Chelsea Clocktower Building LLC, Petitioner Vs. City Of Chelsea, 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

Chelsea Clocktower Building LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that:

Petitioner has filed a Motion to Withdraw the Petition and the motion indicates that 

Petitioner informed Respondent of the motion and that Respondent concurs with the 

requested withdrawal. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal.

Page 2

MTT Docket No. 25-002844

Page 2 of 2

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

By: /s/ Patricia L. Halm

Entered: August 14, 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

Page 3

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

Chelsea Clocktower Building LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that:

Petitioner has filed a Motion to Withdraw the Petition and the motion indicates that 

Petitioner informed Respondent of the motion and that Respondent concurs with the 

requested withdrawal. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to

Page 4

M

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

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

Chelsea Clocktower Building LLC,

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL

TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above-

captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties 

or representatives), Respondent has seven days from the service of the motion to file a 

response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of 

the case or by objecting to the motion. If Respondent does not timely submit a 

concurrence or objection to the request, it will be deemed to be a concurrence and the 

request will be granted, unless otherwise ordered by the Tribunal. If the request is 

granted, the case will be dismissed. If a request is not granted or the Tribunal has not 

notified you that it has been granted, you are required to attend the hearing. 

For your convenience, you may use the Tribunal’s form “Response to Motion to 

Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to 

our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small 

Claims” page, depending on the division in which the case is pending. To submit the 

response, please fill out the form and file it with the Tribunal by e-mail or e-filing.1

By: Tribunal Clerk

Entered: August 3, 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

1 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the 

efficient administration of justice.

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

Chelsea Clocktower Building LLC,

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL

TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above-

captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties 

or representatives), Respondent has seven days from the service of the motion to file a 

response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of 

the case or by objecting to the motion. If Respondent does not timely submit a 

concurrence or objection to the request, it will be deemed to be a concurrence and the 

request will be granted, unless otherwise ordered by the Tribunal. If the request is 

granted, the case will be dismissed. If a request is not granted or the Tribunal has not 

notified you that it has been granted, you are required to attend the hearing. 

For your convenience, you may use the Tribunal’s form “Response to Motion to 

Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to 

our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small 

Claims” page, depending on the division in which the case is pending. To submit the 

response, please fill out the form and file it with the Tribunal by e-mail or e-filing.2

By: Tribunal Clerk

Entered: August 3, 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

2 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the 

efficient administration of justice.

Page 3

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,

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Chelsea Clocktower Building, LLC, 

Petitioner, 

v 

City of Chelsea, 

Respondent.

MTT Docket No. 25-002844 

Stewart Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7420 

slmandell@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101) 

Seth 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 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Motion to Withdraw Petition 

For this Motion, Petitioner states: 

Petitioner desires to withdraw its Petition and files this Motion pursuant to Tax Tribunal 

Rule 231, R 792.10231 and MCL 205.732(c). Respondent’s counsel has confirmed that 

Respondent concurs with the Tribunal dismissing this case as requested herein. 

WHEREFORE, Petitioner requests that the Tribunal enter an Order allowing the Petition 

to be withdrawn, or dismissing this case, with each party bearing its own costs.

Page 2

2 

76434670.1 

 

Respectfully submitted, 

HONIGMAN LLP, 

Attorneys for Petitioner 

By:/s/ Stewart Mandell 

Stewart Mandell (P33781) 

Daniel L. Stanley (P57052) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

Dated: July 31, 2026 

dstanley@honigman.com

Page 3

3 

76434670.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Chelsea Clocktower Building, LLC, 

Petitioner, 

v 

City of Chelsea, 

Respondent.

MTT Docket No. 25-002844 

Stewart Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7420 

slmandell@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101) 

Seth 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 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Proof of Service 

Maxwell Katz states that on July 31, 2026 he served a copy of Petitioner’s Motion to 

Withdraw upon Respondent’s Attorney via electronic mail as shown below: 

Laura M. Hallahan (P42101) 

Seth O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

____/s/ Maxwell Katz__________________________ 

Dated: July 31, 2026 

 Maxwell Katz

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

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: 25-002844

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

Party Filing Document 

Petitioner

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Motion to Withdraw and POS - Chelsea Clocktower (25-002844)

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

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 JANUARY 4 - 15, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Chelsea Clocktower Building LLC,

Petitioner,

v

 

 

City Of Chelsea,

Respondent.

