Michigan

Franklin Medical Holdings LLC Petitioner Vs. City Of Southfield Respondent

Petitioner: Franklin Medical Holdings LLC
Respondent: City Of Southfield

Case overview

Docket number: 26-001424-TT
Status: Answer Due
CaseType: ET Property
Division: ET
County: Oakland
Judge: No judge assigned

Docket history

Line #	Subject	Filer	Line Ref	Enter Date/Post Mark	Fee	Related Item
5	Answer was received	RESP	Not recorded	10/22/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
4	Proof of service of petition was received.	Not recorded	Not recorded	09/24/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
3	Petition has been verified	PET	1	08/11/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
2	Notice of Docket Number ET	Not recorded	Not recorded	08/11/2026	Not recorded	Download
1	A petition was received.	PET	Not recorded	05/26/2026	$400.00	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download

Documents

Answer to Petition and Affirmative Defenses.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Franklin Medical Holdings, LLC, 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

Docket No. 26-001424 

 

_____________________________________________________________________________/ 

 

PETER ELLENSON (P47383) 

LAW OFFICE OF PETER ELLENSON, 

P.C. 

Attorney for Petitioner 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

(248) 406-4443 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

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 necessary to respond to the allegations in 

Paragraph 1 and leaves Petitioner to its proofs. 

 

2. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 2 and leaves Petitioner to its proofs. 

 

3. 

Respondent admits the allegations in Paragraph 3. 

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5.

Page 2

Entire Tribunal Property Tax Answer

Page 2 of 5

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

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

Respondent acknowledges Petitioner identification of the 2026 tax year as being

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

Respondent neither admits nor denies the necessity of a protest to the Board of

Review as the General Property Tax Act speaks for itself.

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

Board of Review are:

Tax

Year

True Cash Value

Assessed Value

Taxable Value

2026

$1,817,460

$908,730

$901,551

10.

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

Tax

Year

True Cash Value

State Equalized Value

Taxable

Value

2026

$1,817,460

$908,730

$901,551

11.

The values in dispute for the property identified above are:

Tax

Year

True Cash Value

State Equalized Value

Taxable

Value

2026

12.

Petitioner is not entitled to the relief requested in Paragraph 12 for the reason that

Petitioner’s amounts do not reflect the accurate valuations for this property. Furthermore, 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 principals, and the values and Respondent’s mode of

assessment are non-discriminatory and constitutional.

13.

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

untrue. 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 principals, 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 City of Southfield 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) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: October 22, 2026 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent City of Southfield asserts the following affirmative defenses: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

(1981). 

3. 

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

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

4. 

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

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

its agents.

Page 4

Entire Tribunal Property Tax Answer 

Page 4 of 5 

 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

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

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

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

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

10. 

Any decrease in

Page 5

En

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EntireTribunalCaseISAnswer.pdfRead complete document text →

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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. 26-001424

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: 

Laura M. Hallahan

/s/

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Franklin Medical Holdings - Southfield - POS 2026 ET Petition.pdfRead complete document text →

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Page 1

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

______________________________________________________________________ 

_______________________________ 

_______________________________ 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

_____________________________, 

Petitioner(s) 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No. 

_____________________________, 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

___________________________________ states that on ___________________ he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. Assessor (via certified mail): 

2. City Clerk or Township Supervisor/Clerk (via certified mail): 

3. County Equalization Director (via first class mail or personal service): 

4. County Clerk (via first class mail or personal service): 

5. Secretary of the local school board (via first class mail or personal service): 

6. State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

[Signature of person who is serving/mailing copy] 

[Print/type name of person serving/mailing copy] 

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 

Franklin Medical Holdings, LLC

26-001424

City of Southfield

Peter Ellenson

9/25/26

Southfield Assessor, 26000 Evergreen Rd, Southfield, MI 48076

Southfield Clerk, 26000 Evergreen Rd, Southfield, MI 48076

Oakland County Equalization Director, 250 Elizabeth Lake Rd #1000W, Pontiac, MI 

48341

Oakland County Clerk, 1200 N Telegraph, Pontiac, MI 48341

Secretary of the Board, Southfield Public Schools, 24661 Lahser Road, Southfield, MI 

48033

/s/ Peter Ellenson

Peter Ellenson

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SubsequentFiling.pdfRead complete document text →

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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: 26-001424

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: Franklin Medical Holdings - Southfield - POS 2026 ET Petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Franklin Medical Holdings - Southfield - ET Petition 2026.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FRANKLIN MEDICAL HOLDINGS, LLC, 

 

Petitioner, 

v 

 

 

 

 

 

 

 

MTT Dkt. No. 

 

 

 

 

 

 

 

 

 

CITY OF SOUTHFIELD, 

 

 

 

Parcel No. 76 24 07 477 010 

Respondent. 

 

 

 

 

 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

 

Attorney for Petitioner 

 

 

 

 

 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

248 406 4443 

peter@ellensonlaw.com 

______________________________________/ 

 

ENTIRE TRIBUNAL TAX PETITION – TY 2026 

 

 

NOW COMES Petitioner, FRANKLIN MEDICAL HOLDINGS, LLC, through its 

attorney, PETER ELLENSON, and states as follows in support of this Petition: 

1. 

Petitioner is a party in interest with respect to the property taxes for the following 

parcel number: 76 24 07 477 010, located at 26206 W 12 Mile Road, Southfield, MI 48034. 

 

2. 

Petitioner’s principal office address is 23815 Northwestern Hwy., Southfield, MI 

48075. 

3. 

Respondent City of Southfield assesses and collects the ad valorem property taxes 

associated with the subject parcels. 

4. 

The subject property is classified as commercial improved (201). 

5. 

The subject property is located in Oakland County. 

6. 

This appeal involves the property’s true cash and taxable values. 

7. 

The tax year at issue is 2026.

Page 2

8. 

No Board of Review petitions was filed or required. 

9. 

The 2026 values for the subject property as established by the Respondent at its 

March 2026 Board of Review are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

1,817,460 

 

 

908,730 

 

 

901,551 

 

10. 

Petitioner contends that the values for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

1,000,000 

 

 

500,000 

 

 

500,000 

 

11. 

The values in dispute for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

817,460 

 

 

408,730 

 

 

401,551 

 

12. 

Petitioner requests that this Honorable Tribunal order the assessing entity to 

correct its tax rolls to reflect taxable, assessed and state equalized values as indicated above (or 

on the attached supplement) to issue refunds as appropriate, and to pay interest and costs. 

13. 

The basis for the requested relief is that the assessed and taxable values exceed 

50% of the true cash value of the subject property. 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: May 26, 2026 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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EntireTribunalCaseISPetition.pdfRead complete document text →

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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 - 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

Franklin Medical Holdings, LLC

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

23815 Northwestern Highway

City or Town

Southfield

State

Michigan

ZIP Code

48075

Telephone Number

2484064443

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

peter@ellensonlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Peter

M.I.

Last Name

Ellenson

Firm Name (if any)

Law Office of Peter Ellenson, PC

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

30500 Northwestern Highway

Suite 500

City or Town

Farmington Hills

State

Michigan

ZIP Code

48334-3177

Telephone Number

2487031134

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

peter@ellensonlaw.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]

26206 W 12 Mile Road

Southfield

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48034

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.)

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:

76 24 07 477 010

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:

908730

Current Taxable Value as established by the Board of Review:

901551

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

1000000

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

500000

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

500000

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/ Peter Ellenson

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686945394

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-08-11_17-20-17.pdfRead complete document text →

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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

Franklin Medical Holdings LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

MTT Docket No.: 26-001424

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: August 11, 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.