Comerica Ahoc LLC, Petitioner Vs. City Of Auburn Hills, Respondent

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

COMERICA AHOC LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF AUBURN HILLS, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001845 

Parcel No. 02-14-25-226-001 

 

_____________________________________________________________________________/ 

 

MARK T. MCMERRELL 

RYAN LLC 

Representative for Petitioner 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

(216) 685-9448 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE 

PENDING MTT DOCKET NO. 24-002164 

 

The parties by and through their respective counsel state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of commercial property 

located in Oakland County—parcel no. 02-14-25-226-001. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT docket no. 24-002164—an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

Page 2

2 

 

4. 

However, as of the filing of the above captioned Motion, the 2024 reiteration 

(MTT docket no. 24-002164) has not yet been resolved. The 2024 reiteration is proceeding in 

accordance with the March 16-31, 2026 Prehearing General Call with valuation disclosures and 

prehearing statements due November 17, 2025. Accordingly, the 2024 reiteration will likely not 

proceed to hearing until the spring of next year and a Final Opinion and Judgment will likely not 

be rendered until Fall 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT docket no. 24-

002164 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed 

with the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT docket no. 24-

002164 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the 

above captioned appeal in abeyance at this juncture before substantial time and resources have 

been spent—including, but not limited to, the preparation of prehearing statements and valuation 

disclosures—is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this joint Motion to hold the 

above captioned appeal in abeyance pending the resolution of its 2024 iteration, MTT docket no. 

24-002164. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT docket no. 24-002164.

Page 3

3 

 

Respectfully submitted, 

/s/Mark T. McMerrell (w/permission) 

 /s/Laura M. Hallahan 

 

 

MARK T. MCMERRELL 

RYAN LLC 

Representative for Petitioner 

 

 

 

Dated: October 17, 2025 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

 

Dated: October 17, 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 

Comerica AHOC LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001845 

 

City of Auburn Hills, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

On October 17, 2025, the parties filed a joint motion requesting that the Tribunal hold 

this case in abeyance pending resolution of MTT Docket No. 24-002164, which is 

currently pending before the Tribunal. In the motion, the parties state that the above-

mentioned case pertains to the same parties, property, and claims as the subject 

appeal, and its resolution could impact the proceedings in this matter. MTT Docket No. 

24-002164 has valuation disclosures and prehearing statements due on November 17, 

2025. Further, it will not be scheduled for a hearing until March 2026, and a Final 

Opinion and Judgment will likely not be issued until Fall 2026 at the earliest. 

Proceeding in this matter could waste time and resources for both the parties and the 

Tribunal while MTT Docket No. 24-002164 remains pending. 

 

The Tribunal has considered the motion and the case file and finds that placing this 

case in abeyance pending resolution of MTT Docket No. 24-002164 will facilitate the 

efficient administration of justice, as that resolution may have a direct bearing on the 

outcome of the instant appeal. Therefore, 

 

IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of the resolution of MTT Docket No. 24-002164 as to the need for further 

proceedings in this matter. 

 

Entered: October 22, 2025 

 

 

By _____________________________ 

cs 

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 

MICHIGAN TAX TRIBUNAL 

 

COMERICA AHOC LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF AUBURN HILLS, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001845 

Parcel No. 02-14-25-226-001 

 

_____________________________________________________________________________/ 

 

MARK T. MCMERRELL 

RYAN LLC 

Representative for Petitioner 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

(216) 685-9448 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE 

PENDING MTT DOCKET NO. 24-002164 

 

The parties by and through their respective counsel state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of commercial property 

located in Oakland County—parcel no. 02-14-25-226-001. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT docket no. 24-002164—an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

Page 2

2 

 

4. 

