Record Finder / 24-003473-TT
Michigan
Ams Lundy LLC, Petitioner V City Of Dearborn, Respondent
- Petitioner
- Ams Lundy LLC
- Respondent
- City Of Dearborn
Case overview
- Docket number
- 24-003473-TT
- Status
- Disposed
- CaseType
- SC Property
- Division
- Small Claims Division
- County
- Wayne
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 11 | Order of Dismissal | Not recorded | Not recorded | 11/01/2024 | Not recorded | Download |
| 10 | Motion to Withdraw Appeal was received. | PET | Not recorded | 10/31/2024 | $0.00 | Download |
| 9 | Appearance | RESP | Not recorded | 10/31/2024 | Not recorded | Download |
| 8 | ET Case Info Sheet | Not recorded | Not recorded | 10/31/2024 | Not recorded | Download |
| 7 | Order Holding Party in Default | Not recorded | Not recorded | 10/30/2024 | Not recorded | Download |
| 6 | Notice of No Action | Not recorded | Not recorded | 10/30/2024 | Not recorded | Download |
| 5 | Motion to Transfer to ET was received. | PET | Not recorded | 10/24/2024 | $25.00 | Download |
| 4 | Stipulated Sub of Counsel | PET | Not recorded | 10/23/2024 | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 09/17/2024 | Not recorded | Download |
| 2 | Notice of Docket Number SC | Not recorded | Not recorded | 09/17/2024 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/31/2024 | $300.00 | Download |
Documents
Order_of_Dismissal-Joint_Withdraw.2024-11-01_11-43-25.0000.pdfRead complete document text →
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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This Order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: November 1, 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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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This Order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: November 1, 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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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This Order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: November 1, 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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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This Order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: November 1, 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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AMS 24-003473 stip dismiss 10.31.24.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL AMS LUNDY LLC, Petitioner, v CITY OF DEARBORN, Respondent. MTT Docket No. 24-003473 _____________________________________________________________________________/ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 JEREMY J. ROMER (P77287) CITY OF DEARBORN Attorney for Respondent 16901 Michigan Avenue, Suite 14 Dearborn, MI 48126 (313) 943-2035 _____________________________________________________________________________/ STIPULATION TO DISMISS Petitioner and Respondent hereby stipulate to the dismissal of Petitioner’s appeal with prejudice and without costs or attorney fees to either party. Signature of Petitioner’s Authorized Representative /s/ Seth A O’Loughlin Laura M. Hallahan Seth A. O’Loughlin Hallahan & Associates, P.C. Signature of Respondent’s Authorized Representative /s/ Jeremy J Romer Jeremy J Romer City of Dearborn
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Appearance 10.31.24.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL AMS LUNDY LLC, Petitioner, v CITY OF DEARBORN, Respondent. MTT Docket No. 24-003473 _____________________________________________________________________________/ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com JEREMY J. ROMER (P77287) CITY OF DEARBORN Attorney for Respondent 16901 Michigan Avenue, Suite 14 Dearborn, MI 48126 (313) 943-2035 jromer@dearborn.gov _____________________________________________________________________________/ APPEARANCE OF COUNSEL PLEASE ENTER the appearance of JEREMY J. ROMER as counsel of record on behalf of Respondent in the above-entitled matter. Respectfully submitted, Jeremy J. Romer ________________________ JEREMY J. ROMER Attorney for Respondent 16901 Michigan Ave., Ste. 14 Dearborn, MI 48126 (313) 943-2035 (313) 943-2069 fax jromer@dearborn.gov
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Page 2 of 2 PROOF OF SERVICE The undersigned certifies that the foregoing was served upon all parties to the above cause to each of the attorneys/parties of record herein at their respective addresses disclosed on the pleadings on November 1, 2024. BY: U.S. Mail Telefacsimile Hand Delivered Overnight courier Federal Express E-mail Signature: _ Jeremy J. Romer Jeremy J. Romer
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10._Entire_Tribunal_Case_Information_Sheet_Must_Upload_Answer_.7ab7f13f-d0e2-4d3b-9159-52dab88d1f03.pdfRead complete document text →
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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. 24-003473 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government City Of Dearborn (WAYNE) 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 Jeremy M.I. J. Last Name Romer Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 16901 Michigan Ave Ste 14 City or Town Dearborn State Michigan ZIP Code 48126 Telephone Number 313-943-3086 Fax Number 313-943-2469 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jromer@ci.dearborn.mi.us Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Jeremy Romer /s/
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Order_Holding_Party_in_Default.2024-10-30_15-25-25.0000.pdfRead complete document text →
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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Respondent has failed to file an answer. See TTR 279. Respondent must file an answer within 14 days of the entry of this Order. Small Claims answer forms can be found on our website at www.michigan.gov/taxtrib. Therefore, IT IS ORDERED that Respondent is HELD IN DEFAULT. IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated above, within 14 days of the entry of this Order.i Failure to comply with this Order will result in the defaulted party being required to file a motion to set aside the default (with appropriate filing fee). By:_______________________________ Entered: October 30, 2024 Patricia L. Halm, Tribunal Chair
