Clawson Plaza, LLC Petitioner Vs. City Of Clawson Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

Clawson Plaza, LLC,

Petitioner,

v

 

 

City Of Clawson,

Respondent.

 MTT Docket No. 26-000666

Please be advised that 26-000666 has been placed on a two-week Prehearing General 

Call commencing September 16, 2027. Unless ordered otherwise, parties will be 

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

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

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

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

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

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

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

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

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

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

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

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

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

covered by the order will not be published.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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 26-000666

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 May 20, 2027. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

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

Statements by May 20, 2027. Witnesses, with the exception of rebuttal witnesses, will 

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

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

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

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

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

May 20, 2027, which means all discovery has been requested, all Motions to Compel 

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

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

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

during “Pre-Valuation Disclosure” discovery.

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

September 16, 2027, which means all discovery has been requested, all Motions to 

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

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

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

on the opposing party’s Prehearing Statement.

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

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

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

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

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 16, 2026

Page 3

MTT Docket No. 26-000666

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

Page 4

ST

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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

Clawson Plaza, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000666

City Of Clawson,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has considered the file in this case and finds that Respondent was held in 

default on August 13, 2026, 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: /s/ Patricia L. Halm

Entered: October 12, 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 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

Clawson Plaza, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000666

City Of Clawson,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has considered the file in this case and finds that Respondent was held in 

default on August 13, 2026, 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: /s/ Patricia L. Halm

Entered: October 12, 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

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 AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CLAWSON PLAZA, LLC, 

Petitioner, 

v 

CITY OF CLAWSON, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-000666 

Parcel Nos.: 16-20-33-354-053 

and 16-20-33-354-056 

 

RESPONDENT’S ANSWER TO PETITION 

AND AFFIRMATIVE DEFENSES 

 

(Entire Tribunal, 2026 Tax Year) 

Respondent, City of Clawson, by and through its attorney, Ren Nushaj of Troy Law Center, City 

Attorney for the City of Clawson, answers the Petition filed by Clawson Plaza, LLC as follows. 

The numbered paragraphs below correspond to the numbered paragraphs of the Petition. Any 

allegation not expressly admitted is denied. 

1. Admitted that the Petition purports to appeal the two contiguous parcels identified 

therein, and admitted that parcels 16-20-33-354-053 (1212 W. 14 Mile Rd.) and 16-20-

33-354-056 (1206 W. 14 Mile Rd.) are classified 201-Commercial on Respondent’s 2026 

assessment roll. 

2. Admitted that no protest of the 2026 assessment was made to Respondent’s March Board 

of Review. Respondent denies any implication that the absence of a protest relieves 

Petitioner of any jurisdictional or procedural prerequisite to invoking the Tribunal’s 

jurisdiction. 

3. Admitted. 

4. Admitted. 

5. Admitted only that Petitioner appears as the record title holder of the subject parcels on 

Respondent’s assessment roll. To the extent this paragraph states a legal conclusion 

regarding Petitioner’s status as a party-in-interest, no response is required; to the extent a 

response is required, Respondent leaves Petitioner to its proofs, which has the effect of a 

denial under R 792.10235(2). 

6. Respondent is without knowledge or information sufficient to form a belief as to the truth 

of the allegations in this paragraph, which has the effect of a denial under R 

792.10235(2).

Page 2

7. Admitted only that Petitioner has checked the box indicating that this appeal involves the 

subject property’s true cash and taxable values. To the extent this paragraph alleges that 

the values on Respondent’s 2026 assessment roll are incorrect, excessive, or unlawful, 

the allegations are denied. 

8. Admitted. 

9. Admitted that an attachment is appended to the Petition. Respondent admits that the true 

cash, state equalized, and taxable values set forth in the columns designated 

“Respondent” accurately reflect the values placed on the subject parcels on Respondent’s 

2026 assessment roll as finally determined. Respondent denies Petitioner’s contended 

values and denies the amounts stated under “Values in Dispute,” and affirmatively states 

that the values placed on the roll are lawful, uniform, and reflective of the subject 

parcels’ true cash value. 