However, as of the filing of the above captioned Motion, the 2024 reiteration 

(MTT docket no. 24-002164) has not yet been resolved. The 2024 reiteration is proceeding in 

accordance with the March 16-31, 2026 Prehearing General Call with valuation disclosures and 

prehearing statements due November 17, 2025. Accordingly, the 2024 reiteration will likely not 

proceed to hearing until the spring of next year and a Final Opinion and Judgment will likely not 

be rendered until Fall 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT docket no. 24-

002164 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed 

with the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT docket no. 24-

002164 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the 

above captioned appeal in abeyance at this juncture before substantial time and resources have 

been spent—including, but not limited to, the preparation of prehearing statements and valuation 

disclosures—is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this joint Motion to hold the 

above captioned appeal in abeyance pending the resolution of its 2024 iteration, MTT docket no. 

24-002164. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT docket no. 24-002164.

Page 3

3 

 

Respectfully submitted, 

/s/Mark T. McMerrell (w/permission) 

 /s/Laura M. Hallahan 

 

 

MARK T. MCMERRELL 

RYAN LLC 

Representative for Petitioner 

 

 

 

Dated: October 17, 2025 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

 

Dated: October 17, 2025

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

COMERICA AHOC LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF AUBURN HILLS, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001845 

Parcel No. 02-14-25-226-001 

 

_____________________________________________________________________________/ 

 

MARK T. MCMERRELL 

RYAN LLC 

Representative for Petitioner 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

(216) 685-9448 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Auburn Hills, by and through its attorneys, Hallahan & Associates, 

P.C., responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent states only a single parcel of property has been identified as under 

appeal. 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 for the reason 

that no allegations are set forth and, thus, no responsive pleading is required.

Page 2

2

5. 

Respondent admits the allegations in Paragraph 5. 

6. 

Respondent admits the allegations in Paragraph 6. 

7. 

Respondent neither admits nor denies the allegations in Paragraph 7 for the reason 

that no allegations are set forth and, thus, no responsive pleading is required. 

8. 

Respondent neither admits nor denies the allegations in Paragraph 8 for the reason 

that no allegations are set forth and, thus, no responsive pleading is required. 

9. 

Respondent neither admits nor denies the allegations in Paragraph 9 for the reason 

that no allegations are set forth and, thus, no responsive pleading is required. 

10. 

Respondent admits the allegations in Paragraph 10. 

11. 

Respondent admits the allegations in Paragraph 11. 

12. 

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

truth of the allegations set forth in Paragraph 12 and, therefore, leaves Petitioner to its proofs. 

13. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 13 but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief. 

14. 

Respondent acknowledges Petitioner’s identification of the 2025 tax year as being 

at issue but denies an issue with the identified tax year. 

15. 

Respondent neither admits nor denies the allegations in Paragraph 15 for the reason 

that no allegations are set forth and, thus, no responsive pleading is required. 

16. 

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 

$38,705,240 

$19,352,620 

$13,694,590

Page 3

3

17. 

Respondent contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$38,705,240 

$19,352,620 

$13,694,590 

18. 

The values in dispute are as follows: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$0 

$0 

$0 

19. 

Respondent acknowledges the relief requested by Petitioner via Paragraph 19 but 

denies that Petitioner is entitled to said relief for the reasons set forth above. In further answer, the 

assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed 

the percentage of true cash value permitted by law, were correctly determined and are based upon 

correct application of proper principles, and the values and Respondent’s mode of assessment are 

non-discriminatory and constitutional. 

20. 

Respondent denies the allegations in Paragraph 20 for the reason that the same are 

untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed 

permitted amounts, do not exceed the percentage of true cash value permitted by law, were 

correctly determined and are based upon correct application of proper principles, and the values 

and Respondent’s mode of assessment are non-discriminatory and constitutional. 

 

WHEREFORE, Respondent, City of Auburn Hills, requests the Tribunal dismiss the 

Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, 

and award Respondent its costs and attorney fees.

