800 E. Court Street Village Limited Dividend Housing Association Limited PA, Petitioner Vs. Michigan Department Of Treasury, Respondent
- Petitioner
- 800 E. Court Street Village Limited Dividend Housing Association Limited PA
- Respondent
- Michigan Department Of Treasury, City Of Flint
Case overview
- Docket number
- 24-004101-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Genesee
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 16 | Order of Dismissal | Not recorded | Not recorded | 09/10/2025 | Not recorded | Download |
| 15 | Proof of Service of Misc Documents was received. | Not recorded | Not recorded | 09/10/2025 | Not recorded | Download |
| 14 | A response to motion was filed. | Not recorded | Not recorded | 09/10/2025 | Not recorded | Download |
| 13 | Notice of Filing of Motion to Withdraw | Not recorded | Not recorded | 09/05/2025 | Not recorded | Download |
| 12 | Motion to Withdraw Appeal was received. | PET | Not recorded | 09/03/2025 | $0.00 | Download |
| 11 | Prehearing General Call | Not recorded | Not recorded | 02/18/2025 | Not recorded | Download |
| 10 | ET Case Info Sheet | Not recorded | Not recorded | 01/21/2025 | Not recorded | Download |
| 9 | Proof of Service of Misc Documents was received. | Not recorded | Not recorded | 01/17/2025 | Not recorded | Download |
| 8 | Answer was received | Not recorded | Not recorded | 01/17/2025 | Not recorded | Download |
| 7 | ET Case Info Sheet | Not recorded | Not recorded | 01/17/2025 | Not recorded | Download |
| 6 | Proof of service of petition was received. | PET | Not recorded | 12/26/2024 | Not recorded | Download |
| 5 | Proof of service of petition was received. | PET | Not recorded | 12/24/2024 | Not recorded | Download |
| 4 | Petition has been verified | PET | 2 | 11/19/2024 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 11/19/2024 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 11/15/2024 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 11/15/2024 | $600.00 | Download |
Documents
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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 800 E. Court Street Village Limited Dividend Housing Association Limited Pa, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 24-004101 Michigan Department of Treasury, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner has filed a Motion to Withdraw the petition and Respondent has filed a response concurring with the requested withdrawal. Therefore, IT IS ORDERED that the case is DISMISSED. This order resolves all pending issues and closes the case. APPEAL RIGHTS If you disagree with the final decision in this case, you may file a motion for reconsideration with the Tribunal or a claim of appeal with the Michigan Court of Appeals. A motion for reconsideration must be filed with the Tribunal with the required filing fee within 21 days from the date of entry of the final decision. Because the final decision closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing system; it must be filed by mail or personal service. The fee for the filing of such motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless the Small Claims decision relates to the valuation of property and the property had a principal residence exemption of at least 50% at the time the petition was filed or the decision relates to the grant or denial of a poverty or disabled veterans exemption and, if so, there is no filing fee. You are required to serve a copy of the motion on the opposing party by mail or personal service or by email if the opposing party agrees to electronic service, and proof demonstrating that service must be submitted with the motion. Responses to motions for reconsideration are prohibited and there are no oral arguments unless otherwise ordered by the Tribunal. Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If
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MTT Docket No. 24-004101 Page 2 of 8 the claim is filed more than 21 days after the entry of the final decision, it is an “appeal by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the record on appeal. There is no certification fee. By:___________________________________ Patricia L. Halm, Tribunal Chair Entered: September 10, 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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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 800 E. Court Street Village Limited Dividend Housing Association Limited Pa, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 24-004101 Michigan Department of Treasury, Respondent. ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner has filed a Motion to Withdraw the petition and Respondent has filed a response concurring with the requested
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MTT
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STATE
