Fifteen Mile Gratiot Investment LLC Petitioner Vs. Township Of Clinton Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF SEPTEMBER 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Fifteen Mile Gratiot Investment LLC,

Petitioner,

v

 

 

Township Of Clinton,

Respondent.

 MTT Docket No. 26-000986

Please be advised that 26-000986 has been placed on a two-week Prehearing General 

Call commencing September 01, 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covered by the order will not be published.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. 26-000986

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 May 5, 2027. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

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

Statements by May 5, 2027. Witnesses, with the exception of rebuttal witnesses, will 

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

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

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

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

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

May 5, 2027, which means all discovery has been requested, all Motions to Compel 

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

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

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

during “Pre-Valuation Disclosure” discovery.

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

September 1, 2027, which means all discovery has been requested, all Motions to 

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

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

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

on the opposing party’s Prehearing Statement.

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

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

certain prehearing conference at

Page 3

MT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Fifteen Mile-Gratiot Investment LLC, 

 

 

 

Petitioner, 

 

v 

 

Clinton Township, 

 

 

 

Respondent. 

 

 

 

 

Docket No. 26-000986 

 

 

_____________________________________________________________________________/ 

 

JOSHUA T. SHILLAIR (P72674) 

COLLIERS INTERNATIONAL 

Attorney for Petitioner 

400 W. 4th Street, Suite 350 

Royal Oak, MI 48067 

(248) 226-1632 

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, Clinton Township, 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 the allegations in Paragraph 2. 

 

3. 

Respondent admits the allegations in Paragraph 3. 

 

4. 

Respondent admits that the subject property is classified as commercial real 

property but lacks the knowledge and information necessary to respond to the remainder of the 

allegations set forth in Paragraph 4 and, therefore, leaves Petitioner to its proofs.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

 

5. 

Respondent admits no protest to 2026 March Board of Review was made but 

neither admits nor denies the necessity of such a protest as the General Property Tax Act speaks 

for itself. 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but 

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

 

8. 

Respondent acknowledges Petitioner’s belief as to an issue with the 2026 tax year 

but denies any issue with said year. 

 

9. 

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

Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

16-11-27-452-040 

$6,305,600 

$3,152,800 

$1,791,130 

 

10. 

Respondent denies the allegations in Paragraph 10, including subparagraphs (a) – 

(d), for the reason that they are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage for true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional. 

 

11. 

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

 

Tax Year 

Parcel Number 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

16-11-27-452-040 

$6,305,600 

$3,152,800 

$1,791,130 

 

12. 

The values in dispute for the property identified above are: 

 

Tax Year 

Parcel Number 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

16-11-27-452-040 

$0 

$0 

$0 

 

13. 

Respondent denies the allegations in Paragraph 13 for the reason that they are 

untrue. 

 

14. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to said relief for the reasons stated in the 

preceding paragraphs. In further answer, the assessed, state equalized and/or taxable values do 

not exceed permitted amounts, do not exceed the percentage for true cash value permitted by 

law, were correctly determined and are based upon correct application of proper principles, and 

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

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

 

WHEREFORE, Respondent, Clinton Township, requests the Tribunal dismiss the 

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

equalization, and award Respondent its costs and attorney fees. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan___________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 17, 2026 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Clinton Township, asserts the following affirmative defenses: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

(1981). 

3. 

Petitioner has the burden of establishing the

Page 4

Entire

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000986

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Clinton (MACOMB)

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: 

/s/Kelsea M. Melcher

/s/

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Page 1

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 26-000986 

Page 1 of 2 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FIFTEEN MILE-GRATIOT INVESTMENT LLC, 

 

Petitioner, 

v 

MTT Docket No. 26-000986 

CLINTON TOWNSHIP, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Senior Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

Clinton Township 

Assessing Office 

40700 Romeo Plank Rd, 

Clinton Township, MI 48038 

(586) 723-8092 

_____________________________________________________________________________/ 

 

CORRECTED PROOF OF SERVICE 

 

STATE OF MICHIGAN 

) 

 

)ss 

COUNTY OF OAKLAND 

) 

 

Jennifer Lunsford, states that on 7/28/2026, in compliance with TTR 221, she did place in the US 

mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number, the 

Notice of Docket Number issued by the Michigan Tax Tribunal for this appeal as well as this Proof 

of Service of Petition for the above captioned appeal to the units of government listed on the second 

page of this Proof of Service of Petition. 

