Hall Road Ventures LLC Petitioner Vs. Township Of Clinton Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

HALL ROAD VENTURES, LLC, 

 

 

 

Petitioner, 

 

v 

 

CLINTON TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001417 

 

Parcel No. 16-11-03-105-020 

 

_____________________________________________________________________________/ 

 

JEROME P. PESICK (P29039) 

JASON C. LONG (P59244) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Attorneys for Petitioner 

380 N. Old Woodward Avenue, Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

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 

_____________________________________________________________________________/ 

 

AMENDED 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: 

The Parties 

1. 

Respondent lacks knowledge or information sufficient 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. 

 

The Subject Property 

 

3. 

Respondent admits the indicated assessment record address of the identified parcel. 

Respondent lacks the knowledge or information sufficient to respond to the truth of the remaining 

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

Page 2

2

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5. 

 

The 2026 Assessment 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent denies the allegation in Paragraph 7 as the 2026 taxable value on the 

rolls. 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 

$11,880,400 

$5,940,200 

$4,423,012 

 

8. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$11,880,400 

$5,940,200 

$4,423,012 

 

9. 

 The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

10. 

Respondent acknowledges Petitioner’s belief as to a dispute in the subject 

property’s valuation but denies Petitioner’s contentions of value have merit and further denies 

Petitioner is entitled to relief. Respondent admits there is no issue relating to “additions” or 

“losses” but denies Petitioner has a right to raise such issues at a later date. 

 

11. 

 Respondent denies the allegations in Paragraph 11, including subparts (a)-(d), for 

the reason that the same are untrue. In further answer, the assessed, state equalized and/or taxable 

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

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

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

 

12. 

Respondent admits the subject property’s assessment is uniform but denies it 

overestimated the subject property’s value or otherwise misapplied the General Property Tax Act. 

 

Conclusion and Request for Relief 

 

13. 

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 set forth above.

Page 3

3

 

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: October 8, 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 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

Page 4

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: 26-001417

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

Party Filing Document 

Respondent

Files

Document Type: Amended Answer

Attachment File Name: AMENDED Answer_Hall Road_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

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

Hall Road Ventures LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001417

Township Of Clinton,

Respondent.

ORDER OF DEFAULT

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

The answer incorrectly identifies the parcel number of the property or properties at 

issue. As such, Respondent must file and serve an amended answer identifying the 

correct parcel number(s) and file proof demonstrating service of the amended answer 

within 14 days of the entry of this order. See TTR 235 and 227. Tribunal rules and 

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

www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent 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.1 

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: /s/ Patricia L. Halm

Entered: October 7, 2026

1 “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 

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 2

MTT Docket No. 26-001417

Page 2 of 2

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 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

Hall Road Ventures LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001417

Township Of Clinton,

Respondent.

ORDER OF DEFAULT

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

The answer incorrectly identifies the parcel number of the property or properties at 

issue. As such, Respondent must file and serve an amended answer identifying the 

correct parcel number(s) and file proof demonstrating service of the amended answer 

within 14 days of the entry of this order. See TTR 235 and 227. Tribunal rules and 

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

www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent 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.2 

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: /s/ Patricia L. Halm

Entered: October 7, 2026

2 “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 

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

Page 4

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

HALL ROAD VENTURES, LLC, 

 

 

 

Petitioner, 

 

v 

 

CLINTON TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001417 

 

Parcel No. 16-11-03-15-020 

 

_____________________________________________________________________________/ 

 

JEROME P. PESICK (P29039) 

JASON C. LONG (P59244) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Attorneys for Petitioner 

380 N. Old Woodward Avenue, Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

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: 

The Parties 

1. 

Respondent lacks knowledge or information sufficient 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. 

 

The Subject Property 

 

3. 

Respondent admits the indicated assessment record address of the identified parcel. 

Respondent lacks the knowledge or information sufficient to respond to the truth of the remaining 

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

Page 2

2

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5. 

 

The 2026 Assessment 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent denies the allegation in Paragraph 7 as the 2026 taxable value on the 

rolls. 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 

$11,888,400 

$5,940,200 

$4,423.012 

 

8. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$11,888,400 

$5,940,200 

$4,423,012 

 

9. 

 The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

10. 

Respondent acknowledges Petitioner’s belief as to a dispute in the subject 

property’s valuation but denies Petitioner’s contentions of value have merit and further denies 

Petitioner is entitled to relief. Respondent admits there is no issue relating to “additions” or 

“losses” but denies Petitioner has a right to raise such issues at a later date. 

 

11. 

 Respondent denies the allegations in Paragraph 11, including subparts (a)-(d), for 

the reason that the same are untrue. In further answer, the assessed, state equalized and/or taxable 

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

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

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

 

12. 

Respondent admits the subject property’s assessment is uniform but denies it 

overestimated the subject property’s value or otherwise misapplied the General Property Tax Act. 

 

Conclusion and Request for Relief 

 

13. 

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 set forth above.

Page 3

3

 

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: September 20, 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 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

Page 4

4

8.

