Denso International America Inc Petitioner Vs. City Of Southfield 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 

Denso International America Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000133 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER DENYING PETITIONER’S MOTION TO HOLD CASE IN ABEYANCE 

 

ORDER OF DISMISSAL 

 

On June 30, 2026, Petitioner filed a motion requesting that the Tribunal hold this case in 

abeyance pending resolution of Docket No. 25-003802 and 26-000133, which are 

currently pending before the Tribunal.1 In the motion, Petitioner states that the parties 

and property at issue in the cases are the same, and resolution of Docket No. 25-

003802 and 26-000133 will most likely help resolve this case. 

 

On July 21, 2025, Respondent filed a response to the motion. In the response, 

Respondent states that this appeal pertains to alleged arithmetic errors or mistakes in 

the 2024 and 2025 tax bills and Petitioner failed to state or provide any explanation as 

to how a Final Opinion and Judgment in Docket no. 25-003802, which involves a State 

Tax Commission (STC) determination of omitted property for the 2020-2022 tax years, 

will resolve this case. 

 

The Tribunal has considered the motion, the response, and the case file and finds that 

the petition filed in this case states that “this appeal is limited solely to correcting 

arithmetic errors or mistakes in the Contested Tax Bills and is not a valuation appeal,” 

but goes on to state that “the Contested Tax Bills indicate mistaken calculations of 

taxable value for the subject property of $14,442,223 for 2024 and $14,889,932 for 

2025.” Thus, despite Petitioner’s attempt to frame the issue in this case as an appeal of 

a contested tax bill, it is evident that it is actually disputing Respondent’s taxable value 

(TV) calculation for the 2024 and 2025 tax year, which is plainly a valuation issue. 

 

MCL 205.735a(6) specifically states that “an appeal of a contested tax bill . . . is limited 

solely to correcting arithmetic errors or mistakes and is not a basis of appeal as to 

disputes of valuation of the property, the property's exempt status, or the property's 

equalized value resulting from equalization of its assessment by the county board of 

 

1 Petitioner erroneously references the instant docket in paragraphs 5 through 8 and 10 of its motion, and 

appears to be referring to Docket No. 26-000958, which is a pending valuation appeal for the subject 

property for the 2026 tax year.

Page 2

MTT Docket No. 26-000133 

Page 2 of 3 

 

commissioners or the state tax commission.”2 Further, the documentation submitted 

with the petition, which includes correspondence from the Oakland County Treasurer 

dated December 19, 2025, indicates that the revised values are not the result of an 

“arithmetic error or mistake.” Rather, the December Board of Review changed the 

property’s values on December 9, 2025, which change resulted in issuance of the 

revised tax bills in dispute. The change is likely the result of the State Tax Commission 

Order referenced in Docket No. 25-003802, as per that order, the property’s 2022 TV 

was increased to $13,099,522, which would result in revised TVs as follows: 

$13,754,488 for 2023, $14,442,212 for 2024, and $14,889,920 for 2025. 

 

Though the TVs listed in the tax bills for 2024 and 2025 differ slightly from those 

calculated by the Tribunal for purposes of this order, Petitioner cannot collaterally attack 

the December BOR decision by way of a

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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 

Denso International America Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000133 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER DENYING PETITIONER’S MOTION TO HOLD CASE IN ABEYANCE 

 

ORDER OF DISMISSAL 

 

On June 30, 2026, Petitioner filed a motion requesting that the Tribunal hold this case in 

abeyance pending resolution of Docket No. 25-003802 and 26-000133, which are 

currently pending before the Tribunal.1 In the motion, Petitioner states that the parties 

and property at issue in the cases are the same, and resolution of Docket No. 25-

003802 and 26-000133 will most likely help resolve this case. 

 

On July 21, 2025, Respondent filed a response to the motion. In the response, 

Respondent states that this appeal pertains to alleged arithmetic errors or mistakes in 

the 2024 and 2025 tax bills and Petitioner failed to state or provide any explanation as 

to how a Final Opinion and Judgment in Docket no. 25-003802, which involves a State 

Tax Commission (STC) determination of omitted property for the 2020-2022 tax years, 

will resolve this case. 