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. COURT STREET VILLAGE LIMITED DIVIDEND HOUSING ASSOCIATION LIMITED PARTNERSHIP MTT Docket No. 24–004101–TT Petitioner, v CITY OF FLINT, and MICHIGAN DEPARTMENT OF TREASURY Respondents. _____________________________________________________________________________/ Stewart L. Mandell (P33781) HONIGMAN, LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, Michigan 48304 (313) 465–7420 slmandell@honigman.com Joseph N. Kuptz (P68623) Attorney for Respondent City of Flint City of Flint Law Department 1101 S. Saginaw St., 3rd Floor Flint, MI 48502 (810) 237–2085 jkuptz@cityofflint.com B. Thomas Golden (P70822) Assistant Attorney General Revenue and Tax Division Attorneys for Respondent Michigan Department of Treasury P.O. Box 30754 Lansing, MI 48909 (517) 335–7584 goldent2@michigan.gov _____________________________________________________________________________/ PROOF OF SERVICE Michelle Moore, states that on this 10th day of September 2025, I served Response to Motion to Withdraw, along with a copy of this Proof of Service
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2 upon the following: Stewart L. Mandell Honigman, LLP 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 Joseph N. Kuptz 1101 S. Saginaw St., 3rd Floor Flint, MI 48502 by depositing the same in a receptacle of the United States Post Office in the City of Lansing, Michigan, enclosed in an envelope, plainly addressed, bearing postage fully prepaid. I declare that the above statement is true to the best of my knowledge, information, and belief. /s/ Michelle Moore Michelle Moore, Legal Secretary
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STATE OF MICHIGAN DEPARTMENT OF ATTORNEY GENERAL P.O. BOX 30754 LANSING, MICHIGAN 48909 DANA NESSEL ATTORNEY GENERAL September 10, 2025 Michigan Tax Tribunal Attn: Samantha M. Welton, Chief Clerk 611 W. Ottawa Street, 4th Floor P.O. Box 30232 Lansing, MI 48909 Re: 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership v City of Flint and Michigan Dep’t of Treasury Michigan Tax Tribunal Docket No. 24-004101-TT Dear Clerk: Enclosed for submission, please find Response to Motion to Withdraw and a Proof of Service, regarding the above referenced case. If you have any questions, please do not hesitate to contact me. Sincerely, /s/ B. Thomas Golden B. Thomas Golden Assistant Attorney General Revenue and Tax Division P.O. Box 30754 Lansing, Michigan 48909 (517) 335-7584 BTG/mm Cc: City of Flint and Stewart L. Mandell Honigman, LLP (Via First-Class U.S. Mail)
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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 Petitioner(s) v MTT Docket No. _____________________________, Respondent(s) RESPONSE TO MOTION TO WITHDRAW APPEAL 1. Petitioner filed a Motion to Withdraw Appeal on __________________________. 2. Choose one: Respondent concurs with the withdrawal of the appeal. Respondent objects to the withdrawal of the appeal. 3. If you checked the box that you object to the withdrawal, explain here: ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ _________________________________________ Party/Representative (sign here) _________________________________________ [Print/type name of person signing] I certify that on this date I served a copy of this request on the opposing party or their representative. ___________________________ ________________________________ Date Signature 800 E. Court Street Village Limited Dividend Housing Association LP 24-004101 Michigan Department of Treasury September 3, 2025 /s/ B. Thomas Golden B. Thomas Golden 09/10/2025 /s/ Michelle Moore
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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 800 E. Court Street Village Limited Dividend Housing Association Limited Pa, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 24-004101 Michigan Department of Treasury, Respondent. NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above- captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or representatives), Respondent has seven days from the service of the motion to file a response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of the case or by objecting to the motion. If Respondent does not timely submit a concurrence or objection to the request, it will be deemed to be a concurrence and the request will be granted, unless otherwise ordered by the Tribunal. If the request is granted, the case will be dismissed. If a request is not granted or the Tribunal has not notified you that it has been granted, you are required to attend the hearing. For your convenience, you may use the Tribunal’s form “Response to Motion to Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small Claims” page, depending on the division in which the case is pending. To submit the response, please fill out the form and file it with the Tribunal by e-mail or e-filing.1 By: Tribunal Clerk__________ Entered: September 5, 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 1 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the efficient administration of justice.