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MTT Docket No. 24-003473 Page 2 of 6 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 i “A submission by mail is considered filed on the date indicated by the United States Postal Service postmark on the envelope containing the submission. A submission without a postmark or with an illegible postmark is considered filed on the date the submission is received by the tribunal. A submission by commercial delivery service is considered filed on the date the submission is given to the commercial service for delivery to the tribunal as indicated by the receipt date on the package containing the submission. A submission by personal service is considered filed on the date the submission is received. A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal act, MCL 205.735a.” TTR 219(5)
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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Respondent has failed to file an answer. See TTR 279. Respondent must file an answer within 14 days of the entry of this Order. Small Claims answer forms can be found on our website at www.michigan.gov/taxtrib. Therefore, IT IS ORDERED that Respondent is HELD IN DEFAULT. IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated above, within 14 days of the entry of this Order.ii Failure to comply with this Order will result in the defaulted party being required to file a motion to set aside the default (with appropriate filing fee). By:_______________________________ Entered: October 30, 2024 Patricia L. Halm, Tribunal Chair
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MTT Docket No. 24-003473 Page 4 of 6 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 ii “A submission by mail is considered filed on the date indicated by the United States Postal Service postmark on the envelope containing the submission. A submission without a postmark or with an illegible postmark is considered filed on the date the submission is received by the tribunal. A submission by commercial delivery service is considered filed on the date the submission is given to the commercial service for delivery to the tribunal as indicated by the receipt date on the package containing the submission. A submission by personal service is considered filed on the date the submission is received. A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal act, MCL 205.735a.” TTR 219(5)
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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
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M
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Notice_of_No_Action_-Rep_Appearance.2024-10-30_11-43-49.0000.pdfRead complete document text →
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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. NOTICE OF NO ACTION TAKE NOTICE that the Tribunal has received a pleading (i.e., petition or answer) that identifies an attorney or authorized representative. However, the attorney or authorized representative did not sign the pleading, as required by TTR 223. As such, the attorney or authorized representative has not appeared on behalf of the party and an appearance must be filed.1 Until an appearance is filed, the answer, evidence, and all other documentation, must be served on the opposing party. Entered: October 30, 2024 By: Tribunal Clerk 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 See TTR 223(1).
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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. NOTICE OF NO ACTION TAKE NOTICE that the Tribunal has received a pleading (i.e., petition or answer) that identifies an attorney or authorized representative. However, the attorney or authorized representative did not sign the pleading, as required by TTR 223. As such, the attorney or authorized representative has not appeared on behalf of the party and an appearance must be filed.2 Until an appearance is filed, the answer, evidence, and all other documentation, must be served on the opposing party. Entered: October 30, 2024 By: Tribunal Clerk 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 2 See TTR 223(1).
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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 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. NOTICE OF NO ACTION TAKE NOTICE that the Tribunal has received a pleading (i.e., petition or answer) that identifies an attorney or authorized representative. However, the attorney or authorized representative did not sign the pleading, as required by TTR 223. As such, the attorney or authorized representative has not appeared on behalf of the party and an appearance must be filed.3 Until an appearance is filed, the answer, evidence, and all other documentation, must be served on the opposing party. Entered: October 30, 2024 By: Tribunal Clerk 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 3 See TTR 223(1).
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Joint Motion to Transfer_AMS Lundy_FINAL.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL AMS LUNDY LLC, Petitioner, v CITY OF DEARBORN, Respondent. Docket No. 24-003473 _____________________________________________________________________________/ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 JEREMY J. ROMER (P77287) CITY OF DEARBORN Attorney for Respondent 16901 Michigan Avenue, Suite 14 Dearborn, MI 48126 (313) 943-2035 _____________________________________________________________________________/ JOINT MOTION TO TRANSFER APPEAL TO ENTIRE TRIBUNAL DIVISION Petitioner and Respondent, by and through their respective attorneys, state the following in support of the above captioned Motion: 1. The above captioned appeal involves three contiguous commercial parcels located in the City of Dearborn. The combined 2024 taxable value of these three contiguous parcels as established by Respondent’s Board of Review exceeds $1 million. 2. The appeal is currently pending in the small claims division where it was originally filed. 3. The parties have discussed the appeal since its filing, and the retention of new counsel for Petitioner, and believe it would be more appropriate to have the case proceed in the entire tribunal division for several reasons.
