Clark Logistics Xxii, LLC, Petitioner Vs. City Of Kalamazoo, 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 XXII LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001707 

 

City of Kalamazoo, 

 

Presiding Judge 

Respondent. 

 

Joshua M. Wease 

 

 

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. 25-001707 

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%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

and (xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 

 

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: January 15, 2026 

jc 

 

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

63485730.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

CLARK LOGISTICS GROUP XXII, LLC, 

 

 

Petitioner, 

 

v 

MTT Docket No. 25-001707 

 

KALAMAZOO, 

 

 

Respondent. 

_____________________________/ 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

1. 

The parcel is located in Kalamazoo County. 

 

2. 

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

 

3. 

Property Parcel No: 06-25-496-001. 

 

4. 

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 

2025

$691,200

$345,600

$335,281

 

 

5. 

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

purposes are: 

 

Tax 

Year 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2025

$567,462

$283,731

$283,731

 

 

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 (attach additional page if necessary):

Page 2

MTT Docket No. 25-001707 

Stipulation for Entry of Consent Judgment 

 

 

 

2 

63485730.1 

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.: 

 

All interest due hereunder is waived if, and only if, all refunds otherwise due are paid 

within 60 days of the entry of the consent judgment, however, otherwise interest shall be 

paid as provided in the Tax Tribunal Act, including MCL 205.737. 

 

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 

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

CITY ATTORNEY

Attorneys for Petitioner

Attorneys for Respondent

 

 

By: _______________________________ 

By: _____________________________ 

Daniel L. Stanley (P57052) 

222 N. Washington Square 

Suite 400 

Lansing, MI 48933 

(517) 377-0714 

dstanley@honigman.com 

Aaron Leal (P58655) 

City Attorney 

Sarah R. Van Hyfte (P79316) 

Assistant City Attorney 

241 W. South Street 

Kalamazoo, MI 49007 

(269) 337-8185 

vanhyftkes@kalamazoocity.org 

 

 

 

 

 

 

 

 

 

 

/s/ Daniel L. Stanley 

 

 

 

 /s/ Sarah R. Van Hyfte (w/permission)

Dated: January 14, 2026 

 

 

 

 Dated: January 14, 2026

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Page 1

63485730.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

CLARK LOGISTICS GROUP XXII, LLC, 

 

 

Petitioner, 

 

v 

MTT Docket No. 25-001707 

 

KALAMAZOO, 

 

 

Respondent. 

_____________________________/ 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

1. 

The parcel is located in Kalamazoo County. 

 

2. 

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

 

3. 

Property Parcel No: 06-25-496-001. 

 

4. 

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 

2025

$691,200

$345,600

$335,281

 

 

5. 

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

purposes are: 

 

Tax 

Year 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2025

$567,462

$283,731

$283,731

 

 

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 (attach additional page if necessary):

Page 2

MTT Docket No. 25-001707 

Stipulation for Entry of Consent Judgment 

 

 

 

2 

63485730.1 

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.: 

 

All interest due hereunder is waived if, and only if, all refunds otherwise due are paid 

within 60 days of the entry of the consent judgment, however, otherwise interest shall be 

paid as provided in the Tax Tribunal Act, including MCL 205.737. 

 

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 

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

CITY ATTORNEY

Attorneys for Petitioner

Attorneys for Respondent

 

 

By: _______________________________ 

By: _____________________________ 

Daniel L. Stanley (P57052) 

222 N. Washington Square 

Suite 400 

Lansing, MI 48933 

(517) 377-0714 

dstanley@honigman.com 

Aaron Leal (P58655) 

City Attorney 

Sarah R. Van Hyfte (P79316) 

Assistant City Attorney 

241 W. South Street 

Kalamazoo, MI 49007 

(269) 337-8185 

vanhyftkes@kalamazoocity.org 

 

 

 

 

 

 

 

 

 

 

/s/ Daniel L. Stanley 

 

 

 

 /s/ Sarah R. Van Hyfte (w/permission)

Dated: January 14, 2026 

 

 

 

 Dated: January 14, 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

NOTICE OF NOVEMBER 2 - 13, 2026 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Clark Logistics XXII, LLC,

Petitioner,

v

 

 

City Of Kalamazoo,

Respondent.

 MTT Docket No. 25-001707

Please be advised that 25-001707 has been placed on a two-week Prehearing General 

Call commencing November 02, 2026. 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. 25-001707

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 July 6, 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 July 6, 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 

July 6, 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 

November 2, 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. “Post-Valuation Disclosure” discovery is limited to the opposing party’s 

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

on the opposing party’s Prehearing Statement.

