Conrad Group LLC Petitioner Vs. City Of Farmington Hills 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 AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Conrad Group LLC,

Petitioner,

v

 

 

City Of Farmington Hills,

Respondent.

 MTT Docket No. 26-000450

Please be advised that 26-000450 has been placed on a two-week Prehearing General 

Call commencing August 02, 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covered by the order will not be published.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. 26-000450

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 April 5, 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 April 5, 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 

April 5, 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 

August 2, 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: September 1, 2026

Page 3

MTT Docket No. 26-000450

Page 3 of 3

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF

Page 5

MTT Docket

Page 6

MT

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Page 1

RECEIVED 

JUL 2 92025 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIR$ICHIGAN TAX TRIBUNAL 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

CONRAD GROUP LIL.C 

Petitioner 

v 

MOAHR Docket 26-000450 

Parcel No. 22-23-15-201-270 

CITY OF FARMINGTON HILLS, 

Respondent 

Jennifer Hendrix, 

MMAO 

City Assessor 

31555 West Eleven Mile Rd 

Farmington Hills, MI 48336 

(248) 871-2479 

jhendrix@fhgov.com 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

AND AFFIRMATIVE DEFENSES 

RESPONDENT, the City of Farmington Hills, through its Assessor, Jennifer Hendrix, hereby 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1. 

2. 

Petitioner has not set forth any allegations fo warrant a response. 

No March Board of 

Review was filed. 

3. 

Respondent admits the allegations in Paragraph 3. 

4. 

Respondent lacks the information and knowledge necessary to respond to the allegations 

in Paragraph 4. The owner of record is 31525 Building LLC, which was transferred from

Page 2

MTT Docket # 26-000450 

6. 

Respondent neither admits nor denies the allegations in Paragraph 6 for reason that they 

do not have sufficient knowledge to for a belief as to the truth of the allegations and 

leaving Petitioner to their strictest proofs. 

10. 

11. 

Respondent admits the allegations in Paragraph 7. 

. 

The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

True Cash Value 

| Assessed Value 

Taxable Value 

22-23-15-201-270 

$6,572,200 

$3,286,100 

$3,286,100 

Respondent contends that the 2026 values for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

22-23-15-201-270 

$6,572,200 

$3,286,100 

$3,286,100 

The 2026 values in dispute for the property identified above are: 

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

22-23-15-201-270 

$0 

$0 

$0 

Respondent denies the allegations in Paragraph 11 for the reason that it is 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 constitutional. Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year and leaving Petitioner to their 

strictest proofs. 

WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal 

dismiss the Petition; affirm Respondent’s assessed and taxable values, subject to county and state 

equalization., and award Respondent its cost and attorney fees.

Page 3

MTT Docket # 26-000450 

Dated: 

/ / bd 7 zl 

OFFICE et THE CITY ASSESSOR 

Re) 

OF F 

INGTON HILLS 

N onde 

ft: rrr “MMAO 

City Assessor, Farmington Hills 

31555 West Eleven Mile Rd 

Farmington Hills, MI 48336 

(248) 871-2479 

jhendrix@fhgov.com

Page 4

MTT Docket # 26-000450 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the 

following affirmative defenses: 

A. 

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

against the Respondent and to support Petitioner’s claim for relief. 

B. 

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). 

C. 

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). 

B. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, and application of wrong principles or illegality on the part of the Respondent or 

its agents. 

C. 

Petitioner fails to allege the mode and method of assessing the subject property 

failed to conform to the mode and method applied in the case of all properties within the 

Respondents taxing unit for the tax year in questions. 

D. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

E. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject property, as equalized, is at a level other than 50% and it also 

fails to allege specific and sufficient facts to support its allegations that the subject property’s

Page 5

MTT Docket # 26-000450 

G. 

Petitioner asks this Tribunal to grant it illegal preference by application of a method 

of assessment different from that utilized in the assessment of other properties in the Respondent’s 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

IL 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

J. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable alia in accordance with statutory and constitutional requirements. 

K. 

Respondent reserves the right to add affirmative defenses which may become 

known during the course of informal or formal discovery proceedings. 

WHEREFORE, Respondent denies that the Petitioner 

is entitled 0 any relief and 

respectfully requests that the Respondent’s assessed and taxable values for the year under appeal 

be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be 

granted all attorney fees and cost wrongfully sustained. 

OFFICE OF THE CITY ASSESSOR 

ILLS 

Z Zz 

CITY OF FARMINGTON H 

Dated: a4

Page 6

STA

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Conrad Group LLC, 

 

Petitioner, 

 

vs. 

 

City of Farmington Hills, 

Respondent.