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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. 26-001417

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.

M

Last Name

Halahan

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

48302-2073

Telephone Number

2487313090

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

lhallahan@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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

HALL ROAD VENTURES LLC, 

Docket No. 26-001417 

Petitioner, 

Parcel No. 16-11-03-105-020 

V. 

CLINTON CHARTER TOWNSHIP, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, Mi 48009 

(248) 642-0333 

Attomeys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, Notice of Docket Number, and this Proof of Service, on the persons 

listed 

below, 

by the means 

identified, 

by placing those documents 

in duly stamped, 

addressed envelopes, and placing the envelopes in the United States mail on August 24, 

2026. 

PERSONS SERVED: 

Clerk 

Clerk 

Secretary of School Board 

Charter Township of 

Macomb County 

Chippewa Valley School District 

Clinton 

120 N Main St, 

19120 Cass Avenue 

40700 Romeo Plank Rd 

Mt.Clemens, MI 48043 

Clinton Township, MI 48038 

Clinton Twp., MI 48038 

Assessor 

Director of Equalization 

State Treasurer 

Charter Township of 

Macomb County 

Michigan Department of Treasury 

Clinton 

1 S Main St 6th floor, 

Austin Building 

40700 Romeo Plank Rd 

Mt Clemens, MI 48043 

430 W. Allegan 

Clinton Twp., MI 48038 

Lansing, Ml 

48922 

Via Whores) 

Monica Athanas

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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: 26-001417

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 - Petition - HRV2026

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

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

HALL ROAD VENTURES LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 16-11-03-105-020 

 

v. 

 

CLINTON CHARTER TOWNSHIP, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Hall Road Ventures LLC, by and through its attorneys, Williams, 

Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner Hall Road Ventures LLC is a Michigan limited liability 

company with its principal place of business in Michigan located at 26640 Harding 

Street, Oak Park, Michigan. 

2. 

Respondent the Clinton Charter Township is a Michigan charter

Page 2

2 

township with its principal offices located at 40700 Romeo Plank Road, Clinton 

Township, Michigan. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 16-11-03-105-020 and 

commonly known as 20900 Hall Road, Clinton Township, Michigan (the “Subject 

Property”). 

4. 

The Subject Property is located in Macomb County and is within the 

Chippewa Valley schools district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 11,880,400 5,940,200 

 4,176,508 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 5,500,000 2,750,000 

 2,750,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 6,380,400 3,190,200 

 1,426,508

Page 3

3 

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: May 26, 2026 

 

 

Attorneys for Petitioner

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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

HALL ROAD VENTURES LLC

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

26640 Harding Street, Oak Park, Michigan

City or Town

Oak Park

State

Michigan

ZIP Code

48237

Telephone Number

2486420333

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

jpesick@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Williams, Williams, Rattner & Plunkett, PC

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

380 N. Old Woodward, Ste 300

City or Town

Birmingham

State

Michigan

ZIP Code

49009

Telephone Number

2486420333

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

jpesick@wwrplaw.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]

20900 Hall Road

Clinton Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48044

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:

16-11-03-105-020

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:

5940200

Current Taxable Value as established by the Board of Review:

4176508

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

5500000

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

2750000

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

2750000

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/ Jerome P. Pesick

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686940338

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

Hall Road Ventures LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001417

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: 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.

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

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

HALL ROAD VENTURES LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 16-11-03-105-020 

 

v. 

 

CLINTON CHARTER TOWNSHIP, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Hall Road Ventures LLC, by and through its attorneys, Williams, 

Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner Hall Road Ventures LLC is a Michigan limited liability 

company with its principal place of business in Michigan located at 26640 Harding 

Street, Oak Park, Michigan. 

2. 

Respondent the Clinton Charter Township is a Michigan charter

Page 2

2 

township with its principal offices located at 40700 Romeo Plank Road, Clinton 

Township, Michigan. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 16-11-03-105-020 and 

commonly known as 20900 Hall Road, Clinton Township, Michigan (the “Subject 

Property”). 

4. 

The Subject Property is located in Macomb County and is within the 

Chippewa Valley schools district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 11,880,400 5,940,200 

 4,176,508 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 5,500,000 2,750,000 

 2,750,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 6,380,400 3,190,200 

 1,426,508

Page 3

3 

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: May 26, 2026 

 

 

Attorneys for Petitioner

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

HALL ROAD VENTURES LLC

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

26640 Harding Street, Oak Park, Michigan

City or Town

Oak Park

State

Michigan

ZIP Code

48237

Telephone Number

2486420333

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

jpesick@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Williams, Williams, Rattner & Plunkett, PC

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

380 N. Old Woodward, Ste 300

City or Town

Birmingham

State

Michigan

ZIP Code

49009

Telephone Number

2486420333

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

jpesick@wwrplaw.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]

20900 Hall Road

Clinton Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48044

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:

16-11-03-105-020

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:

5940200

Current Taxable Value as established by the Board of Review:

4176508

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

5500000

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

2750000

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

2750000

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/ Jerome P. Pesick

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686940338

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.