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2 4. To begin, as a commercial property spanning three parcels a 30-minute hearing is impractical to resolve this valuation matter should a hearing be deemed necessary. 5. Second, placing the case in the entire tribunal division would allow for more efficient discovery between the parties. The conduction of which may assist the parties in reaching an amicable resolution to the above captioned appeal. 6. Third, the preparation of valuation disclosures and the conduction of an entire tribunal hearing, if necessary, should provide the parties with sufficient opportunity to present expert witness testimony regarding the value of each parcel at issue and, consequently, provide the Tribunal with the evidence it needs to make an independent determination of value. 7. Finally, the above captioned appeal should be moved to the Entire Tribunal as it appears that the parties’ final contentions of taxable value in dispute will likely exceed $100,000— depriving the small claims division of jurisdiction over this matter pursuant to TTR 263 and MCL 205.762. 8. The total taxable value in dispute for all three parcels at issue based on the values alleged in Petitioner’s Petition exceeds the $100,000 threshold. Additionally, Petitioner’s recently retained legal counsel believes Petitioner’s contentions of value as set forth in its Petition may be overstated—resulting in further disparity in the parties’ taxable value contentions. Accordingly, the above captioned appeal should be moved to the Entire Tribunal at this stage of the proceedings to ensure that the parties, as well as the Tribunal, do not incur time and expense adjudicating this matter only for the small claims division to be left without jurisdiction to issue a final decision and requiring the above captioned appeal be moved to the entire tribunal division at the eleventh hour. 9. TTR 273(1) allows for the requested relief and no hearing notice has been issued in the case. As Respondent has not filed an Answer, no costs have been incurred to Respondent in
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3 that respect furthering demonstrating the efficiency and practicality of a transfer at this stage of the proceedings. 10. In short, the parties believe that transferring the case to the entire tribunal division is in the interest of the efficient administration of justice, will aid the parties and the Tribunal, and will aid in the efficient handling of the case. There is good cause to grant the requested relief. WHEREFORE, the parties jointly request that this Honorable Tribunal enter an Order: A. Granting the parties’ Joint Motion to Transfer and reassign the above captioned matter to the Entire Tribunal Division; B. Requiring Petitioner file an Entire Tribunal Petition, proof of service, as well as pay the applicable difference in the required filing fee within 14 days of the Order; and C. Affirming that no costs be awarded to Respondent as part of the transfer. Respectfully Submitted, By:_/s/ Laura M. Hallahan__________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 Dated: October 23, 2024 By: _/s/ Jeremy J. Romer (w/permission)_ JEREMY J. ROMER (P77287) CITY OF DEARBORN Attorney for Respondent 16901 Michigan Avenue, Suite 14 Dearborn, MI 48126 (313) 943-2035 Dated: October 24, 2024
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Substitution_AMS Lundy_FINAL.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL AMS LUNDY LLC, Petitioner, v CITY OF DEARBORN, Respondent. MTT Docket No. 24-003473 _____________________________________________________________________________/ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 JEREMY J. ROMER (P77287) CITY OF DEARBORN Attorney for Respondent 16901 Michigan Avenue, Suite 14 Dearborn, MI 48126 (313) 943-2035 _______________________________________________________________________/ PETITIONER’S SUBSTITUTION OF AUTHORIZED REPRESENTATIVE Hallahan & Associates, P.C. substitutes in place of Sam Miller, PropTax America, as counsel for Petitioner AMS Lundy LLC. _/s/ Sam Miller (w/permission)______ Sam Miller PROPTAX AMERICA Dated: October 23, 2024 /s/ Laura M Hallahan______________ Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) HALLAHAN & ASSOCIATES, P.C. Dated: October 23, 2024
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MTT Docket No. 24-003473 2 PROOF OF MAILING On the date below I sent by electronic mail a copy of the foregoing Petitioner’s Substitution of Authorized Representative to: Jeremy J. Romer jromer@ci.dearborn.mi.us I declare that the statement above is true to the best of my information, knowledge and belief. /s/ Kelsea M. Melcher___________ Dated: October 23, 2024 Kelsea M. Melcher
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AMS Lundy LLC.pdfRead complete document text →
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“rege STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR PROPERTY TAX APPEAL PETITION FORM VALUATION / EXEMPTION / CLASSIFICATION APPEAL Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or Non-Property tax disputes. Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default. Section 1: Petitioner’s Contact Information First Name M.1. Last Name/Company Name AMS LUNDY LLC Mailing Address (No., Street, P.O. Box or Rural Route) City or Town State 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: Petitioner’s Attorney/Authorized Representative’s Contact Information } First Name M.1. Last Name Sam Miller ninfo:4601 Firm Name (if an} " LETHE i “Prop Tax America Address (No., Street, P.O. Box or Rural Route) 26923 Havelock City or Town State ZIP Code Dearborn Heights MI 48127 Telephone Number Fax Number 313-377-1447 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) nassco123@yahoo.com Section 3: Subject Property Information How many If you are appealing more than one parcel, are they contiguous or adjoining? parcelsareyou | [7] vest [] No** appealing? *If yes, use a multiple parcel form for information regarding any contiguous parcels. **If no, you must file separate appeals for each non-contiguous or non-adjoining parcel or you will be defaulted.
