: 76-24-18-226-039. 

The values for the property identified above as established by Respondents Board of 

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$5,398,120 

$2,699,060 

$2,699,060 

5. 

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 

2025 

$3,400,000 

$1,700,000 

$1,700,000 

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

Page 2

MTT Docket No. 25-001881 

Stipulation for Entry of Consent Judgment 

HONIGMAN LLP 

Attorneys for Petitioner 

By: 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Dated: June 23, 2025 

CITY OF SOUTHFIELD 

Representative for Respondent 

# 

By: 

Justin Prybylski 

City Assessor 

26000 Evergreen Rd. 

P.O. Box 2055 

Southfield, MI 48037-2055 

jprybylski@cityofsouthfield.com 

Dated: June 23, 2025

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Page 1

MTT Docket No. 25-001881 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

588 NORTHWESTERN LLC, 

Petitioner, 

V. 

MTT Docket No.: 25-001881 

| 

Parcel No(s): 76-24-18-226-039 

CITY OF SOUTHFIELD, 

Respondent 

/ 

Stewart Mandell (P33781) 

Justin E. Prybylski, MMAO(4) 

Attorney 

for Petitioner 

City Assessor 

Honigman LLP 

City of Southfield 

39400 Woodward Avenue, Suite 101 

26000 Evergreen Rd. 

Bloomfield Hills, MI 

48304 

Southfield, MI 

48076 

slmandell@honigman.com 

jprybylski@cityofsouthfield.com 

jcook@honigman.com 

(248) 

796-5230 

(313) 

465-7420 

RESPONDENT’S ANSWER TO PETITIONER’S 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

NOW COMES Respondent, CITY OF SOUTHFIELD, by and through its Representative, and for 

its Answer to Petitioner’s Petition, states as follows: 

I. 

As to the allegations contained in Paragraph 1, Respondent can neither admit, nor 

deny the same as true, for the reason that it’s without sufficient knowledge or information, upon 

which to form a belief as to the truth thereof and leaves Petitioner to its strict proofs. 

2. 

As to the allegations contained in Paragraph 2, Respondent admits the same as true;

Page 2

MTT Docket No. 25-001881 

4. 

As to the allegations contained in Paragraph 4, Respondent admits the same as true; 

the property(s) identified herein are classified commercial real property and used for commercial 

purposes. 

5: 

As to the allegations contained in Paragraph 5, Respondent can neither admit, nor 

deny the same as true, for the reason it’s without sufficient knowledge, or information, upon which 

to form a belief as to the truth thereof and leaves Petitioner to its strict proofs. 

6. 

As to the allegations contained in Paragraph 6, Respondent can neither admit, nor 

deny the same as true, for the reason it’s without sufficient knowledge, or information, upon which 

to form a belief as to the truth thereof and leaves Petitioner to its strict proofs. 

7. 

As to the allegations contained in Paragraph 7, Respondent admits the same as true; 

the property(s) identified herein were not required to appeal to the March Board of Review, as 

required under MCL 205.735a(3). 

8. 

As to the allegations contained 

in Paragraph 8, Respondent denies Petitioner’s 

allegations as untrue and leaves Petitioner to its strict proofs. 

WHEREFORE, Respondent, CITY OF SOUTHFIELD, respectfully requests that this 

Honorable Tribunal affirm Respondent’s assessment and taxable value of the subject property, that 

Petitioner’s Petition be dismissed with prejudice and that Respondent be granted costs and attorney 

fees so wrongfully sustained. 

Respectfully submitted, 

Tg 

Dated: July 24, 2025

Page 3

MTT Docket No. 25-001881 

AFFIRMATIVE DEFENSES 

For its further Answer to Petitioner's Petition and by way of its Affirmative Defenses, 

Respondent respectfully requests unto this Honorable Tribunal as follows: 

I. 

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

against Respondent and to support its claim for relief. 

| 

| 

2. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

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

3. 

