Clark Logistics Group Lv, LLC, Petitioner Vs. City Of Benton Harbor, 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 

Clark Logistics Group LV LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001668 

 

City of Benton Harbor, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001668 

Page 2 of 2 

 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, and (xviii) after June 30, 2025, through December 31, 2025, at the rate of 

8.66%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

By

 

 

Entered: October 21, 2025 

am 

 

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

62517698.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL

CLARK LOGISTICS GROUP LV, LLC, 

Petitioner, 

v 

MTT Docket No. 25-001668 

BENTON HARBOR, 

Respondent. 

_____________________________/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1.

The parcel is located in Berrien County. 

2.

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

3.

Property Parcel No: multiple. 

4.

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

Review are: 

(see attachment) 

5.

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

purposes are: 

(see attachment) 

6.

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: 

7.

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, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660

Page 2

MTT Docket No. 25-001668 

Stipulation for Entry of Consent Judgment 

2 

62517698.1 

Woodward, Suite 2290, Detroit, MI 48226. Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

HONIGMAN LLP 

LAW OFFICE OF SARA A. SENICA 

Attorneys for Petitioner 

Attorneys for Respondent 

By: _______________________________ 

By: _____________________________ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com

dstanley@honigman.com

Sara A. Senica, (P66004) 

12 Longmeadow Village Drive 

Niles, MI 49120 

(269) 684-1500 

sara.sblaw@gmail.com

Dated: October 20, 2025 

 

Dated: October 20, 2025 

/s/ Daniel L. Stanley 

 

 

 /s/ Sara A. Senica (w/permission)

Page 3

MTT Docket No. 25-001668 

Stipulation for Entry of Consent Judgment 

3 

62517698.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL

CLARK LOGISTICS GROUP LV, LLC, 

Petitioner, 

v 

MTT Docket No. 25-001668 

BENTON HARBOR, 

Respondent. 

MULTIPLE PARCEL ATTACHMENT TO 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1.

The values for the property identified herein as established by Respondent’s Board of 

Review are: 

Tax 

Year 

Parcel 

Number 

True Cash 

Value 

Assessed 

Value 

Taxable 

Value 

2025

54-0009-0020-08-2

$4,107,200

$2,053,600

$1,946,734

2025

54-0009-0020-09-1

$1,828,800

$914,400

$877,793

$5,936,000 

$2,968,000 

$2,824,527 

2.

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

purposes are: 

Tax 

Year 

Parcel 

Number 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2025

54-0009-0020-08-2

$2,539,746

$1,269,873

$1,269,873

2025

54-0009-0020-09-1

$1,099,004

$549,502

$549,502

$3,638,750 

$1,819,375 

$1,819,375

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

62517698.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL

CLARK LOGISTICS GROUP LV, LLC, 

Petitioner, 

v 

MTT Docket No. 25-001668 

BENTON HARBOR, 

Respondent. 

_____________________________/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1.

The parcel is located in Berrien County. 

2.

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

3.

Property Parcel No: multiple. 

4.

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

Review are: 

(see attachment) 

5.

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

purposes are: 

(see attachment) 

6.

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: 

7.

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, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660

Page 2

MTT Docket No. 25-001668 

Stipulation for Entry of Consent Judgment 

2 

62517698.1 

Woodward, Suite 2290, Detroit, MI 48226. Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

HONIGMAN LLP 

LAW OFFICE OF SARA A. SENICA 

Attorneys for Petitioner 

Attorneys for Respondent 

By: _______________________________ 

By: _____________________________ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com

dstanley@honigman.com

Sara A. Senica, (P66004) 

12 Longmeadow Village Drive 

Niles, MI 49120 

(269) 684-1500 

sara.sblaw@gmail.com

Dated: October 20, 2025 

 

Dated: October 20, 2025 

/s/ Daniel L. Stanley 

 

 

 /s/ Sara A. Senica (w/permission)

Page 3

MTT Docket No. 25-001668 

Stipulation for Entry of Consent Judgment 

3 

62517698.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL

CLARK LOGISTICS GROUP LV, LLC, 

Petitioner, 

v 

MTT Docket No. 25-001668 

BENTON HARBOR, 

Respondent. 

MULTIPLE PARCEL ATTACHMENT TO 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1.