10. Denied. Respondent specifically denies that the 2026 values, or the taxes levied and 

collected thereon, are invalid, unlawful, or operate as a fraud upon the taxpayer, and 

denies each of the subparagraphs as follows: 

a. Denied. 

b. Denied. 

c. Denied. Respondent affirmatively states that the subject parcels were assessed in 

accordance with the Michigan Constitution, the General Property Tax Act, and 

the assessment methodology approved by the State Tax Commission. 

d. Denied. Respondent further states that the allegations of this subparagraph are 

conclusory and are unsupported by any factual allegation identifying a 

comparable class of property, a mode of assessment, or any disparate treatment. 

e. Denied. Respondent affirmatively states that the taxable value of the subject 

parcels was lawfully uncapped under MCL 211.27a(3) following a transfer of 

ownership within the meaning of MCL 211.27a(6); that no exception set forth in 

MCL 211.27a(7) applies to the conveyance at issue; that MCL 211.27a(7)(k) is 

inapplicable on its face to the subject commercial parcels; and that Petitioner 

bears the burden of proving entitlement to any claimed exception. 

 

WHEREFORE, Respondent, City of Clawson, respectfully requests that the Tribunal deny the 

relief requested in the Petition, affirm the true cash, state equalized, and taxable values placed on 

the subject parcels for the 2026 tax year, determine the true cash value of the subject parcels to 

be not less than the values set forth on Respondent’s 2026 assessment roll, and grant Respondent 

such other relief as the Tribunal deems just, including costs. 

RESPONDENT’S CONTENTION OF VALUE 

Respondent contends that the following values are the correct true cash, state equalized, and 

taxable values of the subject parcels for the 2026 tax year:

Page 3

Petitioner’s Contention 

Respondent’s Contention 

Parcel Number 

TCV 

SEV 

TV 

TCV 

SEV 

TV 

16-20-33-354-053 

1,600,000 

800,000 

800,000 

2,848,820 

1,424,410 

1,424,410 

16-20-33-354-056 

700,000 

350,000 

350,000 

1,197,620 

598,810 

598,810 

Totals 

2,300,000 

1,150,000 

1,150,000 

4,046,440 

2,023,220 

2,023,220 

 

Respondent reserves the right to amend its contention of value upon completion of discovery, 

appraisal, and valuation analysis, including the right to contend for values greater than those set 

forth above. 

 

Respectfully submitted, 

/s/ Ren Nushaj 

 

REN NUSHAJ (P72986) 

City Attorney, City of Clawson 

Attorney for Respondent 

5960 Livernois Rd. 

Troy, MI 48098 

(248) 649-1000 

Ren@TroyLawCenter.com 

Dated: August 26, 2026

Page 4

AFFIRMATIVE AND SPECIAL DEFENSES 

Respondent, City of Clawson, states the following affirmative and special defenses, without 

assuming any burden of proof

Page 5

10.

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000666

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Clawson (OAKLAND)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Renis

M.I.

Last Name

Nushaj

Firm Name (if any)

Troy Law Center

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

5960 Livernois Rd.

City or Town

Troy

State

 Michigan

ZIP Code

48098

Telephone Number

2486491000

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

Ren@troylawcenter.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Renis Nushaj

/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

Clawson Plaza, LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000666

City Of Clawson,

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.1 

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: /s/ Patricia L. Halm

Entered: August 13, 2026

1 “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. 

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 2

MTT Docket No. 26-000666

Page 2 of 2

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

Clawson Plaza, LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000666

City Of Clawson,

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.2 

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: /s/ Patricia L. Halm

Entered: August 13, 2026

2 “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. 

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 4

MTT Docket No. 26-000666

Page 2 of 2

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 

 

 

Clawson Plaza LLC, 

 

Petitioner, 

 

vs. 