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STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
Section 4: Issues Being Appealed (check all that apply)
True Cash and Taxable Value
[J Poverty Exemption
[1 Taxable Value Only (calculation)
{1} Disabled Veterans Exemption
{J Uncapping of Taxable Value
J Eligible Manufacturing Personal Property (ESA)
[1 Exemption from Taxation (other than the denial of a
[1 Classification
Principal Residence or Qualified Agricultural Exemption)
Section 5: Explain the Reason for this Appeal
SEV is too high
Section 6: Jurisdictional Issues
Year(s) you are appealing:
2024
Did you protest the assessment at a Board of Review (BOR)? [mm] Yes
No
If Yes, check which BOR you attended AND attach the BOR decision: [] March
[1] duly
[J] December
If No, check the applicable reason(s):
Not required to attend
Assessment Change Notice was not received by Petitioner
O Appealing a purported Clerical Error or Mutual Mistake of Fact (if yes, include explanation in Section 5)
[| Appeating within 35 days of State Tax Commission Order
[i] Appealing within 35 days of receipt of Notice of UncappingPage 3
Ree
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
Section 7: Valuation Information suse tne muitiple parcel form for additional, contiguous parcels.
Parcel Identification Number:
82-09-123-03-012
Classification of Property:
Real
Personal
(check ong)
Agricultural
Compmerct!
Industrial
Residential
Timber-Cutover
Developmentat
Utility
{check one)
/
Current Assessed Value (also known as State Equalized Value) as established by the BOR:
256,473
Current Taxable Value as established by the BOR:
256,473
What do you believe is the fair market value {also known as True Cash Value)?
512,946
Muttiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value.
156,473
if you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.
100,000
Section 8: Classification Information *Only the Mi Dep't of Treasury may appeal this issue to the Tribunat*
Parcel identification Number:
Current Classification of Property as established by Board of Review:
Real
Personal
(check one}
a
Agricultural
Commercial
Industrial
Residentiai
Timber-Cutover
Developmental
Utility
{check one)
What do you believe is the property’s classification?
Real
Personal
(check one)
O
Agricuftural
Commercial
Industrial
Residential
Timber-Cutover
Developmental
Utility
(check one)
If improved property, how is the property currently being used?
improved property, for what use was the property designed?Page 4
STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Fee Information Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition? [J ves No Are you appealing ONLY the denial of a Poverty Exemption or Disabled Veterans Exemption? (} Yes No if you answered yes to either or both of the above questions, you are not required to pay any filing fees, The filing fee is based on the greater of the 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 fiting fee, plus $26.00 will be added for each additional parcel being appealed, not to exceed a
Page 5
STATE
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SC_Notice_of_Docket_Number.2024-09-17_13-23-47.0000.pdfRead complete document text →
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Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket number has been assigned to that petition. The assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with the Tribunal’s rules. The docket number needs to be included on all documents submitted in this case. Respondent shall file an answer to the petition within 28 days of the issuance of a copy of this Notice to Respondent. Tribunal answer forms are available on our website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer form. Failure to file the answer within the 28-day time frame may result in the placement of Respondent in default, as provided by TTR 279. Further, an electronic copy of the petition can be reviewed by utilizing the Docket Lookup Search on the Tribunal’s website. By: __Tribunal Clerk_____ Entered: September 17, 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
Page 2
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 AMS Lundy LLC, Petitioner, MICHIGAN TAX TRIBUNAL SMALL CLAIMS DIVISION v MTT Docket No. 24-003473 City Of Dearborn, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket number has been assigned to that petition. The assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with the Tribunal’s rules. The docket number needs to be included on all documents submitted in this case. Respondent shall file an answer to the petition within 28 days of the issuance of a copy of this Notice to Respondent. Tribunal answer forms are available on our website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer form. Failure to file the answer within the 28-day time frame may result in the placement of Respondent in default, as provided by TTR 279. Further, an electronic copy of the petition can be reviewed by utilizing the Docket Lookup Search on the Tribunal’s website. By: __Tribunal Clerk_____ Entered: September 17, 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
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.