The values for the property identified herein as established by Respondent’s Board of 

Review are: 

Tax 

Year 

Parcel 

Number 

True Cash 

Value 

Assessed 

Value 

Taxable 

Value 

2025

54-0009-0020-08-2

$4,107,200

$2,053,600

$1,946,734

2025

54-0009-0020-09-1

$1,828,800

$914,400

$877,793

$5,936,000 

$2,968,000 

$2,824,527 

2.

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

purposes are: 

Tax 

Year 

Parcel 

Number 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2025

54-0009-0020-08-2

$2,539,746

$1,269,873

$1,269,873

2025

54-0009-0020-09-1

$1,099,004

$549,502

$549,502

$3,638,750 

$1,819,375 

$1,819,375

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

Clark Logistics Group LV, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001668

City Of Benton Harbor,

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 July 30, 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: September 2, 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

Clark Logistics Group LV, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001668

City Of Benton Harbor,

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 July 30, 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: September 2, 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

Clark Logistics Group LV, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001668

City Of Benton Harbor,

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 July 30, 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: September 2, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPT. OF LICENSING AND REGULATORY AFFAIRS 

IN THE MICHIGAN TAX TRIBUNAL 

 

CLARK LOGISTICS GROUP LV, LLC 

 

MOAHR Docket No. 25-001668-TT 

 

Petitioner, 

 

v. 

 

 

 

 

 

 

PROOF OF SERVICE 

 

 

 

 

 

 

 

 

CITY OF BENTON HARBOR, 

 

Respondent. 

 

Michael B. Shapiro (P20282) 

 

 

Sara A. Senica (P66004) 

Honigman LLP 

 

 

 

 

Attorney for Respondent 

Representatives for Petitioner 

 

 

Law Office of Sara A. Senica, PLLC 

660 Woodward Avenue 

 

 

 

12 Longmeadow Village Drive 

 

2290 First National Building 

 

 

Niles, MI 49120 

Detroit, MI 48226 

 

 

 

 

Ph. 269-684-1500 

Ph. 313- 465-7622 

 

 

 

 

Email: sara.sblaw@gmail.com 

Email: mshapiro@honigman.com 

__________________________________________________________________________ 

 

PROOF OF SERVICE 

 

The undersigned, Sara A. Senica, certifies that on August 11, 2025, she served a copy of her 

Appearance, Respondent’s Answer and Affirmative Defenses, and Proof of Service on Michael B. 

Shapiro, Honigman, LLP, 600 Woodward Ave., 2290 First National Building, Detroit, MI 48226, by 

First Class Mail, with postage prepaid, by depositing the same at the Niles Post Office, Niles, MI, 

49120, and that the same documents were also emailed to Michael B. Shapiro at 

mshapiro@honigman.com on August 11, 2025. 

 

Date: August 11, 2025 

_________________________ 

By: Sara A. Senica, Attorney for Respondent 

12 Longmeadow Village Drive 

Niles, MI 49120 

 

 

 

 

 

Phone: 269-684-1500 

Email: sara.sblaw@gmail.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 

DEPT. OF LICENSING AND REGULATORY AFFAIRS 

IN THE MICHIGAN TAX TRIBUNAL 

 

CLARK LOGISTICS GROUP LV, LLC 

 

MOAHR Docket No. 25-001668-TT 

 

Petitioner, 

 

v. 

 

 

 

 

 

 

ANSWER TO PETITION AND 

 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

CITY OF BENTON HARBOR, 

 

Respondent. 

 

Michael B. Shapiro (P20282) 

 

 

Sara A. Senica (P66004) 

Honigman LLP 

 

 

 

 

Attorney for Respondent 

Representatives for Petitioner 

 

 

Law Office of Sara A. Senica, PLLC 

660 Woodward Avenue 

 

 

 

12 Longmeadow Village Drive 

 

2290 First National Building 

 

 

Niles, MI 49120 

Detroit, MI 48226-3506 

 

 

 

Ph. 269-684-1500 

Ph. 313- 465-7622 

 

 

 

 

Email: sara.sblaw@gmail.com 

Email: mshapiro@honigman.com 

__________________________________________________________________________ 

 

ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

 

 

Respondent City of Benton Harbor, by and through its attorney, states as follows in 

response to Petitioner’s Petition: 

1. Respondent City admits that the parcels at issue are contiguous parcels 11-54-0009-0020-

08-2 and 11-54-0009-0020-09-1 with an address of 1042 N. Crystal Avenue, Benton 

Harbor, Berrien County, Michigan, and Respondent neither admits nor denies the 

principal office address of Petitioner, leaving Petitioner to its proofs. 

