Andy Gutman, As Receiver Petitioner Vs. City Of Ypsilanti 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

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

PROCEDURE

Andy Gutman, as Receiver,

Petitioner,

v

 

 

City Of Ypsilanti,

Respondent.

 MTT Docket No. 26-001225

Please be advised that 26-001225 has been placed on a two-week Prehearing General 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

covered by the order will not be published.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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 26-001225

Page 2 of 3

IT IS ORDERED that the parties shall:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

during “Pre-Valuation Disclosure” discovery.

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

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

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

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

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

opposing party’s Prehearing Statement.

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

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

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 3, 2026

Page 3

MTT Docket No. 26-001225

Page 3 of 3

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 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N GRAND RIVER AVE, LANSING, MI 48906

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

PROCEDURE

Andy

Page 5

MTT

Page 6

MTT

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Page 1

Reus" 

9 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT 

OF LICENSING 

& REGULATORY 

AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Andrew Gutman, as Receiver, 

Petitioner, 

v. 

MTT Docket No. 22° 

AV 00 Yor 

Parcel No. 11-11- 05- 100-006 

City of Ypsilanti, 

Respondent. 

Stewart Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

Proof of Service 

Lisa Joseph states that on </ 2 /2 b 

, she did serve a copy of Petitioner's Entire 

Tribunal Property Tax Petition, with docket number, upon the parties named on the attached list. 

beets_S/21 [26 

/</ 

Lar Vrach 

Lisa Joseph

Page 2

~ =e 

ED 

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

YPSILANTI 

ONE S. HURON STREET 

YPSILANTI, MI 48197 

ASSESSOR 

YPSILANTI 

ONE S. HURON STREET 

YPSILANTI, MI 48197 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WASHTENAW COUNTY 

PO BOX 8645 

ANN ARBOR, MI 48107-8645 

DIRECTOR OF EQUALIZATION 

WASHTENAW COUNTY 

PO BOX 8645 

ANN ARBOR, MI 48107-8645 

SECRETARY OF SCHOOL BOARD 

YPSILANTI PUBLIC SCHOOL DISTRICT 

1885 PACKARD ROAD 

YPSILANTI, MI 48197-1846 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0033

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Page 1

25-0017 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Andrew Gutman, as Receiver, 

Petitioner, 

v. 

City of Ypsilanti, 

Respondent. 

MTT Docket No. __________ 

Parcel No. 11-11-05-100-006 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

Petition 

Andrew Gutman, as Receiver (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 31700 Middlebelt Road, Suite 225, 

Farmington Hills, MI 48334. 

2.

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

11-11-05-100-006, also known as Arbor West Apartments, with an address of 831 Green Road, 

Ypsilanti, MI, in Washtenaw County ("Petitioner's Property"). 

3.

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

Property. 

4.

In 2026, Respondent determined the taxable value of Petitioner's Property to be

Page 2

2 

75662227.1 

$5,137,974 and assessed Petitioner's Property at $8,020,100, which will result in a state equalized 

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

5.

Petitioner's Property is classified as commercial real. 

6.

Petitioner's Property was originally designed to be used as an apartment property. 

7.

Petitioner’s Property cannot be used for the purposes for which it was developed. 

8.

Petitioner’s Property suffers from substantial obsolescence due to its physical 

condition. 

9.

Additionally, as a result of a court order, the apartment units in Petitioner’s Property 

cannot be occupied. 

10.

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

value, and (d) due process, equal protection and uniformity. 

11.

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

relative to the value of a loss. 

12.

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

13.

The 2026 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;

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3 

75662227.1 

(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 

(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. 

14.

Petitioner's Property has multifamily units that cannot be leased, and to the best 

knowledge of the undersigned, Petitioner's Property is not subject to governmental regulatory 

agreements or a subsidy. 

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

2026 taxable value of Petitioner's Property from $5,137,974 to $2,000,000; (ii) reducing the 2026 

assessed value and state equalized value of Petitioner's Property from $8,020,100 to $2,000,000; 

(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 21, 2026

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Stewart L. Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Andy Gutman, as Receiver

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

31700 Middlebelt Rd.

Suite 225

City or Town

Farmington Hills

State

Florida

ZIP Code

48334

Telephone Number

3134657420

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

slmandell@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)

39400 Woodward Avenue

Suite 101

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

313-465-7420

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

slmandell@honigman.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

831 Green Road

Ypsilanti

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48197

Taxing Authority (City or Township)

City Of Ypsilanti (WASHTENAW) 

County

Washtenaw

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

11-11-05-100-006

Classification of Property: Real (check one)

Commercial (check one)

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

8020100

Current Taxable Value as established by the Board of Review:

5137974

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

4000000

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

2000000

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

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Stewart L. Mandell

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052186423512

Supporting Waiver Documents:

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Andy Gutman, as Receiver, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001225

City Of Ypsilanti, 

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 29, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Andrew Gutman, as Receiver, 

 

Petitioner, 

v 

City of Ypsilanti, 

 

Respondent. 