 

City of Clawson, 

Respondent.

 

 

 

MTT Docket No. 26-000666 

 

_____________________________________________________________________________/ 

 

 

PROOF OF SERVICE 

(Property Tax Petition) 

 

On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: 

 

City Assessor 

City of Clawson 

425 N. Main St. 

Clawson, MI 48017

City Clerk 

City of Clawson 

425 N. Main St. 

Clawson, MI 48017

 

On the date below I sent by first class mail a copy of the Petition to: 

 

Equalization Director 

Oakland County 

250 Elizabeth Lake Rd, Ste 1000W 

Pontiac, MI 48341 

County Clerk 

Oakland County 

1200 N. Telegraph Rd, Bldg 12E 

Pontiac, MI 48341 

Secretary, Board of Education 

Clawson Public Schools 

101 Phillips Avenue 

Clawson, MI 48017

State Treasurer 

Department of Treasury 

430 W. Allegan Street 

Lansing, MI 48922

 

I declare that the statements above are true to the best of my information, knowledge and belief. 

 

 

 

/s/ Laura M. Hallahan 

 

Dated: June 30, 2026

Page 2

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

CLAWSON PLAZA, LLC, 

Petitioner, 

v 

CITY OF CLAWSON, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-000666______ 

Parcel No.: 16-20-33-354-053, 

and additional parcels 

_____________________________________________________________________________/ 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. The property that is the subject of this appeal consists of these contiguous real property

parcels:

REAL PROPERTY - CONTIGUOUS 

Parcel Number 

Address 

Classification 

Use 

16-20-33-354-053

1212 W. 14 Mile Rd. 

201-Commercial

Retail 

16-20-33-354-056

1206 W. 14 Mile Rd. 

201-Commercial

Retail 

2. ☒ N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s:

☐March, ☐ July, ☐ December Board of Review.

3. Respondent, identified above, assesses and collects taxes on the subject property.

4. The subject property is located in the County of Oakland and school district of Clawson City

School District.

5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property.

6. The Petitioner’s principal office/legal residence address is: 4036 Telegraph Rd. Suite 201,

Bloomfield Hills, MI 48302.

Page 3

2 

7. This appeal involves issues related to: 

☒ the subject property’s true cash and taxable values 

☐ the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ uniformity of the subject property’s assessment 

☐ the subject property’s exemption from ad valorem taxation under MCL ______ 

8. The tax year at issue is 2026. 

9. The subject property is listed on the attachment, including, by parcel number: 

a. 

Respondent’s Board of Review established values, 

b. 

Petitioner’s value contentions, and 

c. 

Values in dispute. 

10. Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: 

a. 

The assessed, state equalized and/or taxable values exceed the amounts permitted by the 

Michigan Constitution and applicable statutes; 

b. 

The assessed, state equalized and/or taxable values are at higher percentages of true cash 

value than permissible under the Michigan Constitution and applicable statutes; 

c. 

The assessed, state equalized and/or taxable values 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; 

d. 

The assessed, state equalized and/or taxable values, and the mode of assessment adopted 

by Respondent, discriminate against Petitioner and deny Petitioner its constitutional 

rights of uniformity, equal protection and due process of law; and 

e. 

The taxable value of the parcels were unlawfully uncapped as the transfer was exempt 

pursuant to MCL 211.27a (7)(k) and (m).