 MTT Docket No. 25-002844

Please be advised that 25-002844 has been placed on a two-week Prehearing General 

Call commencing January 04, 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. 25-002844

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 September 8, 2026. 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 September 8, 2026. 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 

September 8, 2026, 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 

January 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. “Post-Valuation

Page 3

MTT

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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

Chelsea Clocktower Building LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on September 15, 2025, and the default has been 

timely cured. The documents curing the default can be reviewed through the docket 

search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the 

docket number and clicking on the document link next to the line item entry for the 

documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 14, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Chelsea Clocktower Building LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on September 15, 2025, and the default has been 

timely cured. The documents curing the default can be reviewed through the docket 

search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the 

docket number and clicking on the document link next to the line item entry for the 

documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 14, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 3

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

Chelsea Clocktower Building LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002844

City Of Chelsea,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that 

Respondent was held in default on September 15, 2025, and the default has been 

timely cured. The documents curing the default can be reviewed through the docket 

search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the 

docket number and clicking on the document link next to the line item entry for the 

documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 14, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Chelsea Clocktower Building LLC. 

 

 

 

Petitioner, 

 

v 

 

City of Chelsea, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002844 

 

Parcel No. 06-06-12-111-001 

 

_____________________________________________________________________________/ 

 

STEWART L. MANDELL (P33781) 

DANIEL L STANLEY (P57052) 

HONIGMAN LLP 

Attorney for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

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 Chelsea, by and through its attorneys, Hallahan & Associates, P.C., 

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

1. 

Respondent admits the allegations in Paragraph 1 as to the address and parcel 

number and leaves Petitioner to its proofs as to the remainder of the allegations as Respondent 

lacks the information necessary to respond. 

2. 

Respondent admits that it is the taxing municipality, but leaves Petitioner to its 

proofs as to the remainder of the allegations as Respondent lacks the information necessary to 

respond.

Page 2

2

3. 

Respondent admits the allegations in Paragraph 3 as to the values, but leaves 

Petitioner to its proofs as to the remainder of the allegations as Respondent lacks the information 

necessary to respond 

4. 

Respondent admits the property is classified commercial. Respondent lacks the 

ability to respond to the allegations in Paragraph 4 and leaves Petitioner to its proofs. 

5. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5, but 

denies that Petitioner’s claims have merit or that Petitioner is entitled to relief in this case. 

6. 

Respondent denies the allegations in Paragraph 6. 

7. 

Respondent admits the allegations in Paragraph 7. 

8. 

Respondent denies the allegations in Paragraph 8, including all subparagraphs, 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. 

9. 

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 Chelsea 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.

Page 3

3

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: September 25, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent City of Chelsea 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). 

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

Page 4

4

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

Page 5

5

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002844

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Chelsea (WASHTENAW)

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

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

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

248-731-3087

Fax Number

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/

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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

Chelsea Clocktower Building LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002844

City Of Chelsea,

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. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers 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: September 15, 2025

Patricia L. Halm, Tribunal Chair

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

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.

Page 2

MTT Docket No. 25-002844

Page 2 of 6

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 225(5)

Page 3

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

Chelsea Clocktower Building LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002844

City Of Chelsea,

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. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers 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: September 15, 2025

Patricia L. Halm, Tribunal Chair

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

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

Page 4

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Chelsea Clocktower Building LLC, 

Petitioner, 

v. 

MTT Docket No. 25-002844 

Parcel No. 06-06-12-111-001 

City of Chelsea, 

Respondent. 

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Proof of Service 

Lisa Joseph states that on July 24, 2025 she did serve a copy of Petitioner's Petition, with 

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

& onal 

Dated: July 24, 2025 

Lisa Joseph 

25-0034 

60576020.2

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

CHELSEA 

305 S. MAIN ST., SUITE 100 

CHELSEA, MI 48118-1544 

ASSESSOR 

CHELSEA 

305 S. MAIN ST., SUITE 100 

CHELSEA, MI 48118-1544 

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 

CHELSEA SCHOOL DISTRICT 

500 WASHINGTON STREET 

CHELSEA, MI 48118-1199 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0038 

60576020.2

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

RECEWEP 

RECEIVED 

A 2009 

Wwi3 

JNO 

JN 092055 

oy 

px TRIB uN 

STATE OF MICHIG AREAIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS, 

MICHIGAN TAX TRIBUNAL 

Chelsea Clocktower Building LLC, 

Petitioner, 

Vv. 

MTT Docket No. 

Parcel No. 06-06-12-111-001 

City of Chelsea, 

Respondent. 

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

TranInfo:6606 

 26021220-1 

06/03/25 

Bloomfield Hills, MI 48304-5151 

Chki= 

040627 

Amt: $600.00 

(313) 465-7420 

ID: 

HONIGMAN LLP 

slmandell@honigman.com 

Petition 

Chelsea Clocktower Building LLC (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1. 