Page 4

4

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: October 2, 2025 

 

 

 

(258) 731-3089 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Auburn Hills, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law,

Page 5

5

respec

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001845

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Auburn Hills (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

August 27,2025 

Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

MTT Docket No. 25-001845-TT 

Comerica AHOC, LLC, Petitioner, 

v 

City of Auburn Hills, Respondent. 

Dear Honorable Tribunal 

Enclosed for filing, with regards to the above referenced docket number, please find: 

1. 

A Proof of Service indicating that a copy of the Petition was served on the appropriate 

parties. 

If you should have any questions or concerns, please contact me at 216.685.9448. 

Respectfully Submitted 

Ryan, LLC 

/s/ Mark T. McMerrell 

Mark T. McMerrell 

Petitioner’s Representative 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

216.685.9448

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

Comerica AHOC, LLC 

Petitioner, 

MTT Docket No. 25-001845-TT 

v 

City of Auburn Hills, 

Respondent. 

PROOF OF SERVICE 

I, Janet Muchewicz, being duly sworn, deposes and says that on August 27, 2025, a copy of 

the Petition relative to the above-captioned matter, was served by U.S Postal Service upon: 

Certified Mail 

1. 

City of Auburn Hills Assessor, 1827 N. Squirrel Road, Auburn Hills, Michigan 48326 

2. 

City of Auburn Hills Clerk, 1827 N. Squirrel Road, Auburn Hills, Michigan 48326 

First Class Mail 

Oakland County Clerk, 1200 North Telegraph Road Bldg 12E, Pontiac, Michigan 48341 

Avondale School District, 2940 Waukegan Street, Auburn Hills, Michigan 48326 

Oakland County Equalization, 1200 North Telegraph Road Ste. 1000W, Pontiac, Michigan 

48341 

6. 

State Treasurer, Michigan Department of Treasury, 430 W. Allegan, Lansing, Michigan 48922 

RE

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Comerica AHOC, LLC 

Petitioner(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 25-001845 

City of Auburn Hills 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 02-14-25-226-001 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is X__real 

___ personal. 

3. 

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

contiguous? ___ Yes x 

No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

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.) 

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 - No personal property is included in this appeal 

6. 

The property identified above is classified as 201 - Commercial Improved

Page 4

MTT Docket No. 25-001845 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunals authority over the 

assessment or assessments at issue (attach additional page if necessary): 

N/A 

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 

The property or properties at issue are located in Oakland 

County. The 

property or properties’ address is: 

3701 Hamlin Rd, Auburn Hills, MI 48326 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): City of Auburn Hills 

Petitioner's legal residence or principal office address is: 

Comerica Bank 

1717 Main Street 

Dallas, Texas 75201 

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

X 

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

Page 5

MTT Docket No, 25-001845 

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 vear 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 

Assessed Value 

Taxable Value 

2025 

$38,705,240 

$19,352,620 

$13,694,590 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$12,500,000 

$6,250,000 

$6,250,000 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$26,205,240 

$13,102,620 

$7,444,580 

19. 

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

Petitioner requests that the Tax Tribunal reduce the 2025 True Cash, State Equalized, 

and taxable values of the appeal parcel and order a tax refund with

Page 6

M

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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

Comerica AHOC LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001845

City Of Auburn Hills, 

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 30, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN

 

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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

 

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 non-

contiguous parcel.) 

 

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.) 

 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

 

 

 

 

 

6. 

The property identified above is classified as _________________________ 

 

7. 

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

to Respondent’s ___ March ___ July ___December Board of Review. 

 

 

 

 

Comerica AHOC, LLC

TBD

City of Auburn Hills

02-14-25-226-001

x

x

N/A - No personal property is included in this appeal

201 - Commercial Improved

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): 

 

 

 

 

 

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): 

 

 

 

 

 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

 

 

 

 

 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

 

12. 

Petitioner’s legal residence or principal office address is: 

 

 

 

 

 

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: _______________________________________ 

 

 

 

 

 

 

TBD

N/A

N/A

Oakland

3701 Hamlin Rd, Auburn Hills, MI 48326

City of Auburn Hills

Comerica Bank

1717 Main Street

Dallas, Texas 75201

X

2025

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): 

 

 

 

 

 

16. 