Page 4

3 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: April 20, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $625

Page 5

4 

ATTACHMENT TO PETITION 

(Subject Property) 

 

 

VALUES 

Respondent’s Board of Review -and- Petitioner’s Contention 

Parcel Number 

Respondent 

Petitioner 

TCV 

SEV 

TV 

TCV 

SEV 

TV 

16-20-33-354-053 

2,848,820 

1,424,410 

1,424,410 

1,600,000 

800,000 

800,000 

16-20-33-354-056 

1,197,620 

598,810 

598,810 

700,000 

350,000 

350,000 

 

 

 

 

 

 

 

Totals 

4,046,440 

2,023,220 

2,023,220 

2,300,000 

1,150,000 

1,150,000 

 

 

VALUES IN DISPUTE 

Parcel Number 

TCV 

SEV 

TV 

16-20-33-354-053 

1,248,820 

624,410 

624,410 

16-20-33-354-056 

497,620 

248,810 

248,810 

 

 

 

 

Totals 

1,746,440 

873,220 

873,220

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: 26-000666

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Petition - POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

 

CLAWSON PLAZA, LLC, 

 

Petitioner, 

 

v 

 

CITY OF CLAWSON, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-____________ 

Parcel No.: 16-20-33-354-053, 

and additional parcels 

_____________________________________________________________________________/ 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. The property that is the subject of this appeal consists of these contiguous real property 

parcels: 

REAL PROPERTY - CONTIGUOUS 

Parcel Number 

Address 

Classification 

Use 

16-20-33-354-053 

1212 W. 14 Mile Rd. 

201-Commercial Retail 

16-20-33-354-056 

1206 W. 14 Mile Rd. 

201-Commercial Retail 

 

2. ☒ N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. Respondent, identified above, assesses and collects taxes on the subject property. 

4. The subject property is located in the County of Oakland and school district of Clawson City 

School District. 

5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 

6. The Petitioner’s principal office/legal residence address is: 4036 Telegraph Rd. Suite 201, 

Bloomfield Hills, MI 48302.

Page 2

2 

7. This appeal involves issues related to: 

☒ the subject property’s true cash and taxable values 

☐ the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ uniformity of the subject property’s assessment 

☐ the subject property’s exemption from ad valorem taxation under MCL ______ 

8. The tax year at issue is 2026. 

9. The subject property is listed on the attachment, including, by parcel number: 

a. 

Respondent’s Board of Review established values, 

b. 

Petitioner’s value contentions, and 

c. 

Values in dispute. 

10. Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: 

a. 

The assessed, state equalized and/or taxable values exceed the amounts permitted by the 

Michigan Constitution and applicable statutes; 

b. 

The assessed, state equalized and/or taxable values are at higher percentages of true cash 

value than permissible under the Michigan Constitution and applicable statutes; 

c. 

The assessed, state equalized and/or taxable values 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; 

d. 

The assessed, state equalized and/or taxable values, and the mode of assessment adopted 

by Respondent, discriminate against Petitioner and deny Petitioner its constitutional 

rights of uniformity, equal protection and due process of law; and 

e. 

The taxable value of the parcels were unlawfully uncapped as the transfer was exempt 

pursuant to MCL 211.27a (7)(k) and (m).

Page 3

3 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: April 20, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $625

Page 4

4 

ATTACHMENT TO PETITION 

(Subject Property) 

 

 

VALUES 

Respondent’s Board of Review -and- Petitioner’s Contention 

Parcel Number 

Respondent 

Petitioner 

TCV 

SEV 

TV 

TCV 

SEV 

TV 

16-20-33-354-053 

2,848,820 

1,424,410 

1,424,410 

1,600,000 

800,000 

800,000 

16-20-33-354-056 

1,197,620 

598,810 

598,810 

700,000 

350,000 

350,000 

 

 

 

 

 

 

 

Totals 

4,046,440 

2,023,220 

2,023,220 

2,300,000 

1,150,000 

1,150,000 

 

 

VALUES IN DISPUTE 

Parcel Number 

TCV 

SEV 

TV 

16-20-33-354-053 

1,248,820 

624,410 

624,410 

16-20-33-354-056 

497,620 

248,810 

248,810 

 

 

 

 

Totals 

1,746,440 

873,220 

873,220

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

Clawson Plaza, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000666

City Of Clawson, 

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: May 27, 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

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

Page 1

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

 

CLAWSON PLAZA, LLC, 

 