 

The Tribunal has considered the motion, the response, and the case file and finds that 

the petition filed in this case states that “this appeal is limited solely to correcting 

arithmetic errors or mistakes in the Contested Tax Bills and is not a valuation appeal,” 

but goes on to state that “the Contested Tax Bills indicate mistaken calculations of 

taxable value for the subject property of $14,442,223 for 2024 and $14,889,932 for 

2025.” Thus, despite Petitioner’s attempt to frame the issue in this case as an appeal of 

a contested tax bill, it is evident that it is actually disputing Respondent’s taxable value 

(TV) calculation for the 2024 and 2025 tax year, which is plainly a valuation issue. 

 

MCL 205.735a(6) specifically states that “an appeal of a contested tax bill . . . is limited 

solely to correcting arithmetic errors or mistakes and is not a basis of appeal as to 

disputes of valuation of the property, the property's exempt status, or the property's 

equalized value resulting from equalization of its assessment by the county board of 

 

1 Petitioner erroneously references the instant docket in paragraphs 5 through 8 and 10 of its motion, and 

appears to be referring to Docket No. 26-000958, which is a pending valuation appeal for the subject 

property for the 2026 tax year.

Page 2

MTT Docket No. 26-000133 

Page 2 of 3 

 

commissioners or the state tax commission.”2 Further, the documentation submitted 

with the petition, which includes correspondence from the Oakland County Treasurer 

dated December 19, 2025, indicates that the revised values are not the result of an 

“arithmetic error or mistake.” Rather, the December Board of Review changed the 

property’s values on December 9, 2025, which change resulted in issuance of the 

revised tax bills in dispute. The change is likely the result of the State Tax Commission 

Order referenced in Docket No. 25-003802, as per that order, the property’s 2022 TV 

was increased to $13,099,522, which would result in revised TVs as follows: 

$13,754,488 for 2023, $14,442,212 for 2024, and $14,889,920 for 2025. 

 

Though the TVs listed in the tax bills for 2024 and 2025 differ slightly from those 

calculated by the Tribunal for purposes of this order, Petitioner cannot collaterally attack 

the December BOR decision by way of a

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M

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Denso International America, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000133 

 

Parcel No. 76-24-20-326-228 

 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorney for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7270 

 

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 

_____________________________________________________________________________/ 

 

RESPONDENT’S RESPONSE TO PETITIONER’S 

MOTION TO HOLD CASE IN ABEYANCE 

 

Respondent, City of Southfield, by and through its attorneys, Hallahan & Associates, P.C., 

states the following in response to Petitioner’s Motion to Hold Case in Abeyance: 

1. 

Respondent admits the allegations in Paragraph 1 as to subject parcel and parcel 

location. Respondent denies the remainder of the allegations set forth in Paragraph 1 for the reason 

that the same are untrue. Per Petitioner’s Petition, only the 2024 and 2025 tax years are identified 

to be at issue and the above captioned appeal was “limited solely to correcting arithmetic errors or 

mistakes in the Contested Tax Bills and is not a valuation appeal.”1 

 

1 Petitioner’s Petition at Paragraphs 16 & 18.

Page 2

2

2. 

Respondent neither admits nor denies the allegations in Paragraph 2 as MTT docket 

nos. 25-003802 and 26-000133 speak for themselves. 

3. 

Respondent neither admits nor denies the allegations in Paragraph 2 as MTT docket 

nos. 25-003802 and 26-000133 speak for themselves. 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 as the 

Prehearing General Call and Order of Procedure speaks for itself. 

5. 

Respondent neither admits nor denies the allegations in Paragraph 5 as MTT docket 

nos. 25-003802 and 26-000133 speak for themselves. 

6. 

Respondent admits that a Final Opinion and Judgment in the above captioned 

appeal would resolve the above captioned appeal (subject to any appellate proceedings). 

Respondent denies that the issuance of a Final Opinion and Judgment in MTT 25-003802 is likely 

to resolve the above captioned appeal or the parties’ desire to proceed with the above captioned 

appeal as said matters pertain to not only different tax years but claims. Nor does the above 

captioned appeal concern a sequential tax year. MTT docket no. 25-003802 pertains to an appeal 

of the State Tax Commission’s (hereinafter STC) determination that certain property had been 

omitted from the subject property’s 2020-2022 assessments. As noted above, the above captioned 

appeal pertains to alleged “arithmetic errors or mistakes” in the subject property’s 2024-2025 tax 

bills. Petitioner has failed to state or provide any explanation as to how a Final Opinion and 

Judgment in MTT docket no. 25-003802 will help the parties reach a resolution regarding the 

alleged arithmetic errors in the subject property’s 2024-2025 tax bills denoted to be at issue in the 

above captioned appeal. 

