Clinton Detroit LLC Petitioner Vs. City Of Detroit Respondent

Page 1

1 

 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CLINTON DETROIT LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001116 

 

Respondent. 

 

 

 

Parcel No. 1000216 

____________________________________________________________________________/ 

ANSWER TO PETITION and 

AFFIRMATIVE DEFENSES 

Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer 

to the Petition filed in this matter states the following: 

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

2. Respondent admits as true. 

3. Respondent denies as untrue as there is only 1 parcel under appeal. 

4. No response is required. 

5. No response is required. 

6. Respondent admits as true. 

7. Respondent admits as true. 

8. No response is required. 

9. No response is required. 

10. Respondent admits as true. 

11. Respondent admits as true.

Page 2

2 

 

12. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

13. Respondent admits that that this appeal contains issues of the properties’ taxable 

value and true cash values as it relates to the subject property, but further states that 

these allegations lack merit. 

14. Respondent admits as true. 

15. No response is required. 

16. Respondent admits as true. 

17. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

18. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

19. Respondent respectfully requests that the Michigan Tax Tribunal deny Petitioner’s 

requests for relief and dismiss this petition or in the alternative grant any such other 

and further relief as is just and equitable. 

20. Respondent denies as untrue the allegations contained in sub-paragraphs a and b. 

CONCLUSION and REQUEST FOR RELIEF 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

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

Dated: September 10, 2026 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

Page 3

3 

 

AFFIRMATIVE DEFENSES 

 

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

Defenses to the Petitioner’s claims: 

1. 

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

2. 

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

3. 

This Tribunal lacks subject matter jurisdiction. 

 

4. 

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

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

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

Dated: 

September 10, 2026 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

313.237.3075 

 

 

 

 

 

 

cobbm@detroitmi.gov

Page 4

4 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CLINTON DETROIT LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-00116 

 

Respondent. 

 

 

 

Parcel No. 01000216 

____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

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

Affirmative Defenses to: 

 

 

 

 

 

Sarah R. Belloli 

 

 

 

 

 

101 West Big Beaver Road, 

 

 

 

 

 

Suite 945 

 

 

 

 

 

Troy, MI 48084 

 

 

 

 

 

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

belief. 

 

Dated: September 10, 2026 

 

 

 

 

 

 /s/Mary Beth Cobbs 

 

 

 

 

 

 

Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001116

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City of Detroit (Wayne)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Mary Beth

M.I.

Last Name

Cobbs

Firm Name (if any)

City of Detroit

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

2 Woodward Avenue

Suite 500

City or Town

Detroit

State

 Michigan

ZIP Code

48226

Telephone Number

(313) 237-3075

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

cobbm@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

Mary Beth Cobbs

/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

Clinton Detroit LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001116

City of Detroit,

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: September 4, 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. 26-001116

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

Clinton Detroit LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001116

City of Detroit,

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: September 4, 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. 26-001116

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

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Tel. (313) 230-0104 

Fax CRECETVED 

July 13,2026 

JUL 15 2026 

State of Michigan Treasurer 

MICHIGAN TAX TRIBUNAL 

Treasury Building, 430 West Allegan Street 

Lansing, MI 48922 

- 

Re: CLINTON DETROIT LLC v City of Detroit 

MTT Docket No.: 26-001116 

Dear Chief Clerk: 

Petitioner hereby serves all parties provided for in Michigan Tax Tribunal Rule 221 with its petition in 

this matter. Pursuant to the rule, the petition notes the docket number assigned by the Tribunal and is 

served within 45-days of the issuance of the notice of docket number. 

If you have any questions regarding the enclosed pleading, please do not hesitate to contact our office 

directly at (313) 230-0104. 

Respectfully, 

Sarah R. Belloli 

Ryan, LLC 

cc: 

State of Michigan Treasurer 

Detroit City School District 

Wayne County Equalization Director 

‘Wayne County Clerk 

City of Detroit Assessor 

City of Detroit Clerk 

Enclosures

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

CLINTON DETROIT LLC, 

MTT Docket No.: 26-001116 

Petitioner, 

v 

City of Detroit, 

Respondent. 