Petitioner, 

 

v 

 

CITY OF CLAWSON, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-____________ 

Parcel No.: 16-20-33-354-053, 

and additional parcels 

_____________________________________________________________________________/ 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. The property that is the subject of this appeal consists of these contiguous real property 

parcels: 

REAL PROPERTY - CONTIGUOUS 

Parcel Number 

Address 

Classification 

Use 

16-20-33-354-053 

1212 W. 14 Mile Rd. 

201-Commercial Retail 

16-20-33-354-056 

1206 W. 14 Mile Rd. 

201-Commercial Retail 

 

2. ☒ N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. Respondent, identified above, assesses and collects taxes on the subject property. 

4. The subject property is located in the County of Oakland and school district of Clawson City 

School District. 

5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 

6. The Petitioner’s principal office/legal residence address is: 4036 Telegraph Rd. Suite 201, 

Bloomfield Hills, MI 48302.

Page 2

2 

7. This appeal involves issues related to: 

☒ the subject property’s true cash and taxable values 

☐ the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ uniformity of the subject property’s assessment 

☐ the subject property’s exemption from ad valorem taxation under MCL ______ 

8. The tax year at issue is 2026. 

9. The subject property is listed on the attachment, including, by parcel number: 

a. 

Respondent’s Board of Review established values, 

b. 

Petitioner’s value contentions, and 

c. 

Values in dispute. 

10. Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: 

a. 

The assessed, state equalized and/or taxable values exceed the amounts permitted by the 

Michigan Constitution and applicable statutes; 

b. 

The assessed, state equalized and/or taxable values are at higher percentages of true cash 

value than permissible under the Michigan Constitution and applicable statutes; 

c. 

The assessed, state equalized and/or taxable values 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; 

d. 

The assessed, state equalized and/or taxable values, and the mode of assessment adopted 

by Respondent, discriminate against Petitioner and deny Petitioner its constitutional 

rights of uniformity, equal protection and due process of law; and 

e. 

The taxable value of the parcels were unlawfully uncapped as the transfer was exempt 

pursuant to MCL 211.27a (7)(k) and (m).

Page 3

3 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: April 20, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $625

Page 4

4 

ATTACHMENT TO PETITION 

(Subject Property) 

 

 

VALUES 

Respondent’s Board of Review -and- Petitioner’s Contention 

Parcel Number 

Respondent 

Petitioner 

TCV 

SEV 

TV 

TCV 

SEV 

TV 

16-20-33-354-053 

2,848,820 

1,424,410 

1,424,410 

1,600,000 

800,000 

800,000 

16-20-33-354-056 

1,197,620 

598,810 

598,810 

700,000 

350,000 

350,000 

 

 

 

 

 

 

 

Totals 

4,046,440 

2,023,220 

2,023,220 

2,300,000 

1,150,000 

1,150,000 

 

 

VALUES IN DISPUTE 

Parcel Number 

TCV 

SEV 

TV 

16-20-33-354-053 

1,248,820 

624,410 

624,410 

16-20-33-354-056 

497,620 

248,810 

248,810 

 

 

 

 

Totals 

1,746,440 

873,220 

873,220

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 - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Clawson Plaza, LLC

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

4036 Telegraph Road, Suite 210

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302-2073

Telephone Number

2487018529

Fax Number

248 731 -3090

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

lhallahan@hallahanlaw.com

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

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]

1212 W. 14 Mile Road

Clwson

Michigan

Taxing Authority (City or Township)

City Of Clawson (OAKLAND)

County

Oakland

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:

16-2033-354-053

Classification of Property: Real 

Commercial

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

1424410

Current Taxable Value as established by the Board of Review:

1424410

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

1600000

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

8000000

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

Parcel Number:

16-20-33-354-056

Classification of Property: Real 

Commercial

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

598810

Current Taxable Value as established by the Board of Review:

598810

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

700000

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

350000

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 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/ Laura M Hallahan

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.