7. 

Respondent denies the allegations in Paragraph 7 for the reasons set forth above.

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3

8. 

Respondent denies the allegations in Paragraph 8 for the reasons set forth above. 

To the contrary, holding the above captioned appeal in abeyance pending a case that—based on 

the claims set forth in Petitioner’s Petitions—bears no relevancy to the above captioned appeal 

will only cause unreasonable and substantial delay to the above captioned appeal. 

9. 

Respondent admits

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4

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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: 26-000133

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

Party Filing Document 

Respondent

Files

Document Type: Response to Motion

Attachment File Name: Abeyance Response_Denso_FINAL

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

76035665.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Denso International America Inc., 

Petitioner, 

v 

City of Southfield, 

Respondent. 

MTT Docket No. 26-000133 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Motion to Hold Case in Abeyance 

Petitioner, by and through its counsel, states the following in support of its Motion to Hold 

Case in Abeyance: 

1.

This case concerns the tax year 2026 valuation and assessment of real property 

parcel no. 76-24-20-326-228, located in Southfield in Oakland County, Michigan. 

2.

There are two cases currently pending before the Tax Tribunal regarding the subject 

property’s assessed and taxable values for tax years 2020, 2021, 2022 (MTT Docket No. 25-

003802-TT) and tax years 2024 and 2025 (MTT Docket No. 26-000133-TT). 

3.

The parties and subject property in this case are identical to those at issue in Docket 

Nos. 25-003802 and 26-000133.

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2 

76035665.1 

4.

This case has been placed on the May 17-28, 2027 Prehearing General Call 

and Order of Procedure, with valuation disclosures and prehearing statements scheduled to 

be exchanged on January 19, 2027. 

5.

However, as of the filing of this Motion, the litigation in Docket Nos. 25-003802 

and 26-000133 has only just begun, with discovery still open, motions for summary disposition 

not filed, and valuation disclosures and prehearing statements not exchanged yet. 

6.

The resolution of Docket Nos. 25-003802 and 26-000133 will most likely help 

resolve this case; Final Opinions and Judgments from the Tribunal in Docket Nos. 25-003802 and 

26-000133 could impact this case and the parties’ desire to proceed with this case. 

7.

Thus, it could potentially be a waste of the Tax Tribunal’s and parties’ time and 

resources to proceed with this case when Docket Nos. 25-003802 and 26-000133 remain pending. 

8.

To proceed with this case before a resolution regarding Docket Nos. 25-003802 and 

26-000133 have been reached would likely not constitute an efficient administration of justice. 

9.

Proceeding with this case will require the parties and the Tribunal to expend 

substantial resources which may ultimately be unnecessary. Placing this case 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. 

10.

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

in abeyance pending the resolution of Docket Nos. 25-003802 and 26-000133. 

WHEREFORE, Petitioner respectfully requests the Tribunal grant this motion and enter an 

Order holding this case in abeyance pending the resolution of Docket Nos. 25-003802 and 26-

000133.

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3 

76035665.1 

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner, 

By:/s/ Jackie J. Cook 

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Dated: June 30, 2026

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4 

76035665.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Denso International America Inc., 

Petitioner, 

v 

City of Southfield, 

Respondent. 

MTT Docket No. 26-000133 

Jackie J. Cook (P68781)

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000133

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

Party Filing Document 

Petitioner

Files

Document Type: Motion for Abeyance

Attachment File Name: Motion to Hold in Abeyance - Denso Southfield (26-000133)

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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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 MAY 17- 28, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Denso,

Petitioner,

v

 

 

City Of Southfield,

Respondent.

 MTT Docket No. 26-000133

Please be advised that 26-000133 has been placed on a two-week Prehearing General 

Call commencing May 17, 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. 26-000133

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 January 19, 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 January 19, 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

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MTT

Page 4

STATE

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Denso International America, Inc. 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000133 

 

Parcel No. 76-24-20-326-228 

 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorney for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7270 

 

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 Southfield, by and through its attorneys, Hallahan & Associates, 

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

1. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

2. 