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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 800 E. Court Street Village Limited Dividend Housing Association Limited Pa, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 24-004101 Michigan Department of Treasury, Respondent. NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above- captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or representatives), Respondent has seven days from the service of the motion to file a response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of the case or by objecting to the motion. If Respondent does not timely submit a concurrence or objection to the request, it will be deemed to be a concurrence and the request will be granted, unless otherwise ordered by the Tribunal. If the request is granted, the case will be dismissed. If a request is not granted or the Tribunal has not notified you that it has been granted, you are required to attend the hearing. For your convenience, you may use the Tribunal’s form “Response to Motion to Withdraw Appeal” located on the Tribunal’s website. To access the form, please go
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STA
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership Petitioner, v City of Flint and Michigan Department of Treasury, Respondents. MTT Docket No. 24-004101 Stewart L. Mandell (P33781) Honigman LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7420 slmandell@honigman.com Joseph N. Kuptz (P68623) Chief Deputy City Attorney Attorney for Respondent City of Flint City of Flint Law Department 1101 S. Saginaw St., 3rd Floor Flint, MI 48502 (810) 237-2085 jkuptz@cityofflint.com B. Thomas Golden (P70822) Assistant Attorney General Revenue and Tax Division Attorneys for Respondent Michigan Department of Treasury P.O. Box 30754 Lansing, MI 48909 (517) 335-7584 goldent2@michigan.gov Motion to Withdraw Appeal For this Motion, Petitioner states: Petitioner desires to withdraw its Petition and files this Motion pursuant to Tax Tribunal Rule 237(4), R 792.10237(4) and MCL 205.732(c). After reviewing this Motion, Respondents’ counsel confirmed that Respondents concur in the Tribunal granting the relief requested herein.
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2 61660780.1 WHEREFORE, Petitioner requests that the Tribunal enter an Order allowing the Petition to be withdrawn, or dismissing this case, with each party bearing its own costs. Respectfully submitted, HONIGMAN LLP, Attorneys for Petitioner By: __/s/ Stewart Mandell_____ Stewart Mandell (P33781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7420 Dated: September 2, 2025 slmandell@honigman.com
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3 61660780.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership Petitioner, v City of Flint and Michigan Department of Treasury, Respondents. MTT Docket No. 24-004101 Stewart L. Mandell (P33781) Honigman LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7420 slmandell@honigman.com Joseph N. Kuptz (P68623) Chief Deputy City Attorney Attorney for Respondent City of Flint City of Flint Law Department 1101 S. Saginaw St., 3rd Floor Flint, MI 48502 (810) 237-2085 jkuptz@cityofflint.com B. Thomas Golden (P70822) Assistant Attorney General Revenue and Tax Division Attorneys for Respondent Michigan Department of Treasury P.O. Box 30754 Lansing, MI 48909 (517) 335-7584 goldent2@michigan.gov Proof of Service Stewart Mandell states that that on September 2, 2025, he served a copy of the foregoing Motion to Withdraw Appeal via electronic mail, upon: Joseph N. Kuptz (P68623) Chief Deputy City Attorney Attorney for Respondent City of Flint City of Flint Law Department jkuptz@cityofflint.com B. Thomas Golden (P70822) Assistant Attorney General Revenue and Tax Division Attorneys for Respondent Michigan Department of Treasury goldent2@michigan.gov
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4 61660780.1 /s/ Stewart Mandell Dated: September 2, 2025 Stewart Mandell
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA ACTING 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 JANUARY 16 - 30, 2026 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE 800 E. Court Street Village Limited Dividend Housing Association Limited Pa, Petitioner, v Michigan Department of Treasury, Respondent. MTT Docket No. 24-004101 Please be advised that 24-004101 has been placed on a two-week Prehearing General Call commencing January 16, 2026. Parties will be notified at least one week before they are scheduled to appear. 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, as provided by TTR 237. In accordance with MCR 1.109(D)(9), as of January 1, 2021, 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. Please refer to the Tribunal’s FAQs and Glossary of Terms pages on our 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 September 19, 2025. 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.
