Dearborn Elite Hospitality LLC, Petitioner Vs. City Of Dearborn, 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 

Dearborn Elite Hospitality LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002037 

 

City of Dearborn, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms, and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, 

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after 

December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 

2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-002037 

Page 2 of 2 

 

through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 

31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at 

the rate of 9.47%, (viii) after June 30, 2025, through December 31, 2025, at the rate of 

8.66%, and (ix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

 

 

By _____________________________ 

Entered: March 2, 2026 

sb 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

DEARBORN ELITE HOSPITALITY LLC, 

 

 

 

Petitioner, 

 

vs. 

 

CITY OF DEARBORN, 

 

 

 

Respondent. 

 

 

 

 

MTT Docket No. 25-002037 

_____________________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

JEREMY J. ROMER (P77287) 

GOPI P. PATEL (P77727) 

CITY OF DEARBORN 

Attorneys for Respondent 

16901 Michigan Ave., Suite 14 

Dearborn, MI 48126 

(313) 943-2035 

_____________________________________________________________________________/ 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

1. 

The case is pending in the __X__ Entire Tribunal ___ Small Claims Division. 

 

2. 

Property Parcel No: 82-09-123-02-015 

 

3. 

The property is located at: 6355 Mercury Dr., Dearborn, Wayne County, MI. 

 

4. 

The 2025 values for the property identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Year 

Original TCV 

Original AV 

Original TV 

2025 

$8,186,000 

$4,093,000 

$3,788,925 

 

5. 

The 2025 values for the property identified above as stipulated by the parties for 

settlement purposes are: 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Year 

 Revised TCV 

Revised SEV 

Revised TV 

2025 

$7,350,000 

$3,675,000 

$3,675,000

Page 2

MTT Docket No. 25-002037 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

 

6. 

If stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or 

years (attach additional page if necessary): 

____________________________________________________ 

 

7. 

List separately any special terms or conditions being proposed by the parties that would 

affect the execution of this Consent Judgment including, but not limited to, the joint 

payment of the refund, the waiver of interest, etc. (attach additional page if necessary): 

 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

 

Refunds shall be made payable to Petitioner and Petitioner’s counsel Hallahan & 

Associates, P.C. and sent in care of Petitioner’s counsel Hallahan & Associates, P.C., 

to: 1750 Telegraph Road, Suite 202, Bloomfield Hills, Michigan 48302-2082. 

 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

 

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

 //s// Laura M. Hallahan 

 

 

 

 

 

 

 

 

 

 

Laura M. Hallahan 

 

Signature of Respondent’s authorized representative: 

 //s// Jeremy J. Romer 

 

 

 

 

 

 

 

 

 

Jeremy J. Romer

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

DEARBORN ELITE HOSPITALITY LLC, 

 

 

 

Petitioner, 

 

vs. 

 

CITY OF DEARBORN, 

 

 

 

Respondent. 

 

 

 

 

MTT Docket No. 25-002037 

_____________________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

JEREMY J. ROMER (P77287) 

GOPI P. PATEL (P77727) 

CITY OF DEARBORN 

Attorneys for Respondent 

16901 Michigan Ave., Suite 14 

Dearborn, MI 48126 

(313) 943-2035 

_____________________________________________________________________________/ 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

1. 

The case is pending in the __X__ Entire Tribunal ___ Small Claims Division. 

 

2. 

Property Parcel No: 82-09-123-02-015 

 

3. 

The property is located at: 6355 Mercury Dr., Dearborn, Wayne County, MI. 

 

4. 

The 2025 values for the property identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Year 

Original TCV 

Original AV 

Original TV 

2025 

$8,186,000 

$4,093,000 

$3,788,925 

 

5. 

The 2025 values for the property identified above as stipulated by the parties for 

settlement purposes are: 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Year 

 Revised TCV 

Revised SEV 

Revised TV 

2025 

$7,350,000 

$3,675,000 

$3,675,000

Page 2

MTT Docket No. 25-002037 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

 

6. 

If stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or 

years (attach additional page if necessary): 

____________________________________________________ 

 

7. 

List separately any special terms or conditions being proposed by the parties that would 

affect the execution of this Consent Judgment including, but not limited to, the joint 

payment of the refund, the waiver of interest, etc. (attach additional page if necessary): 

 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

 

Refunds shall be made payable to Petitioner and Petitioner’s counsel Hallahan & 

Associates, P.C. and sent in care of Petitioner’s counsel Hallahan & Associates, P.C., 

to: 1750 Telegraph Road, Suite 202, Bloomfield Hills, Michigan 48302-2082. 

 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

 

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

 //s// Laura M. Hallahan 

 

 

 

 

 

 

 

 

 

 

Laura M. Hallahan 

 

Signature of Respondent’s authorized representative: 

 //s// Jeremy J. Romer 

 

 

 

 

 

 

 

 

 

Jeremy J. Romer

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF DECEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

Dearborn Elite Hospitality LLC,

Petitioner,

v

 

 

City Of Dearborn,

Respondent.