MTT Docket No. 26-001225 

Parcel No. 11-11-05-100-066 

_____________________________________________________________________________/ 

 

STEWART L. MANDELL (P33781) 

HONIGMAN LLP 

Attorney for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent City of Ypsilanti, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 1 and leaves Petitioner to its proofs. 

2. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 2 and leaves Petitioner to its proofs. 

3. 

Respondent admits the allegations in Paragraph 3.

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2

4. 

Respondent admits the allegations in Paragraph 4 as to the roll values, but lacks the 

information necessary to determine whether or not the property is indeed Petitioner’s and leaves 

Petitioner to its proofs as to that issue. 

5. 

Respondent admits the allegations in Paragraph 5. 

6. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 6 and leaves Petitioner to its proofs. 

7. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 7 and leaves Petitioner to its proofs. 

8. 

Respondent denies the allegations in Paragraph 8. 

9. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 9 and leaves Petitioner to its proofs. 

10. 

Respondent acknowledges Petitioner’s belief as to the issues in this case but denies 

that those claims have merit or that Petitioner is entitled to relief. 

11. 

Respondent denies the allegations in Paragraph 11. 

12. 

Respondent neither admits nor denies the allegation in Paragraph 12 as jurisdiction 

is a matter that can only be resolved by the Tribunal. 

13. 

Respondent denies the allegations in Paragraph 8, including subparagraphs (a)-(d), 

for the reason that the same are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional.

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3

14. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 14 and leaves Petitioner to its proofs. 

 

15. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition, but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent City of Ypsilanti requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Seth A. O’Loughlin______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: July 23, 2026 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent City of Ypsilanti asserts the following affirmative defenses: 

1. 

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. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974).

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4

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

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

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

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

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

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

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

10. 

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. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its

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5

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001225

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Ypsilanti (WASHTENAW)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

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

mtt@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Seth A. O'Loughlin

/s/

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

Page 1

25-0017 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Andrew Gutman, as Receiver, 

Petitioner, 

v. 

City of Ypsilanti, 

Respondent. 

MTT Docket No. __________ 

Parcel No. 11-11-05-100-006 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

Petition 

Andrew Gutman, as Receiver (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 31700 Middlebelt Road, Suite 225, 

Farmington Hills, MI 48334. 

2.

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

11-11-05-100-006, also known as Arbor West Apartments, with an address of 831 Green Road, 

Ypsilanti, MI, in Washtenaw County ("Petitioner's Property"). 

3.

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

Property. 

4.

In 2026, Respondent determined the taxable value of Petitioner's Property to be

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2 

75662227.1 

$5,137,974 and assessed Petitioner's Property at $8,020,100, which will result in a state equalized 

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

5.

Petitioner's Property is classified as commercial real. 

6.

Petitioner's Property was originally designed to be used as an apartment property. 

7.

Petitioner’s Property cannot be used for the purposes for which it was developed. 

8.

Petitioner’s Property suffers from substantial obsolescence due to its physical 

condition. 

9.

Additionally, as a result of a court order, the apartment units in Petitioner’s Property 

cannot be occupied. 

10.

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

value, and (d) due process, equal protection and uniformity. 

11.

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

relative to the value of a loss. 

12.

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

13.

The 2026 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;

Page 3

3 

75662227.1 

(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 

(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. 

14.

Petitioner's Property has multifamily units that cannot be leased, and to the best 

knowledge of the undersigned, Petitioner's Property is not subject to governmental regulatory 

agreements or a subsidy. 

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

2026 taxable value of Petitioner's Property from $5,137,974 to $2,000,000; (ii) reducing the 2026 

assessed value and state equalized value of Petitioner's Property from $8,020,100 to $2,000,000; 

(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 21, 2026

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Stewart L. Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@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

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Andy Gutman, as Receiver

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

31700 Middlebelt Rd.

Suite 225

City or Town

Farmington Hills

State

Florida

ZIP Code

48334

Telephone Number

3134657420

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

slmandell@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)

39400 Woodward Avenue

Suite 101

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

313-465-7420

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

slmandell@honigman.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

831 Green Road

Ypsilanti

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48197

Taxing Authority (City or Township)

City Of Ypsilanti (WASHTENAW) 

County

Washtenaw

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

11-11-05-100-006

Classification of Property: Real (check one)

Commercial (check one)

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

8020100

Current Taxable Value as established by the Board of Review:

5137974

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

4000000

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

2000000

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

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Stewart L. Mandell

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052186423512

Supporting Waiver Documents:

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.