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MTT Docket No. 24-004101 Page 2 of 2 IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing Statements by September 19, 2025. 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, as provided by TTR 237. IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on September 19, 2025, which means all discovery has been requested, all motions to compel have been filed and resolved, 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 January 16, 2026, which means all discovery has been requested, all motions to compel have been filed and resolved, and all requested or ordered discovery has been exchanged by that date. “Post-Valuation Disclosure” discovery is limited to the opposing
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ST
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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. 24-004101 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government City Of Flint (GENESEE) 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 B. M.I. Thomas Last Name Golden Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) Williams Building 2nd Fl ID Mail City or Town Lansing State Michigan ZIP Code 48909 Telephone Number 517-335-7584 Fax Number 517-241-2741 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) GoldenT2@michigan.gov Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: B. Thomas Golden /s/
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 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 Petitioner(s) v MOAHR Docket No. _____________________________, Respondent(s) PROOF OF SERVICE ___________________________________ states that on ___________________ he/she [Name of person serving/mailing petition] [date of service] served a copy of the ___________________ relative to the above-captioned matter upon: [Provide name and address of the party/people being served] ________________________________________________ ________________________________________________ ________________________________________________ ________________________________________________ _________________________________________ [Signature of person who is serving/mailing copy] _________________________________________ [Print/type name of person serving/mailing copy]
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. COURT STREET VILLAGE LIMITED MTT Docket No. 24-004101-TT DIVIDEND HOUSING ASSOCIATION LIMITED PARTNERSHIP, Petitioner, v. CITY OF FLINT and MICHIGAN DEPARTMENT OF TREASURY, Respondents. _____________________________________________________________________/ HONIGMAN LLP Stewart L. Mandell (P-33781) Daniel L. Stanley (P-57052) Attorneys for Petitioner 39400 Woodward Ave, Ste 101 Bloomfield Hills, MI 48304 (313) 465-7420 (517) 377-0714 slmandell@hongiman.com dstanley@honigman.com JOSEPH N. KUPTZ (P-68623) Chief Deputy City Attorney Attorney for Respondent City of Flint, only City of Flint Law Department 1101 S. Saginaw St., 3rd Floor Flint, MI 48502 (810) 237-2085 jkuptz@cityofflint.com _____________________________________________________________________/ ENTIRE TRIBUNAL PROPERTY TAX ANSWER Respondent, City of Flint, answers Petitioner’s Entire Tribunal Property Tax Petition as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted.
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5. Respondent admits that Petitioner has raised issues regarding the taxation of the property and an October 16, 2024 decision by the other Respondent in this matter, the Michigan Department of Treasury. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations. 11. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations. 12. Admitted. 13. Admitted. 14. Admitted. 15. Admitted. 16. This allegation is directed to the Respondent Michigan Department of Treasury. In further response, Respondent City of Flint lacks knowledge or information sufficient to form a belief as to the truth of the allegations. AFFIRMATIVE DEFENSES 1. Respondent, City of Flint, approved Petitioner’s request for exemption on July 3, 2024.
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2. Respondent reserves the right to amend or supplement its affirmative defenses in this matter. Respectfully submitted, Dated: January 17, 2025 /s/ Joseph N. Kuptz_________ Joseph N. Kuptz (P-68623) Chief Deputy City Attorney Attorney for Respondent 1101 S. Saginaw Street, 3rd Fl. Flint, MI 48502 (810) 237-2085
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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. 24-004101 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government City Of Flint (GENESEE) 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 Joseph M.I. N Last Name Kuptz Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 1101 S Saginaw St 3rd Floor City or Town Flint State Michigan ZIP Code 48502 Telephone Number 810-766-7146 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jkuptz@cityofflint.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Joseph N. Kuptz (P-68623) /s/