 MTT Docket No. 25-002037

Please be advised that 25-002037 has been placed on a two-week Prehearing General 

Call commencing December 16, 2026. Unless ordered otherwise, parties will be 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 25-002037

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 August 19, 2026. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

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

Statements by August 19, 2026. Witnesses, with the exception of rebuttal witnesses, 

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

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

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

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

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

August 19, 2026, which means all discovery has been requested, all Motions to Compel 

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

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

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

during “Pre-Valuation Disclosure” discovery.

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

December 16, 2026, which means all discovery has been requested, all Motions to 

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

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

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

on the opposing party’s Prehearing Statement.

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

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

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

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

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: January 16, 2026

Page 3

MTT Docket No. 25-002037

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

Page 4

STATE

Page 5

M

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Dearborn Elite Hospitality LLC, 

 

Petitioner, 

 

vs. 

 

City of Dearborn, 

 

Respondent. 

MOAHR Docket No. 25-002037 

_____________________________________________________________________________/ 

 

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 Dearborn 

16901 Michigan Ave 

Dearborn, MI 48126 

City Clerk 

City of Dearborn 

16901 Michigan Ave, Ste 11 

Dearborn, MI 48126 

 

 

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

 

Equalization Director 

Wayne County 

500 Griswold, 21st Floor 

Detroit, MI 48226 

 

County Clerk 

Wayne County 

2 Woodward Avenue, Room 201 

Detroit, MI 48226 

 

Secretary, Board of Education 

Dearborn Public Schools 

18700 Audette 

Dearborn, MI 48124 

 

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: September 17, 2025

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

Dearborn Elite Hospitality LLC, 

Petitioner, 

v 

City of Dearborn, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 25-002037

Parcel No. 82-09-123-02-015 

_____________________________________________________________________________/ 

PROPERTY TAX PETITION 

(Entire Tribunal, 2025 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 

82-09-123-02-015

Address 

6355 Mercury Dr 

Classification 

201 Comm Imp 

Use 

Hotel 

County 

Wayne 

Sch Dist Dearborn 

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: 985 W. Entrance Drive, Auburn

Hills, MI 48326.

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 ______

7.

The tax year at issue is 2025.

Page 3

Petition 

2 

8. 

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

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

8,186,000 

4,093,000 

3,788,925 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

6,500,000 

3,250,000 

3,250,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

1,686,000 

843,000 

538,925 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2025 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 2025 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 

(248) 731-3089 

Dated: May 30, 2025 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

Filing Fee: $600

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

 

DEARBORN ELITE HOSPITALITY LLC, 

 

Petitioner, 

 

 

MTT Docket No. 25-002037 

 

 

 

v 

 

 

CITY OF DEARBORN, 

 

Respondent. 

_____________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Ste. 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

(248) 731-3086 fax 

lhallahan@hallahanlaw.com 

 

JEREMY J. ROMER (P77287) 

GOPI P. PATEL (P77727) 

CITY OF DEARBORN 

Attorneys for Respondent 

16901 Michigan Ave., Ste. 14 

Dearborn, MI 48126 

(313) 943-2035 

(313) 943-2469 fax 

jromer@dearborn.gov 

gpatel@dearborn.gov 

_____________________________________________________________________/ 

 

RESPONDENT'S ANSWER TO PETITION 

AND AFFIRMATIVE DEFENSES 

 

 

NOW COMES Respondent, City of Dearborn, by and through its attorney, JEREMY J. 

ROMER, and for its Answer to Petition states as follows: 

ANSWER TO THE PETITION 

 

1. 

As to the allegations contained in Paragraph 1, this Respondent admits the 

allegation contained therein. 

 

2. 

As to the allegations contained in Paragraph 3, this Respondent admits the 

allegations contained therein.

Page 2

2 

 

3. 

As to the allegation contained in Paragraph 4, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

4. 

As to the allegation contained in Paragraph 5, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

5. 

As to the allegation contained in Paragraph 6, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

6. 

As to the allegation contained in Paragraph 7, this Respondent admits the 

allegations contained therein. 

 

7. 

As to the allegation contained in Paragraph 8, this Respondent denies each and 

every allegation contained therein for the reason that they are untrue 

 

8. 

As to the allegations contained in Paragraph 9, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

9. 

As to the allegations contained in Paragraph 10, this Respondent is without 

sufficient information or knowledge to form a belief as to the truth of the allegation stated therein 

and leaves Petitioner to her proofs. 

 

10. 

As to the allegations contained in Paragraph 11, this Respondent denies each and 

every allegation contained therein for the reason that they are untrue.

