Baracus Partners, LLC Petitioner Vs. City Of Detroit Respondent

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

BARACUS PARTNERS, LLC, 

Petitioner, 

MTT Docket No. 26-001581-TT 

v. 

CITY OF DETROIT, 

Respondent. 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

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

2. 

Property Parcel No: 22002730-40. 

3. 

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

Review are: 

Tax Year 

True Cash Value 

| Assessed Value 

Taxable Value 

2026 

$647,000 

$323,500 

$323,500 

4, 

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

purposes are: 

Tax Year 

[True Cash Value 

| Assessed Value 

Taxable Value 

2026 

$380,000 

$190,000 

$190,000 

5. 

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

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

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

years: 

6. 

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

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

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

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall 

be made payable jointly to Petitioner named herein and its 

counsel, Foley & Lardner LLP, and sent 

in care of such 

1 

4920-3358-0900.1

Page 2

counsel. Calculations of the refund amount shall also be sent 

to Petitioner's counsel at the same address. 

IT IS FURTHER ORDERED AND ADJUDGED that all interest 

due hereunder is waived if, and only if, all refunds otherwise 

due are made within 90 days of the date of entry of the Consent 

Judgment. 

FOLEY & LARDNER LLP 

CITY OF DETROIT LAW 

Attorneys Petitioner 

Attorneys for Respondent 

By. —/s/ Jason Conti — — 

By:/sl. 

Mary Beth Colibs 

Jason Conti (P55617) 

(P40080) 

500 Woodward Avenue, Suite 2700 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

Detroit, Michigan 48226 

(313) 234-7177 

(313) 237-3075 

Dated: October 5, 2026 

4920-3358-0900.1 

Dated: October 12, 2026 

CITY OF V/A 

By 

Alvin Horhn, Deputy CFO, Assessor 

CAYMC - 2 Woodward Avenue 

Suite 824 

Detroit, Michigan 48226 

(313) 224-3052 

Dated: 

_ 10/12/2026

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001581

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

Party Filing Document 

Joint

Files

Document Type: Stip for Consent Judgment

Attachment File Name: Baracus Partners-City of Detroit stipulation for consent judgment 26-1581

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BARACUS PARTNERS, LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26- 001581 MTT 

Respondent. 

________________________________________________________________________________/ 

ANSWER TO PROPERTY TAX PETITION 

 Respondent, City of Detroit, by and through its undersigned counsel and for its Answer to this 

Petition states the following: 

1. Respondent, City of Detroit, admits as true. 

2. Respondent admits as true. 

3. Respondent admits as true. 

4. Respondent admits as true. 

5. Respondent admits that this appeal involves issues of (a) valuation, (b) assessment,(c) 

taxable value and (d) uniformity, but states that Petitioner’s allegations lack merit. 

6. Respondent admits as true that this appeal involves issues of taxable values imposed 

upon the Subject Property, but states that these allegations of the value of a loss lack 

merit.

Page 2

2 

 

7. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or 

information to form a belief as to the truth of the allegation and leaves Petitioner to its 

proofs. 

8. Respondent, City of Detroit, admits that Petitioner appeal is challenging the 2026 

assessment, assessed value, state equalized value and taxable values imposed upon the 

Subject Property, but states that these allegations, including those contained in sub-

paragraphs a-d lack merit. 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: October 1, 2026 

 

 

 

 

 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226 

 (313) 237-3075 

 

 

AFFIRMATIVE DEFENSES. 

 

 

NOW COMES Respondent, City of Detroit, and asserts the following Affirmative 

Defenses to the Petitioner’s claims: 

1. 

Petitioner’s lacks standing and/or capacity to bring forth this Petition. 

2. 

Petitioner’s claims may be barred by the applicable statute of limitations. 

3. 

This Tribunal lacks subject matter jurisdiction.

Page 3

3 

 

4. 

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

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: October 1, 2026 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

313.237.3075 

 

 

 

 

 

 

cobbm@detroitmi.gov

Page 4

4 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BARACUS PARTNERS , LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001581- MTT 

Respondent. 

 

_______________________________________________________________________ 

PROOF OF SERVICE 

 

On 10/1/2026 , I mailed by first class mail a copy of Respondent’s Answer and Affirmative 

Defenses to: 

 

 

 

Jason Conti, Esq. 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

500 Woodward Ave., Suite 2700 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

I declare that the above statement is true to the best of my information, knowledge, and 

belief. 

 

Dated: October 1, 2026 

 

 

 

 

 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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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. 26-001581

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City of Detroit (Wayne)

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

Mary Beth

M.I.

Last Name

Cobbs

Firm Name (if any)

City of Detroit

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

2 Woodward Avenue

Suite 500

City or Town

Detroit

State

 Michigan

ZIP Code

48226

Telephone Number

(313) 237-3075

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

cobbm@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

/s/Mary Beth Cobbs

/s/

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Page 1

4917-0059-9892.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

BARACUS PARTNERS, LLC, 

 

 

 

MTT Docket No. 26-001581 

 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

 

v 

 

CITY OF DETROIT, 

 

 

 

Respondent. 