Petitioner fails to allege that the mode and method of appraising its property failed 

to conform to the mode and method applied in the case of all of the properties in the Respondent’s 

taxing unit for the year in question. 

4. 

Petitioner fails to allege specific and sufficient facts to establish the true cash value, 

assessed value and taxable value of its property. 

5. 

Petitioner fails to allege specific and sufficient facts to support its allegation that 

the assessed value of its property, as equalized, is at a factor other than 50% and also fails to allege 

specific and sufficient facts to support its allegations that the property’s taxable value is improper. 

6. 

Petitioner fails to show that any rate other than 50% after equalization was applied 

to the true cash value of its property, as well as to the properties of all others to arrive at the 

respective equalized assessments. 

7. 

Petitioner, 

in 

essence, 

asks 

that 

this Honorable Tribunal 

grant 

it 

an 

illegal 

preference 

by application 

of a method of assessment different from 

that employed 

in 

the

Page 4

MTT Docket No. 25-001881 

9. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

10. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

11. 

Respondent reserves the right to add to these Affirmative Defenses any new 

Affirmative Defenses that discovery reveals. 

WHEREFORE, Respondent, CITY OF SOUTHFIELD, denies that Petitioner is entitled to 

the relief it seeks and respectfully requests that the Respondent’s assessment and taxable value of 

the subject property be affirmed, and that Petitioner’s Petition be dismissed with prejudice and that 

Respondent be granted costs and attorney fees so wrongfully sustained. 

Dated: July 24, 2025 

Respectfully submitted, 

- 

Justin E. Prybylski, MMAO(4) 

Assessor 

|| City of Southfield 

26000 Evergreen Rd 

Southfield, MI 48076 

0: (248) 796-5230 

iprybylski@cityofsouthfield.com

Page 5

MTT Docket No. 25-001881 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

588 NORTHWESTERN LLC, 

Petitioner, 

V. 

MTT Docket No.: 25-001881 

Parcel No(s): 76-24-18-226-039 

CITY OF SOUTHFIELD, 

Respondent 

Proof of Service 

Justin E. Prybylski, MMAO(4), Assessor for the City of Southfield, certifies that on Thursday, 

July 24, 2025, copies of Respondent’s Answer to Petitioner’s Petition were served to: 

Stewart Mandell, Attorney for Petitioner

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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. 25-001881

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Southfield (OAKLAND)

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

Justin

M.I.

E

Last Name

Prybylski

Firm Name (if any)

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

26000 Evergreen Rd.

City or Town

Southfield

State

Michigan

ZIP Code

48076

Telephone Number

248-796-5240

Fax Number

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

jprybylski@cityofsouthfield.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Justin E. Prybylski, MMAO(4), MCPPE

/s/

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Page 1

25-0029 

60631836.2 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

588 Northwestern LLC, 

Petitioner, 

v. 

City of Southfield, 

Respondent, 

MTT Docket No. ________ 

Parcel No. 76-24-18-226-039 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

Petition 

588 Northwestern LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office is at 28588 Northwestern Highway, Southfield, 

Michigan 48034. Petitioner is a party in interest with respect to property taxes on tax parcel 

number 76-24-18-226-039 ("Petitioner's Property"), with an address of 28588 Northwestern Hwy., 

located in Oakland County, Michigan. 

2.

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

Property.

Page 2

2 

60631836.2 

3.

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$2,699,060 and assessed Petitioner's Property at $2,699,060, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

6.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7.

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

8.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and,

Page 3

3 

60631836.2 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $2,699,060 to $1,150,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $2,699,060 to $1,150,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: May 30, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.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

588 Northwestern LLC

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

28588 Northwestern Highway

City or Town

Southfield

State

Michigan

ZIP Code

48034

Telephone Number

2485668300

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

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

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

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

slmandell@honigman.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 Southfield (OAKLAND)

County

Oakland

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:

76-24-226-039

Classification of Property: Real 

Commercial

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

2699060

Current Taxable Value as established by the Board of Review:

2699060

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

2300000

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

1150000

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/ Stewart L. Mandell

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.