 

/s/Jennifer Lunsford 

Jennifer Lunsford 

 

Karen Cameron states that she submitted electronically on 7/28/2026, to the Michigan Tax 

Tribunal 

a 

copy 

of 

this 

Proof 

of 

Service 

of 

Petition 

at 

eFile 

through 

www.etaxappeal.lara.state.mi.us. 

 

/s/Karen Cameron 

Karen Cameron

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 26-000986 

Page 2 of 2 

 

By Certified Mail 

 

Assessor’s Office 

Clinton Township 

Assessing Office 

40700 Romeo Plank Rd, 

Clinton Township, MI 48038 

 

CORRECTED & RE-MAILED ADDRESS 

Office of the Township Clerk 

Clinton Township 

Clerk's Office 

40700 Romeo Plank Road 

Clinton Township, MI 48038 

 

By First Class Mail 

 

CORRECTED & RE-MAILED ADDRESS 

Director of Equalization 

Macomb County 

Equalization Director 

1 South Main St. 

Mount Clemens, MI 48043 

 

CORRECTED & RE-MAILED ADDRESS 

County Clerk’s Office 

Macomb County 

Clerk’s Office 

40 N Main Street 

Mount Clemens, MI 48043 

 

Secretary of the School Board 

Clintondale Community Schools 

35200 Little Mack Avenue 

Clinton Township, MI 48035 

 

Treasurer for the State of Michigan 

Michigan Department of Treasury 

Lansing, MI 48922

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: 26-000986

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: POS_FIFTEEN_MILE-GRATIOT_INVESTMENT_LLC_26-000986 

CORRECTED

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

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 26-000986 

Page 1 of 2 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FIFTEEN MILE-GRATIOT INVESTMENT LLC, 

 

Petitioner, 

v 

MTT Docket No. 26-000986 

CLINTON TOWNSHIP, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Senior Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

Clinton Township 

Assessing Office 

40700 Romeo Plank Rd, 

Clinton Township, MI 48038 

(586) 723-8092 

_____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

STATE OF MICHIGAN 

) 

 

)ss 

COUNTY OF OAKLAND 

) 

 

Jennifer Lunsford, states that on 7/21/2026, in compliance with TTR 221, she did place in the US 

mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number, the 

Notice of Docket Number issued by the Michigan Tax Tribunal for this appeal as well as this Proof 

of Service of Petition for the above captioned appeal to the units of government listed on the second 

page of this Proof of Service of Petition. 

 

/s/Jennifer Lunsford 

Jennifer Lunsford 

 

Karen Cameron states that she submitted electronically on 7/21/2026, to the Michigan Tax 

Tribunal 

a 

copy 

of 

this 

Proof 

of 

Service 

of 

Petition 

at 

eFile 

through 

www.etaxappeal.lara.state.mi.us. 

 

/s/Karen Cameron 

Karen Cameron

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 26-000986 

Page 2 of 2 

 

By Certified Mail 

 

Assessor’s Office 

Clinton Township 

Assessing Office 

40700 Romeo Plank Rd, 

Clinton Township, MI 48038 

 

Office of the Township Clerk 

Clinton Township 

Clerk's Office 

172 W Michigan Ave 

Clinton, MI 49236 

 

By First Class Mail 

 

Director of Equalization 

Lenawee County 

Equalization Director 

301 N Main Street 

Adrian, MI 49221 

 

County Clerk’s Office 

Lenawee County 

Clerk’s Office 

425 N Main Street 

Adrian, MI 49221 

 

Secretary of the School Board 

Clintondale Community Schools 

35200 Little Mack Avenue 

Clinton Township, MI 48035 

 

Treasurer for the State of Michigan 

Michigan Department of Treasury 

Lansing, MI 48922

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: 26-000986

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: POS_FIFTEEN_MILE-GRATIOT_INVESTMENT_LLC_26-000986

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

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FIFTEEN MILE-GRATIOT INVESTMENT LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

Clinton Township, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

Clinton Township 

Assessing Office 

40700 Romeo Plank Rd, 

Clinton Township, MI 48038 

(586) 723-8092 

 

 

 

_____________________________________________________________________________/ 

 

2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, FIFTEEN MILE-GRATIOT INVESTMENT LLC, has the 

legal residence or principal office address of 34550 Commerce rd. Fraser MI 48026. 

Petitioner is a party in interest with respect to property taxes on property parcel no(s). 