AMS Lundy LLC.pdfRead complete document text →
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Page 1
“rege STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR PROPERTY TAX APPEAL PETITION FORM VALUATION / EXEMPTION / CLASSIFICATION APPEAL Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or Non-Property tax disputes. Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default. Section 1: Petitioner’s Contact Information First Name M.1. Last Name/Company Name AMS LUNDY LLC Mailing Address (No., Street, P.O. Box or Rural Route) City or Town State 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: Petitioner’s Attorney/Authorized Representative’s Contact Information } First Name M.1. Last Name Sam Miller ninfo:4601 Firm Name (if an} " LETHE i “Prop Tax America Address (No., Street, P.O. Box or Rural Route) 26923 Havelock City or Town State ZIP Code Dearborn Heights MI 48127 Telephone Number Fax Number 313-377-1447 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) nassco123@yahoo.com Section 3: Subject Property Information How many If you are appealing more than one parcel, are they contiguous or adjoining? parcelsareyou | [7] vest [] No** appealing? *If yes, use a multiple parcel form for information regarding any contiguous parcels. **If no, you must file separate appeals for each non-contiguous or non-adjoining parcel or you will be defaulted.
Page 2
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
Section 4: Issues Being Appealed (check all that apply)
True Cash and Taxable Value
[J Poverty Exemption
[1 Taxable Value Only (calculation)
{1} Disabled Veterans Exemption
{J Uncapping of Taxable Value
J Eligible Manufacturing Personal Property (ESA)
[1 Exemption from Taxation (other than the denial of a
[1 Classification
Principal Residence or Qualified Agricultural Exemption)
Section 5: Explain the Reason for this Appeal
SEV is too high
Section 6: Jurisdictional Issues
Year(s) you are appealing:
2024
Did you protest the assessment at a Board of Review (BOR)? [mm] Yes
No
If Yes, check which BOR you attended AND attach the BOR decision: [] March
[1] duly
[J] December
If No, check the applicable reason(s):
Not required to attend
Assessment Change Notice was not received by Petitioner
O Appealing a purported Clerical Error or Mutual Mistake of Fact (if yes, include explanation in Section 5)
[| Appeating within 35 days of State Tax Commission Order
[i] Appealing within 35 days of receipt of Notice of UncappingPage 3
Ree
STATE OF MICHIGAN
GRETCHEN WHITMER
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS
MARLON I. BROWN, DPA
GOVERNOR
LANSING
DIRECTOR
Section 7: Valuation Information suse tne muitiple parcel form for additional, contiguous parcels.
Parcel Identification Number:
82-09-123-03-012
Classification of Property:
Real
Personal
(check ong)
Agricultural
Compmerct!
Industrial
Residential
Timber-Cutover
Developmentat
Utility
{check one)
/
Current Assessed Value (also known as State Equalized Value) as established by the BOR:
256,473
Current Taxable Value as established by the BOR:
256,473
What do you believe is the fair market value {also known as True Cash Value)?
512,946
Muttiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value.
156,473
if you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.
100,000
Section 8: Classification Information *Only the Mi Dep't of Treasury may appeal this issue to the Tribunat*
Parcel identification Number:
Current Classification of Property as established by Board of Review:
Real
Personal
(check one}
a
Agricultural
Commercial
Industrial
Residentiai
Timber-Cutover
Developmental
Utility
{check one)
What do you believe is the property’s classification?
Real
Personal
(check one)
O
Agricuftural
Commercial
Industrial
Residential
Timber-Cutover
Developmental
Utility
(check one)
If improved property, how is the property currently being used?
improved property, for what use was the property designed?Page 4
STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Fee Information Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition? [J ves No Are you appealing ONLY the denial of a Poverty Exemption or Disabled Veterans Exemption? (} Yes No if you answered yes to either or both of the above questions, you are not required to pay any filing fees, The filing fee is based on the greater of the 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 fiting fee, plus $26.00 will be added for each additional parcel being appealed, not to exceed a
Page 5
STATE
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.