Proof of Service 

Joan Kleiner, being duly sworn, deposes and says that on July 13, 2026, she served a copy of the Petition with noted 

docket number relative to the above-captioned matter upon the following parties as required by the Tribunal’s 

service rules: 

VIA CERTIFIED MAIL 

City of Detroit Assessor: 

City of Detroit Assessor, 2 Woodward Ave, Suite 804, Detroit, MI 48226 

City of Detroit Clerk: 

City of Detroit Clerk , 2 Woodward Ave, Suite 804, Detroit, MI 48226 

VIA FIRST-CLASS MAIL 

Wayne County Equalization Director: 

Wayne County Equalization Director, 400 Monroe St, Detroit, MI 48226 

Wayne County Clerk: 

Wayne County Clerk, 2 Woodward Ave, Detroit, MI 48226 

Detroit City School District — School Board Secretary: 

3011 W Grand Blvd, Detroit, MI 48202 

‘Treasurer of the State of Michigan: 

State of Michigan Treasurer, Treasury Building, 430 West Allegan Street, Lansing, MI 48922 

With proper postage affixed thereto. Proof of service submitted within 45 days after issuance of the notice of docket number as 

required by the Tribunals service rules. 

/s/ Joan Kleiner 

Joan Kleiner 

July 13, 2026

Page 3

101 West Big Beaver Road 

Suite 945 

Ryan )) 

Troy, Michigan 48084 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

R €Ceiveq 

JL 15 ggg 

LAR

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 

CLINTON DETROIT LLC, 

Petitioner(s) 

v 

City of Detroit, 

Respondent(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. Property Parcel No: 01000216.

2. The property identified above is ☑ real ☐ personal.

3. If more than one parcel of real property is under appeal, are the properties

contiguous? ☑ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.)

N/A 

4. Are all of the parcels of personal property located on a parcel of real property under

appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not

located on a parcel of real property under appeal.) 

N/A 

5. If parcels of personal property are under appeal, when were the personal property statements filed by

parcel number (attach additional page if necessary):

N/A 

6. The property identified above is classified as 201 Commercial-Improved

7. If the assessment or assessments at issue were protested, the protest was made to

Respondent’s ☐ March ☐ July ☐ December Board of Review.

No protest to the Board of Review was required. 

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

Page 2

MTT Docket No. ____________________ 

Page 2 of 4 

8. If a protest was required and no protest was made, list the separate and specific facts upon which

Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach

additional page if necessary):

N/A 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or

classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate

and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or

assessments at issue (attach additional page if necessary):

N/A 

10. The property or properties at issue are located in Wayne County. The property’s address is:

428 Clinton, Detroit, MI 48226

11. The assessment or assessments at issue were established by the (applicable local governmental unit):

City of Detroit

12. Petitioner’s legal residence or principal office address is:

4327 Delemere Ct,Ste 100,Royal Oak , MI 48073

13. This appeal involves issues relating to the (check all that are applicable):

☑the property or properties’ true cash and taxable values

☐the property or properties’ taxable value only

If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or

loss? ☐ Yes ☑ No

☐uniformity of the property or properties’ assessment

☐the property or the properties’ exemption from ad valorem taxation under MCL ______

14. The tax year(s) at issue are: 2026

Page 3

MTT Docket No. ____________________ 

Page 3 of 4 

15. If more than the current tax year is being appealed, list the separate and specific facts upon which

Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page

if necessary):

N/A 

16. The values for the property identified above as established by Respondent’s Board of Review are:

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$2,368,000 

$1,184,000 

$1,184,000 

17. Petitioner contends that the values for the property identified above are:

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$500,000 

$250,000 

$250,000 

18. The values in dispute for the property identified above are:

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$1,868,000 

$934,000 

$934,000 

19. Petitioner requests the following relief (attach additional page if necessary):

Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set

forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess

of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just

and equitable.

20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach

additional page if necessary):

A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash

value in violation of the applicable statutory and constitutional limitations.

B. The assessment is based on improper or inaccurate valuation methodology, including but not

limited to the use of non-representative data, failure to account for relevant property characteristics,

and/or application of incorrect assumptions. As a result, the assessment is not uniform with

comparable properties and results in an excessive and unlawful tax burden.