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

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

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

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

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: December 1, 2025

Page 3

MTT Docket No. 25-001707

Page 3 of 3

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF NOVEMBER 2 - 13, 2026 PREHEARING GENERAL CALL AND ORDER 

OF

Page 5

MTT

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Page 1

RECEIVED 

JUL 01 2023 

MICHIGAN TAX TRIBUNAL 

June 25, 2025 

Clerk of the Court 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

Re: 

Clark Logistic Group XXII, LLC v. City of Kalamazoo 

MTT Docket No. 25-001707 

Dear Clerk: 

Enclosed please find Respondent City of Kalamazoo’s 1) Appearance 2) Answer and Affirmative 

Defenses and 3) Proof of Service to be filed in the above captioned matter. 

Thank you for your assistance. 

Sincerely, TA 

Carrie Funk 

Enclosures 

cc: Michael Shapiro

Page 2

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CLARK LOGISTICS GROUP XXII, LLC, 

Petitioner, 

v 

MTT DOCKET NO. 25-001707 

CITY OF KALAMAZOO, 

Respondent. 

/ 

Michael B. Shapiro (P20282) 

Aaron Leal (P58655) 

Daniel L. Stanley (P57052) 

CITY ATTORNEY 

39400 Woodward Avenue, Suite 101 

Sarah R. Van Hyfte (P79316) 

Bloomfield Hills, MI 48304-5151 

Assistant City Attorney 

(313) 465-7622 

241 W. South Street 

mshapiro@honigman.com 

Kalamazoo, MI 49007 

dstanley@honigman.com 

(269) 337-8185 

vanhyftes@kalamazoocity.org 

ANSWER TO PETITION and AFFIRMATIVE DEFENSES 

Respondent CITY OF KALAMAZOO, a Michigan municipal corporation, by and through 

its attorney, Sarah R. Van Hyfte, Assistant City Attorney, states in answer to the Petition filed in 

this Tribunal as follows: 

1. 

Admit in part, but deny that Petitioner’s property is located in Kent County, 

Michigan as it is located in Kalamazoo, Michigan. 

Admit, 

Admit. 

Respondent neither admits nor denies. 

Respondent neither admits nor denies.

Page 3

AFFIRMATIVE DEFENSES 

Respondent CITY OF KALAMAZOO states for its Affirmative Defense in this cause as 

follows: 

1. 

That the assessment in question for the subject property for the years in question 

is lawful, valid, and constitutional and was calculated using lawful, valid, and 

constitutional methods and procedures. 

2. 

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

3. 

The Respondent City reserves the right to amend these affirmative defenses 

following 

exchange 

of 

valuation 

disclosures, 

exchange 

of 

prehearing 

statements and any further discovery and information obtained by the City. 

Wherefore Respondent respectfully requests that the Tax Tribunal confirm the assessed 

values on the subject property as determined by the City Assessor and deny Petitioner’s request in 

its entirety. 

Dated: 

\o/ 95/ 8) 

OFFICE OF THE CITY ATTORNEY 

or Conch a, HS 

“Sarah R. Van Hyfte (P79316), 

Assistant City Attorney

Page 4

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CLARK LOGISTICS GROUP XXII, LLC, 

Petitioner, 

v 

CITY OF KALAMAZOO, 

Respondent. 

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 

MTT DOCKET NO. 25-001707 

Aaron Leal (P58655) 

CITY ATTORNEY 

Sarah R. Van Hyfte (P79316) 

Assistant City Attorney 

241 W. South Street 

Kalamazoo, MI 49007 

(269) 337-8185 

vanhyftes@kalamazoocity.org 

APPEARANCE 

The Office of the City Attorney, by Sarah R. Van Hyfte, Assistant City Attorney, enters its 

appearance on behalf of Respondent, City of Kalamazoo, in this matter. 

Date: (o/3 5/95 

Office of the City Attorney 

mah a Hig 

Sarah R. Van Hyfte (P79316) 

Assistant City Attorney 

241 W. South Street 

Kalamazoo, MI 49007 

269-337-8185

Page 5

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

CLARK LOGISTICS GROUP XXII, LLC, 

Petitioner, 

v 

MTT DOCKET NO. 25-001707 

CITY OF KALAMAZOO, 

Respondent. 