 

2. Respondent City admits the allegations in paragraph 2. 

 

3. Respondent City admits the allegations in paragraph 3. 

 

4. Respondent City denies the statement in paragraph 4 as untrue, as both parcels are 

classified as “Industrial”. 

 

5. Respondent City lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations stated in paragraph 5, but Respondent denies that the property is 

not appropriately assessed.

Page 2

6. Respondent City lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations stated in paragraph 5, but Respondent denies that the property is 

not appropriately assessed. 

 

7. Respondent City admits that Petitioner did not appear at Respondent’s Board of Review. 

 

8. Respondent City denies the statements made in paragraph 8 as untrue. 

 

(a) Respondent City denies the statements made in paragraph 8(a) as untrue. 

(b) Respondent City denies the statements made in paragraph 8(b) as untrue. 

(c) Respondent City denies the statements made in paragraph 8(c) as untrue. 

(d) Respondent City denies the statements made in paragraph 8(d) as untrue. 

 

WHEREFORE, Respondent City respectfully requests that this honorable Tribunal dismiss the 

Petition and uphold the assessed, taxable, and true cash values established by Respondent, along 

with awarding costs and fees, including attorney fees, incurred by Respondent in defense of this 

matter, along with granting all other relief the Tribunal deems just and proper. 

AFFIRMATIVE DEFENSES 

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

2. Petitioner’s claims against Respondent are barred because the valuation method used by 

Respondent comply with the Constitution, state law, and prevailing State Tax 

Commission procedures. 

 

3. Respondent’s assessment reflects 50% of the subject property’s true cash value, and the 

values on the roll, including the taxable value, comply with the General Property Tax 

Act. 

 

4. Petitioner has failed to allege facts to support its allegation that the taxable value of the 

subject property is improper. 

 

5. Respondent City asserts and does not waive the affirmative defenses set forth in MCR 

2.111(F)(3) to the extent that said defenses are established by the facts of this case. 

 

6. Respondent City expressly reserves the right to plead and assert further and other 

affirmative defenses as supported by the facts of the case. 

 

 

 

 

August 11, 2025 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

 

 

_____________________________________ 

 

 

 

 

 

 

Sara A. Senica, Attorney for Respondent City

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

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001668

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Benton Harbor (BERRIEN)

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

Sara

M.I.

A

Last Name

Senica

Firm Name (if any)

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

12 Longmeadow Village Dr

City or Town

Niles

State

Michigan

ZIP Code

49120

Telephone Number

269-684-1500

Fax Number

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

sara.sblaw@gmail.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Sara A. Senica

/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

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

Clark Logistics Group LV, LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001668

City Of Benton Harbor,

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: July 30, 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. 25-001668

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

Clark Logistics Group LV, LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001668

City Of Benton Harbor,

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: July 30, 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

25-0089 

60684031.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Clark Logistics Group LV, LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 54-0009-0020-08-2, 54-0009-

0020-09-1] 

Benton Harbor, 

Respondent. 

_________________________/ 

PETITION 

Clark Logistics Group LV, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, 

says: 

1. 

Petitioner's principal office address is 3700 E. Milham Avenue, Suite A, Portage, 

MI 49002. Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 54-

0009-0020-08-2, 54-0009-0020-09-1 ("Petitioner's Property"), at 1042 N. Crystal Ave. located in 

Berrien County, Michigan. If this petition includes more than one (1) real property tax parcel, the 

tax parcels are contiguous. 

2. 

Respondent, Benton Harbor, assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$2,824,527 ($1,946,734, $877,793) and assessed Petitioner's Property at $2,968,000 ($2,053,600, 

$914,400), which will result in a state equalized value in the same amount based upon the tentative 

equalization factor.

Page 2

2 

60684031.1 

4. 