Page 4

MTT Docket No. ____________________ 

Page 4 of 4 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Sarah R. Belloli 

Email Address: 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

Mailing Address: 

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Telephone Number: 

(313) 230-0104

Date: 

2026-05-19

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

CLINTON DETROIT LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

Ryan LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

428 Clinton

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48226

Taxing Authority (City or Township)

City of Detroit (Wayne) 

County

Wayne

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

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

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

01000216.

Classification of Property: Real (check one)

Commercial (check one)

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

1184000

Current Taxable Value as established by the Board of Review:

1184000

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

500000

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

250000

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

Fee Information

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

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

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Sarah R. Belloli

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051986124867

Supporting Waiver Documents:

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

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

Clinton Detroit LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001116

City of Detroit, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 21, 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

Sarah Belloli

Ryan LLC

101 W. Big Beaver

Suite 945

Troy , MI 48048

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 

CLINTON DETROIT LLC, 

Petitioner(s) 

v 

City of Detroit, 

Respondent(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. Property Parcel No: 01000216.

2. The property identified above is ☑ real ☐ personal.

3. If more than one parcel of real property is under appeal, are the properties

contiguous? ☑ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.)

N/A 

4. Are all of the parcels of personal property located on a parcel of real property under

appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not

located on a parcel of real property under appeal.) 

N/A 

5. If parcels of personal property are under appeal, when were the personal property statements filed by

parcel number (attach additional page if necessary):

N/A 

6. The property identified above is classified as 201 Commercial-Improved

7. If the assessment or assessments at issue were protested, the protest was made to

Respondent’s ☐ March ☐ July ☐ December Board of Review.

No protest to the Board of Review was required. 

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

Page 2

MTT Docket No. ____________________ 

Page 2 of 4 

8. If a protest was required and no protest was made, list the separate and specific facts upon which

Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach

additional page if necessary):

N/A 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or

classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate

and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or

assessments at issue (attach additional page if necessary):

N/A 

10. The property or properties at issue are located in Wayne County. The property’s address is:

428 Clinton, Detroit, MI 48226

11. The assessment or assessments at issue were established by the (applicable local governmental unit):

City of Detroit

12. Petitioner’s legal residence or principal office address is:

4327 Delemere Ct,Ste 100,Royal Oak , MI 48073

13. This appeal involves issues relating to the (check all that are applicable):

☑the property or properties’ true cash and taxable values

☐the property or properties’ taxable value only

If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or

loss? ☐ Yes ☑ No

☐uniformity of the property or properties’ assessment

☐the property or the properties’ exemption from ad valorem taxation under MCL ______

14. The tax year(s) at issue are: 2026

Page 3

MTT Docket No. ____________________ 

Page 3 of 4 

15. If more than the current tax year is being appealed, list the separate and specific facts upon which

Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page

if necessary):

N/A 

16. The values for the property identified above as established by Respondent’s Board of Review are:

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$2,368,000 

$1,184,000 

$1,184,000 

17. Petitioner contends that the values for the property identified above are:

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$500,000 

$250,000 

$250,000 

18. The values in dispute for the property identified above are:

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$1,868,000 

$934,000 

$934,000 

19. Petitioner requests the following relief (attach additional page if necessary):

Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set

forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess

of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just

and equitable.

20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach

additional page if necessary):

A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash

value in violation of the applicable statutory and constitutional limitations.

B. The assessment is based on improper or inaccurate valuation methodology, including but not

limited to the use of non-representative data, failure to account for relevant property characteristics,

and/or application of incorrect assumptions. As a result, the assessment is not uniform with

comparable properties and results in an excessive and unlawful tax burden.

Page 4

MTT Docket No. ____________________ 

Page 4 of 4 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Sarah R. Belloli 

Email Address: 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

Mailing Address: 

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Telephone Number: 

(313) 230-0104

Date: 

2026-05-19

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

CLINTON DETROIT LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

Ryan LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

428 Clinton

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48226

Taxing Authority (City or Township)

City of Detroit (Wayne) 

County

Wayne

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

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

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

01000216.

Classification of Property: Real (check one)

Commercial (check one)

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

1184000

Current Taxable Value as established by the Board of Review:

1184000

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

500000

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

250000

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

Fee Information

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

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

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Sarah R. Belloli

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051986124867

Supporting Waiver Documents:

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