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

 

17. 

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

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 

19. 

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

 

 

 

 

 

 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

 

 

 

 

 

 

 

TBD

N/A

2025

$38,705,240

$19,352,620

$13,694,590

2025

$12,500,000

$6,250,000

$6,250,000

2025

$26,205,240

$13,102,620

$7,444,590

Petitioner requests that the Tax Tribunal reduce the 2025 True Cash, State Equalized,

 and taxable values of the appeal parcel and order a tax refund with interest and costs,

 as provided by the Tax Tribunal Act.

The 2025 assessment imposed on the subject property is excessive and exceeds the 

market value. The State equalized value imposed on the subject property is more 

than 50% of its true cash value. Thus, the tax levied and collected should be deemed 

to be excessive and invalid.

Page 4

MTT Docket No. _________________ 

Page 4 of 4 

 

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

______________________________________________________________________ 

 

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

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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

Comerica AHOC LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001845

City Of Hillsdale, 

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 25, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN

 

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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

 

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 non-

contiguous parcel.) 

 

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.) 

 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

 

 

 

 

 

6. 

The property identified above is classified as _________________________ 

 

7. 

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

to Respondent’s ___ March ___ July ___December Board of Review. 

 

 

 

 

Comerica AHOC, LLC

TBD

City of Auburn Hills

02-14-25-226-001

x

x

N/A - No personal property is included in this appeal

201 - Commercial Improved

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): 

 

 

 

 

 

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): 

 

 

 

 

 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

 

 

 

 

 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

 

12. 

Petitioner’s legal residence or principal office address is: 

 

 

 

 

 

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: _______________________________________ 

 

 

 

 

 

 

TBD

N/A

N/A

Oakland

3701 Hamlin Rd, Auburn Hills, MI 48326

City of Auburn Hills

Comerica Bank

1717 Main Street

Dallas, Texas 75201

X

2025

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): 

 

 

 

 

 

16. 

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

 

17. 

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

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year

True Cash Value

State Equalized Value

Taxable Value

 

19. 

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

 

 

 

 

 

 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

 

 

 

 

 

 

 

TBD

N/A

2025

$38,705,240

$19,352,620

$13,694,590

2025

$12,500,000

$6,250,000

$6,250,000

2025

$26,205,240

$13,102,620

$7,444,590

Petitioner requests that the Tax Tribunal reduce the 2025 True Cash, State Equalized,

 and taxable values of the appeal parcel and order a tax refund with interest and costs,

 as provided by the Tax Tribunal Act.

The 2025 assessment imposed on the subject property is excessive and exceeds the 

market value. The State equalized value imposed on the subject property is more 

than 50% of its true cash value. Thus, the tax levied and collected should be deemed 

to be excessive and invalid.

Page 4

MTT Docket No. _________________ 

Page 4 of 4 

 

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

______________________________________________________________________ 

 

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

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

Comerica AHOC, LLC

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

1717 Main Street

City or Town

Dallas

State

Texas

ZIP Code

75201

Telephone Number

3307014156

Fax Number

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

mark.mcmerrell@ryan.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Mark

M.I.

T

Last Name

McMerrell

Firm Name (if any)

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

127 Public Square Suite 2800

City or Town

Cleveland

State

Ohio

ZIP Code

44114

Telephone Number

216-685-9448

Fax Number

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

mark.mcmerrell@ryan.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]

3701 Hamlin Road

Auburn Hills

Michigan

48326

Taxing Authority (City or Township)

City Of Auburn Hills (OAKLAND)

County

Oakland

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:

02-14-25-226-001

Classification of Property: Real 

Commercial

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

19352620

Current Taxable Value as established by the Board of Review:

13694590

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

12500000

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

6250000

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/ Mark T McMerrell

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