/ 

Michael B. Shapiro (P20282) 

Aaron Leal (P58655) 

Daniel L. Stanley (P57052) 

CITY ATTORNEY 

39400 Woodward Avenue, Suite 101 

Sarah R. Van Hyfte (P79316) 

Bloomfield Hills, MI 48304-5151 

Assistant City Attorney 

(313) 465-7622 

241 W. South Street 

mshapiro@honigman.com 

Kalamazoo, MI 49007 

dstanley@honigman.com 

(269) 337-8185 

vanhyftes@kalamazoocity.org 

PROOF OF SERVICE 

STATE OF MICHIGAN 

} 

} ss. 

COUNTY OF KALAMAZOO 

} 

25 

Carrie Funk, being duly sworn, deposes and says that on thet day of June 2025, she 

served the Respondent City of Kalamazoo’s Appearance and Answer with Affirmative Defenses 

upon Petitioner’s Attorney by mailing said documents to the address above, first class, United 

States mail, postage fully pre-paid. 

ran 

—/2_ 

Carrie Funk 

/ 

BUSINESS ADDRESS: 

241 W. South Street

Page 6

THE 

CITY 

OF 

Office of the City Attorne) 

241 W. South Street 

ly Kalamazoo, MI 49007-4707 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

: 

US POSTAGE-rmeyaowes 

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$ 000.622 

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0008040492 JUN 

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Page 1

RECEIVED _ 

JUN 05 2025 poe 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Clark Logistics Group XXII, LLC, 

Petitioner, 

v. 

MTT Docket No. 

2) Spe OO 290) 7 

[Parcel No(s). 06-25-496-001] 

Kalamazoo, 

Respondent. 

PROOF OF SERVICE 

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

that on 

[29 [5 < 

she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

KALAMAZOO 

241 W. SOUTH STREET 

KALAMAZOO, M149007-4796 

ASSESSOR 

KALAMAZOO 

241 W. SOUTH STREET 

KALAMAZOO, MI 49007-4796 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

KENT COUNTY 

201 W. KALAMAZOO AVENUE 

KALAMAZOO, MI 49007-3726 

DIRECTOR OF EQUALIZATION 

KENT COUNTY 

201 W. KALAMAZOO AVENUE 

KALAMAZOO, MI 49007-3726 

SECRETARY OF SCHOOL BOARD 

COMSTOCK PARK PUBLIC SCHOOLS 

101 SCHOOL STREET NE, P.O. BOX 800 

COMSTOCK PARK, MI 49321-9114 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0093

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Page 1

25-0093 

60694331.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Clark Logistics Group XXII, LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 06-25-496-001] 

Kalamazoo, 

Respondent. 

_________________________/ 

PETITION 

Clark Logistics Group XXII, 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). 06-

25-496-001 ("Petitioner's Property"), at 3600 E. Cork St. located in Kent County, Michigan. If 

this petition includes more than one (1) real property tax parcel, the tax parcels are contiguous. 

2. 

Respondent, Kalamazoo, assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$335,281 and assessed Petitioner's Property at $345,600, 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 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.

Page 2

2 

60694331.1 

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, 

(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.

Page 3

3 

60694331.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value of Petitioner's Property from $335,281 to $200,000, and reducing the 2025 assessed 

and state equalized value of Petitioner's Property from $345,600 to $200,000, 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 XXII, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001707

City Of Kalamazoo, 

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 22, 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

25-0093 

60694331.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Clark Logistics Group XXII, LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 06-25-496-001] 

Kalamazoo, 

Respondent. 

_________________________/ 

PETITION 

Clark Logistics Group XXII, 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). 06-

25-496-001 ("Petitioner's Property"), at 3600 E. Cork St. located in Kent County, Michigan. If 

this petition includes more than one (1) real property tax parcel, the tax parcels are contiguous. 

2. 

Respondent, Kalamazoo, assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$335,281 and assessed Petitioner's Property at $345,600, 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 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.

Page 2

2 

60694331.1 

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, 

(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.

Page 3

3 

60694331.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value of Petitioner's Property from $335,281 to $200,000, and reducing the 2025 assessed 

and state equalized value of Petitioner's Property from $345,600 to $200,000, 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 XXII, 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

Michael

M.I.

B

Last Name

Shapiro

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7622

Fax Number

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

mshapiro@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?1

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

Michigan

Taxing Authority (City or Township)

City Of Kalamazoo (KALAMAZOO)

County

Kalamazoo

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.)

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:

06-25-496-001

Classification of Property: Real 

Commercial

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

345600

Current Taxable Value as established by the Board of Review:

335281

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

400000

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

200000

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:

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?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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 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/ Michael B. Shapiro

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