Petitioner's principal office address is 320 N. Main St., Suite 200, Ann Arbor, MI 

48104. Petitioner is a party in interest with respect to property taxes on tax parcel number 06-06- 

12-111-001 ("Petitioner's Property"), with an address of 310 N. Main St., located in Washtenaw 

County, Michigan.

Page 2

3. 

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

$1,299,000 and assessed Petitioner's Property at $1,299,000, which will result in a state equalized 

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

4. 

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

used or available for use for commercial purposes. 

Petitioner believes that Petitioner's Property 

was originally designed to be used for commercial purposes. 

5. 

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

value, and (d) uniformity. 

6. 

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

relative to the value of a loss. 

7. 

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

8. 

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

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

for the reasons that: 

(a) 

The 2025 assessment, including state equalized value and/or taxable value, 

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

(b) 

The 2025 assessment, including state equalized value and/or taxable value, 

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

applicable statutes; 

(c) 

The 2025 assessment, including taxable value and/or state equalized value,

Page 3

(d) 

The 2025 assessment, including state equalized value and/or taxable value, 

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

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

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

2025 taxable value of Petitioner's Property from $1,299,000 to $650,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $1,299,000 to $650,000; (iii) 

requiring payment to Petitioner of the refunds attributable to the foregoing relief, plus interest and 

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

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, Michigan 48304-5151 

(313) 465-7420 

simandell@honigman.com 

Dated: June 2, 2025

Page 4

Hontgman LLP 

COSTS ADVANCED ACCOUNT 

Invoice Date 

Invoice Number 

Invoice Narrative 

6/2/25 

BB 

99997/997594/SLM 

21074678.1 

Filing Fee for Petition for Chelsea 

Clocktower Parcel 06-06-12-1111-001 

Payment Amount

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

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

Chelsea Clocktower Building LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002844

City Of Chelsea, 

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 24, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

RECEWEP 

RECEIVED 

A 2009 

Wwi3 

JNO 

JN 092055 

oy 

px TRIB uN 

STATE OF MICHIG AREAIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS, 

MICHIGAN TAX TRIBUNAL 

Chelsea Clocktower Building LLC, 

Petitioner, 

Vv. 

MTT Docket No. 

Parcel No. 06-06-12-111-001 

City of Chelsea, 

Respondent. 

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

TranInfo:6606 

 26021220-1 

06/03/25 

Bloomfield Hills, MI 48304-5151 

Chki= 

040627 

Amt: $600.00 

(313) 465-7420 

ID: 

HONIGMAN LLP 

slmandell@honigman.com 

Petition 

Chelsea Clocktower Building LLC (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1. 

Petitioner's principal office address is 320 N. Main St., Suite 200, Ann Arbor, MI 

48104. Petitioner is a party in interest with respect to property taxes on tax parcel number 06-06- 

12-111-001 ("Petitioner's Property"), with an address of 310 N. Main St., located in Washtenaw 

County, Michigan.

Page 2

3. 

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

$1,299,000 and assessed Petitioner's Property at $1,299,000, which will result in a state equalized 

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

4. 

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

used or available for use for commercial purposes. 

Petitioner believes that Petitioner's Property 

was originally designed to be used for commercial purposes. 

5. 

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

value, and (d) uniformity. 

6. 

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

relative to the value of a loss. 

7. 

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

8. 

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

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

for the reasons that: 

(a) 

The 2025 assessment, including state equalized value and/or taxable value, 

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

(b) 

The 2025 assessment, including state equalized value and/or taxable value, 

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

applicable statutes; 

(c) 

The 2025 assessment, including taxable value and/or state equalized value,

Page 3

(d) 

The 2025 assessment, including state equalized value and/or taxable value, 

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

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

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

2025 taxable value of Petitioner's Property from $1,299,000 to $650,000; (ii) reducing the 2025 

assessed value and state equalized value of Petitioner's Property from $1,299,000 to $650,000; (iii) 

requiring payment to Petitioner of the refunds attributable to the foregoing relief, plus interest and 

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

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, Michigan 48304-5151 

(313) 465-7420 

simandell@honigman.com 

Dated: June 2, 2025

Page 4

Hontgman LLP 

COSTS ADVANCED ACCOUNT 

Invoice Date 

Invoice Number 

Invoice Narrative 

6/2/25 

BB 

99997/997594/SLM 

21074678.1 

Filing Fee for Petition for Chelsea 

Clocktower Parcel 06-06-12-1111-001 

Payment Amount

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.