Petitioner's Property is classified as Commercial Real. 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. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

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 

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 Petitioner's 

Property that is taxable under Michigan law, and are based upon the application of wrong 

principles; and,

Page 3

3 

60684031.1 

(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 2025 

taxable value of Petitioner's Property from $2,824,527 ($1,946,734, $877,793) to $1,470,000 

($1,020,000, $450,000), and reducing the 2025 assessed and state equalized value of Petitioner's 

Property from $2,968,000 ($2,053,600, $914,400) to $1,470,000 ($1,020,000, $450,000), and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Michael B. Shapiro (P20282) 

 

Daniel L. Stanley (P57052 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

/s/ Michael B. Shapiro

May 29, 2025

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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

Clark Logistics Group LV, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001668

City Of Benton Harbor, 

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 21, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Clark Logistics Group LV, LLC, 

Petitioner, 

) 

aad 

v. 

MTT Docket N 

P 200 [bb 3 

[Parcel 

No(s). 

54-0009-0020-08-2, 

54-0009- 

0020-09-1] 

Benton Harbor, 

Respondent. 

/ 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

“ 

a 

. 

“ye 

ye 

. 

that on s [3 2 [2S 

| shedidservea copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

ff Foon Qpacrh 

4 

/ 

Lisa Joseph 

25-0089 

60684031.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

BENTON HARBOR 

200 E WALL STREET 

BENTON HARBOR, MI 49022 

ASSESSOR 

BENTON HARBOR 

200 E WALL STREET 

BENTON HARBOR, MI 49022 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

BERRIEN COUNTY 

701 MAIN STREET 

ST. JOSEPH, MI 49085-1316 

DIRECTOR OF EQUALIZATION 

BERRIEN COUNTY 

701 MAIN STREET 

ST. JOSEPH, MI 49085-1316 

SECRETARY OF SCHOOL BOARD 

BENTON HARBOR AREA SCHOOLS 

823 RIVERVIEW DRIVE, PO BOX 1107 

BENTON HARBOR, MI 49023-1107 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0089 

60684031.1

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Page 1

25-0089 

60684031.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Clark Logistics Group LV, LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 54-0009-0020-08-2, 54-0009-

0020-09-1] 

Benton Harbor, 

Respondent. 

_________________________/ 

PETITION 

Clark Logistics Group LV, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, 

says: 

1. 

Petitioner's principal office address is 3700 E. Milham Avenue, Suite A, Portage, 

MI 49002. Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 54-

0009-0020-08-2, 54-0009-0020-09-1 ("Petitioner's Property"), at 1042 N. Crystal Ave. located in 

Berrien County, Michigan. If this petition includes more than one (1) real property tax parcel, the 

tax parcels are contiguous. 

2. 

Respondent, Benton Harbor, assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$2,824,527 ($1,946,734, $877,793) and assessed Petitioner's Property at $2,968,000 ($2,053,600, 

$914,400), which will result in a state equalized value in the same amount based upon the tentative 

equalization factor.

Page 2

2 

60684031.1 

4. 

Petitioner's Property is classified as Commercial Real. 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. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

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 

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 Petitioner's 

Property that is taxable under Michigan law, and are based upon the application of wrong 

principles; and,

Page 3

3 

60684031.1 

(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 2025 

taxable value of Petitioner's Property from $2,824,527 ($1,946,734, $877,793) to $1,470,000 

($1,020,000, $450,000), and reducing the 2025 assessed and state equalized value of Petitioner's 

Property from $2,968,000 ($2,053,600, $914,400) to $1,470,000 ($1,020,000, $450,000), and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Michael B. Shapiro (P20282) 

 

Daniel L. Stanley (P57052 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

/s/ Michael B. Shapiro

May 29, 2025

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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 - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Clark Logistics Group LV, LLC

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

3700 E. Milham

City or Town

Portage

State

Michigan

ZIP Code

49002

Telephone Number

2485668300

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Daniel

M.I.

Last Name

Stanley

Firm Name (if any)

Honigman LLP

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

222 N. Washington Sq

Suite 400

City or Town

Lansing

State

Michigan

ZIP Code

48933

Telephone Number

517-377-0714

Fax Number

517-364-9514

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

DStanley@Honigman.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?2

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

Michigan

Taxing Authority (City or Township)

City Of Benton Harbor (BERRIEN)

County

Berrien

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

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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

54-0009-0020-08-2

Classification of Property: Real 

Commercial

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

2053600

Current Taxable Value as established by the Board of Review:

1946734

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

2040000

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

1020000

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

Parcel Number:

54-0009-0020-09-1

Classification of Property: Real 

Commercial

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

914400

Current Taxable Value as established by the Board of Review:

877793

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

900000

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

450000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification? 

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

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

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

If the State 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.

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

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