Respondent admits that the listed parcel corresponds to the stated address. 

3. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 3 and, therefore, leaves Petitioner to its proofs.

Page 2

2

4. 

Respondent can neither admit nor deny the allegations set forth in Paragraph 4 as 

standing is a legal matter that can only be resolved by the Tribunal. 

5. 

Respondent objects as the paragraph is vague as to the date to which it 

corresponds. Subject to and without waiving the objection, Respondent admits that for the 2026 

tax year the identified parcel is classified as commercial improved per Respondent’s assessment 

records. 

6. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 6 as said allegation is vague as “commercial uses” 

has not been defined and could be read in multiple ways. 

7. 

Respondent restates its response to Paragraph 6 herein. 

8. 

Respondent objects as the paragraph is vague as to the date to which it 

corresponds. Subject to and without waiving the objection, Respondent admits that for the 2026 

assessment the property is within the Southfield Public School District. 

9. 

Respondent objects as the paragraph is vague as to the date to which it 

corresponds. Subject to and without waiving the objection, Respondent admits the allegations as 

to the 2026 tax year. 

10. 

Respondent objects as the paragraph is vague as to the date and tax year to which 

it corresponds. Subject to and without waiving said objection, Respondent acknowledges the 

matter identified to be at issue by Petitioner but denies Petitioner’s allegations have merit. 

11. 

Respondent objects as the paragraph is vague as to the date and tax year to which 

it corresponds. Subject to and without waiving said objections, Respondent neither admits nor 

denies the allegations set forth in Paragraph 11 and leaves Petitioner to its proofs.

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3

12. 

Respondent objects as the paragraph is vague as to the date and tax year to which 

it corresponds. Subject to and without waiving said objections, Respondent neither admits nor 

denies the allegations set forth in Paragraph 12 and leaves Petitioner to its proofs. 

13. 

Respondent objects as the paragraph is vague as to the date and tax year to which 

it corresponds. Subject to and without waiving said objections, Respondent neither admits nor 

denies the allegations set forth in Paragraph 13 and leaves Petitioner to its proofs. 

14. 

Respondent objects as

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4

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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. 26-000133

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Southfield (OAKLAND)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

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

248-731-3089

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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

DENSO International America, Inc., 

Petitioner, 

_podI3 2 

v. 

MTT Docket No. A © 

0 

[Parcel No(s). 76-24-20-326-228] 

Southfield, 

Respondent. 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, 

and that on 

2 

, she did serve 

a copy of Petitioner's Petition, with docket 

number, upon the parties named on the attached list. 

(7 Foun Opasph 

Lisa Joseph 

26-0003

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

SOUTHFIELD 

26000 EVERGREEN ROAD 

SOUTHFIELD, MI 48076 

ASSESSOR 

SOUTHFIELD 

26000 EVERGREEN ROAD 

SOUTHFIELD, MI 48076 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

SECRETARY OF SCHOOL BOARD 

SOUTHFIELD PUBLIC SCHOOLS 

24661 LAHSER ROAD 

SOUTHFIELD, MI 48033-3238 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0003

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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

Denso,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 26-000133

City Of Southfield,

Respondent.

ORDER VACATING DEFAULT ORDER

The Tribunal has reviewed the file in the above-captioned case and finds that the 

Tribunal entered an order on March 24, 2026, holding Petitioner in default. The Tribunal 

erred in the entry of that order. Therefore,

IT IS ORDERED that the Order of Default is VACATED.

By _________________________________

Patricia L. Halm, Tribunal Chair

Entered: March 24, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Denso,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 26-000133

City Of Southfield,

Respondent.

ORDER VACATING DEFAULT ORDER

The Tribunal has reviewed the file in the above-captioned case and finds that the 

Tribunal entered an order on March 24, 2026, holding Petitioner in default. The Tribunal 

erred in the entry of that order. Therefore,

IT IS ORDERED that the Order of Default is VACATED.