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58238829.2 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. COURT STREET VILLAGE LIMITED DIVIDEND HOUSING ASSOCIATION LIMITED PARTNERSHIP, Petitioner, v. MTT Docket No. 24-004101 MICHIGAN DEPARTMENT OF TREASURY AND CITY OF FLINT, Respondents. _______________________________________/ AMENDED PROOF OF SERVICE Lisa Joseph states that on December 24, 2024, she did serve a copy of Petitioner's Petition, with docket number, upon the parties named on the attached list. _____________________________________ Lisa Joseph
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58238829.2 BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK CITY OF FLINT 1101 S. SAGINAW FLINT, MI 48502 ASSESSOR CITY OF FLINT 1101 S. SAGINAW FLINT, MI 48502 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK GENESEE COUNTY 900 S. SAGINAW STREET FLINT, MI 48502-1514 DIRECTOR OF EQUALIZATION GENESEE COUNTY 900 S. SAGINAW STREET FLINT, MI 48502-1514 SECRETARY OF SCHOOL BOARD FLINT COMMUNITY SCHOOLS 923 E. KEARSLEY STREET FLINT, MI 48503-6106 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 24-0153
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership, Petitioner, v. MTT Docket No. 24-004101 [Parcel No(s). 41-18-209-058] Flint, Respondent. _____________________________________/ PROOF OF SERVICE Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and that on December 24, 2024, she did serve a copy of Petitioner's Petition, with docket number, upon the parties named on the attached list. _____________________________________ Lisa Joseph
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58238829.1 BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK FLINT 1101 S. SAGINAW FLINT, MI 48502 ASSESSOR FLINT 1101 S. SAGINAW FLINT, MI 48502 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK GENESEE COUNTY 900 S. SAGINAW STREET FLINT, MI 48502-1514 DIRECTOR OF EQUALIZATION GENESEE COUNTY 900 S. SAGINAW STREET FLINT, MI 48502-1514 SECRETARY OF SCHOOL BOARD FLINT COMMUNITY SCHOOLS 923 E. KEARSLEY STREET FLINT, MI 48503-6106 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 24-0153
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58002253.5 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. COURT STREET VILLAGE LIMITED DIVIDEND HOUSING ASSOCIATION LIMITED PARTNERSHIP, Petitioner, v MTT Docket No. ____________ Parcel No. 41-18-209-058 CITY OF FLINT and MICHIGAN DEPARTMENT OF TREASURY, Respondents. / PETITION Petitioner, 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership, through its attorneys, HONIGMAN LLP, says: 1. Petitioner’s current principal office address is 25200 Telegraph Road, Sue 400, Southfield, MI 48033. 2. Petitioner is a party in interest with respect to the property taxes for real property located in the City of Flint, County of Genessee, Michigan, with tax parcel number 41-18-209- 058 (“Petitioner’s Property”). 3. The Respondents are the City of Flint (the “City”), which assesses and collects property taxes on Petitioner’s Property, and the Michigan Department of Treasury (the “Department”). 4. The current 2024 assessed value, state equalized value and taxable value for Petitioner’s Property are $1,730,200.
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2 58002253.5 5. At issue is the property taxation resulting from both the aforementioned values and an October 16, 2024 decision by the Department. 6. Petitioner’s Property has an address of 800 E. Court Street, Flint, Michigan and is commonly known as Court Street Village. 7. Petitioner’s Property is a residential multifamily property that provides housing to low income seniors. 8. Petitioner has a regulatory agreement with the Michigan State Housing Development Authority, pursuant to which the dwelling units at Petitioner’s Property are required to be leased exclusively to low-income seniors. Additionally, Petitioner’s Property benefits from vouchers through Department of Housing and Urban Development (“HUD”) Section 202 and Section 8 programs. By virtue of the vouchers, tenants pay 30% of their income for rent, and HUD pays the difference between that and a HUD determined contract rent for each dwelling unit. Additionally, Petitioner received favorable below market financing terms. 9. The case involves a claim for property tax exemption under MCL 211.7d. 10. Petitioner’s Property consists of 149 residential housing units that were qualified, built or financed under section 202 of title II of the housing act of 1959, Public Law 86-372. Specifically, Petitioner’s Property received a $7,450,000 Capital Advance award from HUD under Section 202 of title II of the housing act of 1959. 11. Petitioner contends that Petitioner’s Property is and should continue to be exempt from taxation pursuant to MCL 211.7d. 12. Pursuant to the provisions of MCL 211.7d, Petitioner sought property tax exemption. 13. On July 3, 2024, the City approved Petitioner’s request for exemption.