(hereinafter referenced as the Subject Property) 16-11-27-452-040. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous. 

2. The Subject Property is located in Macomb County.

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, Clinton Township of Macomb County, assesses and collects property taxes 

on the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. The Subject 

Property is presently used or available for use for Commercial purposes. Petitioner 

believes that the Subject Property was originally designed to be used for Commercial 

purposes. 

5. Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

35192 GRATIOT AVE, CLINTON TOWNSHIP, MI 48035 

7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

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

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2026 

16-11-27-452-

040 

$6,305,600.00 

$3,152,800.00 

$1,791,130.0

0 

 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, 

are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: 

a. The assessment, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable value are 

based upon an erroneous determination of the true cash value of that portion 

of the Subject Property that is taxable under Michigan law, and are based 

upon the application of wrong principles; and 

d. The assessment, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

16-11-27-452-

040 

$2,700,000.00 

$1,350,000.00 

$1,350,000.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2026 

16-11-27-452-040 

$1,802,800.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton

Page 5

2026

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

FIFTEEN MILE-GRATIOT INVESTMENT LLC,

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

34550 Commerce rd

City or Town

FRASER

State

Michigan

ZIP Code

48026

Telephone Number

2482261632

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

tax.efile@colliers.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

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

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

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

tax.efile@colliers.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

35192 GRATIOT AVE

CLINTON TOWNSHIP

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48035

Taxing Authority (City or Township)

Township Of Clinton (MACOMB) 

County

Macomb

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

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

N/A

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

16-11-27-452-040

Classification of Property: Real (check one)

Commercial (check one)

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

3152800

Current Taxable Value as established by the Board of Review:

1791130

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

2700000

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

1350000

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

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ /s/Joshua T. Shillair

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051485421118

Supporting Waiver Documents:

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Fifteen Mile Gratiot Investment LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000986

Township Of Clinton, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 8, 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

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FIFTEEN MILE-GRATIOT INVESTMENT LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

Clinton Township, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

Clinton Township 

Assessing Office 

40700 Romeo Plank Rd, 

Clinton Township, MI 48038 

(586) 723-8092 

 

 

 

_____________________________________________________________________________/ 

 

2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, FIFTEEN MILE-GRATIOT INVESTMENT LLC, has the 

legal residence or principal office address of 34550 Commerce rd. Fraser MI 48026. 

Petitioner is a party in interest with respect to property taxes on property parcel no(s). 

(hereinafter referenced as the Subject Property) 16-11-27-452-040. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous. 

2. The Subject Property is located in Macomb County.

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, Clinton Township of Macomb County, assesses and collects property taxes 

on the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. The Subject 

Property is presently used or available for use for Commercial purposes. Petitioner 

believes that the Subject Property was originally designed to be used for Commercial 

purposes. 

5. Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

35192 GRATIOT AVE, CLINTON TOWNSHIP, MI 48035 

7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

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

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2026 

16-11-27-452-

040 

$6,305,600.00 

$3,152,800.00 

$1,791,130.0

0 

 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, 

are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: 

a. The assessment, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton Township 

Parcel Number: 16-11-27-452-040 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable value are 

based upon an erroneous determination of the true cash value of that portion 

of the Subject Property that is taxable under Michigan law, and are based 

upon the application of wrong principles; and 

d. The assessment, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

16-11-27-452-

040 

$2,700,000.00 

$1,350,000.00 

$1,350,000.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2026 

16-11-27-452-040 

$1,802,800.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2026 Entire Tribunal Property Tax Petition & Proof of Service 

FIFTEEN MILE-GRATIOT INVESTMENT LLC v Clinton

Page 5

2026

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

FIFTEEN MILE-GRATIOT INVESTMENT LLC,

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

34550 Commerce rd

City or Town

FRASER

State

Michigan

ZIP Code

48026

Telephone Number

2482261632

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

tax.efile@colliers.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

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

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

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

tax.efile@colliers.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

35192 GRATIOT AVE

CLINTON TOWNSHIP

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48035

Taxing Authority (City or Township)

Township Of Clinton (MACOMB) 

County

Macomb

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

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

N/A

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

16-11-27-452-040

Classification of Property: Real (check one)

Commercial (check one)

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

3152800

Current Taxable Value as established by the Board of Review:

1791130

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

2700000

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

1350000

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

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ /s/Joshua T. Shillair

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051485421118

Supporting Waiver Documents:

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