By _________________________________

Patricia L. Halm, Tribunal Chair

Entered: March 24, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN

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

Denso,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000133

City Of Southfield,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner failed to file proof evidencing service of the petition. See TTR 227. The 

Tribunal finds that placing Petitioner in default, rather than dismissal of this case, may 

effectuate the efficient administration of this appeal. As such, Petitioner must submit 

the proof of service within 14 days of the entry of this order. Tribunal rules and 

information on Entire Tribunal petitions can be found on our website at 

www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Petitioner is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: March 24, 2026

Patricia L. Halm, Tribunal Chair

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

i “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by

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MTT Docket No. 26-000133

Page 2 of 4

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Denso,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000133

City Of Southfield,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner failed to file proof evidencing service of the petition. See TTR 227. The 

Tribunal finds that placing Petitioner in default, rather than dismissal of this case, may 

effectuate the efficient administration of this appeal. As such, Petitioner must submit 

the proof of service within 14 days of the entry of this order. Tribunal rules and 

information on Entire Tribunal petitions

Page 4

M

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

25-0010 

63610163.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Denso International America Inc, 

Petitioner, 

v 

City of Southfield, 

Respondent. 

MTT Docket No. 

Parcel No. 76-24-20-326-228 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7270 

jcook@honigman.com

Petition 

Petitioner, Denso International America, Inc. (“Denso”), by and through its attorneys, 

Honigman LLP, for its Petition against Respondent, City of Southfield, states as follows: 

1.

Denso’s principal office and place of business is located at 24777 Denso Drive, 

Southfield, MI 48033. 

2.

The subject real property, parcel no. 76-24-20-326-228, is located at 24777 Denso 

Drive, Southfield, MI 48033 in Oakland County (“subject property”). 

3.

Denso, an automotive parts manufacturer with a global presence, has used the 

subject property directly off Telegraph Road near I-696 as its technical campus since purchasing 

it in 2005. 

4.

Denso is a party in interest under MCL 205.735a as Denso owns the subject

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2 

63610163.1 

property and is the taxpayer responsible for property tax assessments on the subject property. 

5.

The subject property is classified commercial-improved. 

6.

The subject property is presently used for commercial uses. 

7.

On information and belief, the subject property was designed for commercial uses. 

8.

The subject property is in the Southfield Public School District and Oakland County 

Intermediate School District. 

9.

Respondent City of Southfield assesses and collects property taxes on the subject 

property. 

10.

This matter involves issues relating to tax bill calculation mistakes only. 

11.

There was no transfer of ownership. 

12.

There was no addition. 

13.

There was no new construction. 

14.

There was no omitted property. 

15.

There was no previously exempt property. 

16.

The calculations in the tax bills for tax years 2024 and 2025 accordingly appear to 

be based on mistakes. (The “Contested Tax Bills” are attached as Appendix A.) 

17.

This contested tax bill appeal is filed within 60 days of the dates reflected on the 

tax bills, December 17, 2025, December 19, 2025, and December 22, 2025. Appendix A. 

18.

This appeal is limited solely to correcting arithmetic errors or mistakes in the 

Contested Tax Bills and is not a valuation appeal. 

19.

The Tax Tribunal’s jurisdiction is invoked under MCL 205.735a(6). 

20.

The original taxable values for the subject property were $11,565,421 for 2024 and 

$11,923,549 for 2025.

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3 

63610163.1 

21.

The Contested Tax Bills indicate mistaken calculations of taxable value for the 

subject property of $14,442,223 for 2024 and $14,889,932 for 2025. 

22.

The mistaken calculations of taxable value for 2024 and 2025 in the Contested Tax 

Bills result in mistaken calculations of property tax and interest. 

23.

The mistakes result in unlawful double taxation of property that was already 

subjected to taxation in tax year 2024 and 2025. 

24.

The taxable value amounts in contention are $2,876,802 for tax year 2024 and 

$2,966,383 for tax year 2025. 

25.

The Tax Tribunal has “exclusive and original” jurisdiction over “a proceeding for 

direct review of a final decision, finding, ruling, determination, or order of an agency relating to 

assessment, valuation, rates, special assessments, allocation, or equalization, under the property 

tax laws of this state.” MCL 205.731(a). 

26.

The Tribunal may review the subject property’s taxable value calculations de novo. 

27.

The Tribunal has the power to correct the mistakes in the Contested Tax Bills. MCL 

205.732(a). 