 

 

 

MTT Docket No. 26-000450 

 

_____________________________________________________________________________/ 

 

 

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 Farmington Hills 

31555 W Eleven Mile Rd 

Farmington Hills, MI 48336 

City Clerk 

City of Farmington Hills 

31555 W Eleven Mile Rd 

Farmington Hills, MI 48336 

 

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 

Farmington Public Schools 

32500 Shiawassee St 

Farmington, MI 48336 

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 29, 2026

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

CONRAD GROUP LLC, 

Petitioner, 

v 

CITY OF FARMINGTON HILLS, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-000450______ 

Parcel No. 22-23-15-201-270 

_____________________________________________________________________________/ 

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 is one real property parcel:

Parcel Number 

22-23-15-201-270

Address 

31525 Twelve Mile 

Classification 

201-Commercial

Use 

Vacant 

County 

Oakland 

Sch Dist Farmington 

Public 

School 

District 

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.

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

property.

5.

The Petitioner’s principal office/legal residence address is: 4789 Walnut Creek Cir., West

Bloomfield, MI 48322.

6.

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 ______

Page 3

Petition 

2 

7.

The tax year at issue is 2026.

8.

The values1 established by Respondent’s Board of Review for the subject property are:

Parcel Number 

TCV 

SEV 

TV 

22-23-15-201-270

6,572,200 

3,286,100 

3,286,100 

9.

Petitioner contends that the values1 for the subject property are:

Parcel Number 

TCV 

SEV 

TV 

22-23-15-201-270

2,350,000 

1,175,000 

1,175,000 

10.

The values1 in dispute are.

Parcel Number

TCV 

SEV 

TV 

22-23-15-201-270

5,397,200 

2,111,100 

2,111,100 

11.

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;

and

(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.

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. 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 4

Petition 

3 

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 

(258) 731-3089

Dated: April 1, 2026 

lhallahan@hallahanlaw.com

Filing Fee: $600

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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

Docket Number: 26-000450

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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

CONRAD GROUP LLC, 

 

Petitioner, 

 

v 

 

CITY OF FARMINGTON HILLS, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-_____________ 

Parcel No. 22-23-15-201-270 

_____________________________________________________________________________/ 

 

 

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 is one real property parcel: 

Parcel Number 

22-23-15-201-270 

Address 

31525 Twelve Mile 

Classification 

201-Commercial 

Use 

Vacant 

County 

Oakland 

Sch Dist Farmington 

Public 

School 

District 

 

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. 

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

property. 

5. 

The Petitioner’s principal office/legal residence address is: 4789 Walnut Creek Cir., West 

Bloomfield, MI 48322. 

6. 

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 ______

Page 2

Petition 

2 

7. 

The tax year at issue is 2026. 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

22-23-15-201-270 

6,572,200 

3,286,100 

3,286,100 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

22-23-15-201-270 

2,350,000 

1,175,000 

1,175,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

22-23-15-201-270 

5,397,200 

2,111,100 

2,111,100 

11. 

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; 

and 

(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. 

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. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

 

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 

(258) 731-3089 

Dated: April 1, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $600

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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

Conrad Group LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000450

City Of Farmington 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: May 20, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

CONRAD GROUP LLC, 

 

Petitioner, 

 

v 

 

CITY OF FARMINGTON HILLS, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-_____________ 

Parcel No. 22-23-15-201-270 

_____________________________________________________________________________/ 

 

 

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 is one real property parcel: 

Parcel Number 

22-23-15-201-270 

Address 

31525 Twelve Mile 

Classification 

201-Commercial 

Use 

Vacant 

County 

Oakland 

Sch Dist Farmington 

Public 

School 

District 

 

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. 

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

property. 

5. 

The Petitioner’s principal office/legal residence address is: 4789 Walnut Creek Cir., West 

Bloomfield, MI 48322. 

6. 

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 ______

Page 2

Petition 

2 

7. 

The tax year at issue is 2026. 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

22-23-15-201-270 

6,572,200 

3,286,100 

3,286,100 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

22-23-15-201-270 

2,350,000 

1,175,000 

1,175,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

22-23-15-201-270 

5,397,200 

2,111,100 

2,111,100 

11. 

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; 

and 

(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. 

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. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

 

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 

(258) 731-3089 

Dated: April 1, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $600

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

Conrad Group LLC

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

4789 Walnut Creek Circle

City or Town

West Bloomfield

State

Michigan

ZIP Code

48324

Telephone Number

2487313090

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?1

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

31525 Twelve Mile Road

Farmington Hills

Michigan

Taxing Authority (City or Township)

City Of Farmington 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:

22-23-15-201-270

Classification of Property: Real 

Commercial

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

3286100

Current Taxable Value as established by the Board of Review:

3286100

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

2350000

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

1175000

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/ 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.