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3 58002253.5 14. In addition to the City, the Department also is involved with processing claims for exemption under MCL 211.7d. 15. On October 16, 2024, the Department denied Petitioner’s claim for exemption of Petitioner’s Property. A copy of the Department’s denial letter is attached hereto. 16. The Department’s denial of exemption was unlawful and erroneous because Petitioner and Petitioner’s Property meet the requirements for exemption under MCL 211.7d. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: 1) holding that Petitioner’s Property is exempt from taxation pursuant to MCL 211.7d; and 2) requiring the correction of any applicable records and payment to Petitioner of any refunds attributable to such exemption, plus interest and costs. HONIGMAN LLP Attorneys for Petitioner By:/s/ Stewart L. Mandell Stewart L. Mandell (P33781) Daniel L. Stanley (P57052) 39400
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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 800 E. Court Street Village Limited Dividend Housing Association Limited Pa, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 24-004101 Michigan Department of Treasury, 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 221 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 229(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: November 19, 2024 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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58002253.5 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. COURT STREET VILLAGE LIMITED DIVIDEND HOUSING ASSOCIATION LIMITED PARTNERSHIP, Petitioner, v MTT Docket No. ____________ Parcel No. 41-18-209-058 CITY OF FLINT and MICHIGAN DEPARTMENT OF TREASURY, Respondents. / PETITION Petitioner, 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership, through its attorneys, HONIGMAN LLP, says: 1. Petitioner’s current principal office address is 25200 Telegraph Road, Sue 400, Southfield, MI 48033. 2. Petitioner is a party in interest with respect to the property taxes for real property located in the City of Flint, County of Genessee, Michigan, with tax parcel number 41-18-209- 058 (“Petitioner’s Property”). 3. The Respondents are the City of Flint (the “City”), which assesses and collects property taxes on Petitioner’s Property, and the Michigan Department of Treasury (the “Department”). 4. The current 2024 assessed value, state equalized value and taxable value for Petitioner’s Property are $1,730,200.
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2 58002253.5 5. At issue is the property taxation resulting from both the aforementioned values and an October 16, 2024 decision by the Department. 6. Petitioner’s Property has an address of 800 E. Court Street, Flint, Michigan and is commonly known as Court Street Village. 7. Petitioner’s Property is a residential multifamily property that provides housing to low income seniors. 8. Petitioner has a regulatory agreement with the Michigan State Housing Development Authority, pursuant to which the dwelling units at Petitioner’s Property are required to be leased exclusively to low-income seniors. Additionally, Petitioner’s Property benefits from vouchers through Department of Housing and Urban Development (“HUD”) Section 202 and Section 8 programs. By virtue of the vouchers, tenants pay 30% of their income for rent, and HUD pays the difference between that and a HUD determined contract rent for each dwelling unit. Additionally, Petitioner received favorable below market financing terms. 9. The case involves a claim for property tax exemption under MCL 211.7d. 10. Petitioner’s Property consists of 149 residential housing units that were qualified, built or financed under section 202 of title II of the housing act of 1959, Public Law 86-372. Specifically, Petitioner’s Property received a $7,450,000 Capital Advance award from HUD under Section 202 of title II of the housing act of 1959. 11. Petitioner contends that Petitioner’s Property is and should continue to be exempt from taxation pursuant to MCL 211.7d. 12. Pursuant to the provisions of MCL 211.7d, Petitioner sought property tax exemption. 13. On July 3, 2024, the City approved Petitioner’s request for exemption.
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3 58002253.5 14. In addition to the City, the Department also is involved with processing claims for exemption under MCL 211.7d. 15. On October 16, 2024, the Department denied Petitioner’s claim for exemption of Petitioner’s Property. A copy of the Department’s denial letter is attached hereto. 16. The Department’s denial of exemption was unlawful and erroneous because Petitioner and Petitioner’s Property meet the requirements for exemption under MCL 211.7d. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: 1) holding that Petitioner’s Property is exempt from taxation pursuant to MCL 211.7d; and 2) requiring the correction of any applicable records and payment to Petitioner of any refunds attributable to such exemption, plus interest and costs. HONIGMAN LLP Attorneys for Petitioner By:/s/ Stewart L. Mandell Stewart L. Mandell (P33781) Daniel L. Stanley (P57052) 39400
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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 800 E. Court Street Village Limited Dividend Housing Association Limited Partnership Home Address (No., Street, P.O. Box or Rural Route) 39400 Woodward Suite 101 City or Town Bloomfield Hills State Michigan ZIP Code 48304 Telephone Number 313-465-7420 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) 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 Flint (GENESEE) County Genesee If you are appealing more than one parcel, are they contiguous or adjoining?
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.) 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: 41-18-209-058 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 1730200 Current Taxable Value as established by the Board of Review: 1730200 What do you believe is the fair market value (also known as True Cash Value)? 0 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 0 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?
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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
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