 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

________________________________________/ 

 

PROOF OF SERVICE 

 

On September 9, 2026, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for the 2026 Tax Year, Notice of Docket Number, and this Proof of Service on: 

Wayne County Clerk 

Two Woodward Avenue 

Detroit, Michigan 48226 

 via U.S. mail 

Wayne County Equalization 

Director 

500 Griswold 

Detroit, Michigan 48226 

via U.S. mail

Detroit School Board 

Secretary 

3011 W. Grand Boulevard 

Detroit, Michigan 48202 

via U.S. mail

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

 via U.S. mail 

 

 

 

City Clerk 

CAYMC 

Two Woodward Avenue 

Suite 120 

Detroit, Michigan 48226 

 via Certified Mail 

 

City of Detroit Assessor 

CAYMC 

Two Woodward Avenue 

Suite 120 

Detroit, Michigan 48226 

 via Certified Mail

Page 2

2 

4917-0059-9892.1 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: /s/ Jason Conti (P55617) 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001581

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: 2026-09-09 Baracus Partners proof of service of petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

1 

4933-7508-2158.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

BARACUS PARTNERS, LLC, 

 

 

 

MTT Docket No. ___________ 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

 

 

 

 

v 

 

CITY OF DETROIT, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2026 TAX YEAR 

 

 

BARACUS PARTNERS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, files this 

Petition For The 2026 Tax Year, and states: 

 

1. 

Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, 

Michigan, 48075. Petitioner is a party in interest with respect to property taxes on real property tax parcel 

no. 22002730-40 (the “Subject Property”), also known as 8800 Evergreen, Detroit, Michigan. 

 

2. 

Respondent City of Detroit (“Respondent”) assesses and collects property taxes on the 

Subject Property. 

 

3. 

In 2026, Respondent determined the taxable value of the Subject Property to be $323,500, 

and the assessed value of the Subject Property to be $323,500, which will result in a state equalized value 

in the same amount based upon the tentative equalization factor. 

 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject Property was 

originally designed to be used for Commercial purposes. 

 

5. 

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

and (d) uniformity.

Page 2

2 

4933-7508-2158.1 

 

6. 

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

relative to the value of a loss. 

 

7. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March, 2026. 

 

8. 

The 2026 assessment, including state equalized value and taxable value, imposed on the 

Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as 

a fraud upon the taxpayer 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, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and applicable 

statutes; 

 

 

(c) 

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

upon an erroneous determination of the true cash value of that portion of the Subject Property that is 

taxable under Michigan law, and are 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. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable 

value of the Subject Property from $323,500 to $25,000, and reducing the 2026 state equalized value of the 

Subject Property from $323,500 to $25,000, and requiring Respondent to pay Petitioner the refunds 

attributable to such reductions, plus interest and costs.

Page 3

3 

4933-7508-2158.1 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 27, 2026

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

Baracus Partners, LLC

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

24500 Northwestern Hwy.

Suite 100

City or Town

Livonia

State

Michigan

ZIP Code

48152

Telephone Number

3132347177

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

jconti@foley.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

Last Name

Conti

Firm Name (if any)

Foley & Lardner LLP

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

500 Woodward Avenue

Suite 2700

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3132347177

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

jconti@foley.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]

8800 Evergreen

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48228

Taxing Authority (City or Township)

City of Detroit (Wayne) 

County

Wayne

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:

22002730-40

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:

323500

Current Taxable Value as established by the Board of Review:

323500

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

50000

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

25000

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/ /S/ JASON CONTI

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787093281

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

Baracus Partners, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001581

City of Detroit, 

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: August 19, 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

1 

4933-7508-2158.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

BARACUS PARTNERS, LLC, 

 

 

 

MTT Docket No. ___________ 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

 

 

 

 

v 

 

CITY OF DETROIT, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2026 TAX YEAR 

 

 

BARACUS PARTNERS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, files this 

Petition For The 2026 Tax Year, and states: 

 

1. 

Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, 

Michigan, 48075. Petitioner is a party in interest with respect to property taxes on real property tax parcel 

no. 22002730-40 (the “Subject Property”), also known as 8800 Evergreen, Detroit, Michigan. 

 

2. 

Respondent City of Detroit (“Respondent”) assesses and collects property taxes on the 

Subject Property. 

 

3. 

In 2026, Respondent determined the taxable value of the Subject Property to be $323,500, 

and the assessed value of the Subject Property to be $323,500, which will result in a state equalized value 

in the same amount based upon the tentative equalization factor. 

 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject Property was 

originally designed to be used for Commercial purposes. 

 

5. 

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

and (d) uniformity.

Page 2

2 

4933-7508-2158.1 

 

6. 

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

relative to the value of a loss. 

 

7. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March, 2026. 

 

8. 

The 2026 assessment, including state equalized value and taxable value, imposed on the 

Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as 

a fraud upon the taxpayer 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, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and applicable 

statutes; 

 

 

(c) 

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

upon an erroneous determination of the true cash value of that portion of the Subject Property that is 

taxable under Michigan law, and are 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. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable 

value of the Subject Property from $323,500 to $25,000, and reducing the 2026 state equalized value of the 

Subject Property from $323,500 to $25,000, and requiring Respondent to pay Petitioner the refunds 

attributable to such reductions, plus interest and costs.

Page 3

3 

4933-7508-2158.1 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 27, 2026

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

Baracus Partners, LLC

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

24500 Northwestern Hwy.

Suite 100

City or Town

Livonia

State

Michigan

ZIP Code

48152

Telephone Number

3132347177

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

jconti@foley.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

Last Name

Conti

Firm Name (if any)

Foley & Lardner LLP

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

500 Woodward Avenue

Suite 2700

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3132347177

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

jconti@foley.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]

8800 Evergreen

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48228

Taxing Authority (City or Township)

City of Detroit (Wayne) 

County

Wayne

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:

22002730-40

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:

323500

Current Taxable Value as established by the Board of Review:

323500

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

50000

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

25000

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/ /S/ JASON CONTI

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787093281

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.