28.

The Tax Tribunal has the power to order a refund of the

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4

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25-0010

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R

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

Denso, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000133

City Of Southfield, 

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: February 24, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

25-0010 

63610163.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Denso International America Inc, 

Petitioner, 

v 

City of Southfield, 

Respondent. 

MTT Docket No. 

Parcel No. 76-24-20-326-228 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7270 

jcook@honigman.com

Petition 

Petitioner, Denso International America, Inc. (“Denso”), by and through its attorneys, 

Honigman LLP, for its Petition against Respondent, City of Southfield, states as follows: 

1.

Denso’s principal office and place of business is located at 24777 Denso Drive, 

Southfield, MI 48033. 

2.

The subject real property, parcel no. 76-24-20-326-228, is located at 24777 Denso 

Drive, Southfield, MI 48033 in Oakland County (“subject property”). 

3.

Denso, an automotive parts manufacturer with a global presence, has used the 

subject property directly off Telegraph Road near I-696 as its technical campus since purchasing 

it in 2005. 

4.

Denso is a party in interest under MCL 205.735a as Denso owns the subject

Page 2

2 

63610163.1 

property and is the taxpayer responsible for property tax assessments on the subject property. 

5.

The subject property is classified commercial-improved. 

6.

The subject property is presently used for commercial uses. 

7.

On information and belief, the subject property was designed for commercial uses. 

8.

The subject property is in the Southfield Public School District and Oakland County 

Intermediate School District. 

9.

Respondent City of Southfield assesses and collects property taxes on the subject 

property. 

10.

This matter involves issues relating to tax bill calculation mistakes only. 

11.

There was no transfer of ownership. 

12.

There was no addition. 

13.

There was no new construction. 

14.

There was no omitted property. 

15.

There was no previously exempt property. 

16.

The calculations in the tax bills for tax years 2024 and 2025 accordingly appear to 

be based on mistakes. (The “Contested Tax Bills” are attached as Appendix A.) 

17.

This contested tax bill appeal is filed within 60 days of the dates reflected on the 

tax bills, December 17, 2025, December 19, 2025, and December 22, 2025. Appendix A. 

18.

This appeal is limited solely to correcting arithmetic errors or mistakes in the 

Contested Tax Bills and is not a valuation appeal. 

19.

The Tax Tribunal’s jurisdiction is invoked under MCL 205.735a(6). 

20.

The original taxable values for the subject property were $11,565,421 for 2024 and 

$11,923,549 for 2025.

Page 3

3 

63610163.1 

21.

The Contested Tax Bills indicate mistaken calculations of taxable value for the 

subject property of $14,442,223 for 2024 and $14,889,932 for 2025. 

22.

The mistaken calculations of taxable value for 2024 and 2025 in the Contested Tax 

Bills result in mistaken calculations of property tax and interest. 

23.

The mistakes result in unlawful double taxation of property that was already 

subjected to taxation in tax year 2024 and 2025. 

24.

The taxable value amounts in contention are $2,876,802 for tax year 2024 and 

$2,966,383 for tax year 2025. 

25.

The Tax Tribunal has “exclusive and original” jurisdiction over “a proceeding for 

direct review of a final decision, finding, ruling, determination, or order of an agency relating to 

assessment, valuation, rates, special assessments, allocation, or equalization, under the property 

tax laws of this state.” MCL 205.731(a). 

26.

The Tribunal may review the subject property’s taxable value calculations de novo. 

27.

The Tribunal has the power to correct the mistakes in the Contested Tax Bills. MCL 

205.732(a). 

28.

The Tax Tribunal has the power to order a refund of the

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25-0010

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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

Denso

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

24777 Denso Drive

City or Town

Southfield

State

Michigan

ZIP Code

48033

Telephone Number

248-566-8402

Fax Number

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

maxwell.katz@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

39400 Woodward Avenue Suite 101

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

248-566-8474

Fax Number

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

jcook@honigman.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]

24777

Southfield

Michigan

48033

Taxing Authority (City or Township)

City Of Southfield (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)

Tax Bill

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-20-326-228

Classification of Property: Real 

Commercial

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

14892790

Current Taxable Value as established by the Board of Review:

14442223

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

29785580

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

14892790

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

11565421

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

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