Page 3

3 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss this 

Petition with prejudice, deny the legal and/or equitable relief requested, and order Petitioner to pay 

Respondent the costs and attorney fees so wrongfully sustained by the necessity of the defense. 

 

Respectfully submitted, 

Jeremy J. Romer 

 

________________________ 

 

JEREMY J. ROMER 

 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

 

16901 Michigan Ave., Ste. 14 

 

 

 

 

 

 

 

Dearborn, MI 48126 

 

 

 

 

 

 

 

(313) 943-2035 

 

 

 

 

 

 

 

(313) 943-2069 fax 

 

 

 

 

 

 

 

jromer@dearborn.gov 

 

 

Dated: August 20, 2025

Page 4

4 

AFFIRMATIVE DEFENSES 

 

 

For its further answer to Petition, and by way of its affirmative defenses, Respondent 

respectfully represents to this Honorable Tribunal as follows: 

1. Petitioner lacks standing to bring this matter before the Michigan Tax Tribunal. 

2. 

Petitioner has failed to allege specific and sufficient acts to set forth a cause of action 

against Respondent. 

3. 

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

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

4. 

Petitioner has failed to allege that the mode and method of appraising its property failed 

to conform to the mode and method applied in the case of all other properties in the Respondent 

taxing unit. 

5. 

Petitioner has failed to allege specific and sufficient facts to establish the true cash 

value of its property. 

6. 

Petitioner has failed to file a petition which conforms to the requirements of TTR 240 

and its subsections sufficient to apprise Respondent of the grounds of its Petition. 

7. 

Petitioner has failed to show that any rate other than 50%, after equalization, was 

applied to the true cash value of Petitioner’s property as well as to the properties of all others to 

arrive at the respective equalized assessments appearing on Respondent’s assessment roll. 

8. 

Petitioner failed in its appearance, if required, before the Board of Review to allege that 

the assessment is unlawful and is based upon the application of wrong principles and thereby 

operates as a fraud upon the taxpayer. 

9. 

Petitioner, in essence, seeks by its 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.

Page 5

5 

10. 

The property at issue is subject to taxation under the relevant provisions of the General 

Property Tax Act, and Respondent reserves the right to file a Motion for Summary

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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. 25-002037

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Dearborn (WAYNE)

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

Jeremy

M.I.

J.

Last Name

Romer

Firm Name (if any)

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

16901 Michigan Ave Ste 14

City or Town

Dearborn

State

Michigan

ZIP Code

48126

Telephone Number

313-943-3086

Fax Number

313-943-2469

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

jromer@ci.dearborn.mi.us

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

Respondent or Authorized Attorney/Representative’s Signature: 

Jeremy Romer

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

Dearborn Elite Hospitality LLC, 

 

Petitioner, 

 

v 

 

City of Dearborn, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 25-_____________ 

Parcel No. 82-09-123-02-015 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2025 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 

82-09-123-02-015 

Address 

6355 Mercury Dr 

Classification 

201 Comm Imp 

Use 

Hotel 

County 

Wayne 

Sch Dist Dearborn 

 

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: 985 W. Entrance Drive, Auburn 

Hills, MI 48326. 

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 ______ 

7. 

The tax year at issue is 2025.

Page 2

Petition 

2 

8. 

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

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

8,186,000 

4,093,000 

3,788,925 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

6,500,000 

3,250,000 

3,250,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

1,686,000 

843,000 

538,925 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2025 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 2025 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 

(248) 731-3089 

Dated: May 30, 2025 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

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

Dearborn Elite Hospitality LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002037

City Of Dearborn Heights, 

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: August 7, 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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

Dearborn Elite Hospitality LLC, 

 

Petitioner, 

 

v 

 

City of Dearborn, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 25-_____________ 

Parcel No. 82-09-123-02-015 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2025 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 

82-09-123-02-015 

Address 

6355 Mercury Dr 

Classification 

201 Comm Imp 

Use 

Hotel 

County 

Wayne 

Sch Dist Dearborn 

 

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: 985 W. Entrance Drive, Auburn 

Hills, MI 48326. 

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 ______ 

7. 

The tax year at issue is 2025.

Page 2

Petition 

2 

8. 

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

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

8,186,000 

4,093,000 

3,788,925 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

6,500,000 

3,250,000 

3,250,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

82-09-123-02-015 

1,686,000 

843,000 

538,925 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2025 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 2025 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 

(248) 731-3089 

Dated: May 30, 2025 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

Filing Fee: $600

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Dearborn Elite Hospitality LLC 

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

985 W. Entrance Drive

City or Town

Auburn Hills

State

Michigan

ZIP Code

48326

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]

6355 Mercury Dr

Dearborn

Michigan

Taxing Authority (City or Township)

City Of Dearborn (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.)

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:

82-09-123-02-015

Classification of Property: Real 

Commercial

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

4093000

Current Taxable Value as established by the Board of Review:

3788925

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

6500000

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

3250000

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

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