Hd Development Of Maryland Inc, Petitioner Vs. City Of Southfield, Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

HD Development of Maryland Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002265 

 

 

 

_____________________________________________________________________________/ 

 

DANIEL L. STANLEY (P57052) 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorneys for Petitioner 

222 North Washington Square, Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

(313) 465-7270 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

RESPONDENT’S RESPONSE TO PETITIONER’S MOTION TO AMEND 

PETITION TO CONTEST 2026 ASSESSED AND TAXABLE VALUES 

 

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

responds to the allegations made in Petitioner’s Motion to Amend as follows: 

1. 

Respondent admits the allegations in Paragraph 1. 

2. 

Respondent denies the allegations in Paragraph 2, including subparagraphs (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

Page 2

2

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

constitutional. 

3. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Motion but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. Respondent incorporates by reference the affirmative defenses set forth in 

its Answer to Petition herein. 

WHEREFORE, Respondent, City of Southfield, requests the Tribunal enter an Order 

denying Petitioner’s Motion to Amend and dismissing the appeal. 

 

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: June 5, 2026 

(248) 731-3089

Page 3

3

 

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Response to 

Petitioner’s Motion to Amend to: 

 

Daniel L. Stanley 

Honigman LLP 

dstanley@honigman.com 

 

Jackie J. Cook 

Honigman LLP 

jcook@honigman.com 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

 

/s/Kelsea M. Melcher___________ 

Dated: June 5, 2026 

Kelsea M. Melcher

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Page 1

1 of 1

Docket #: 25-002265

Party Filing Document

Party Filing Document: 

 Respondent

 Respondent

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

RECEIVED sq, 

MAY 15 2026 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRBICHIGAN TAX TRIBUNAL 

HD Development of Maryland, Inc., 

Petitioner, 

Vv. 

Southfield, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 25-002265 

a1 

06/18/26 

$300.00 

dh: 0075 

HONTGHA LLP 

/ 

Daniel L. Stanley (P57052) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

(313) 465-7270 

dstanley@honigman.com 

jcook@honigman.com 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

/ 

Motion to Amend Petition to Contest 

2026 Assessed and Taxable Values 

Petitioner, HD Development of Maryland, Inc., through 

its attorneys, Honigman LLP, 

moves to amend the Petition in this matter to include the following: 

1. 

In 2026, Respondent determined the taxable value of Petitioner’s Property 

to be $3,083,526 and Respondent assessed Petitioner’s Property at $4,526,090 

, which will result

Page 2

2. 

The 2026 assessment, including state equalized value and taxable value, 

imposed on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and 

unlawful for the reasons that: 

(a) 

The assessment, 

including state equalized value and/or taxable value, 

exceeds the amounts permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(©) 

The assessment, including taxable value and/or state equalized value, 

is 

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

Property that is taxable under Michigan law and is based upon the application of wrong principles; 

and 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode 

of assessment adopted 

by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner moves that this Motion be granted, and Petitioner requests that 

the Tribunal enter an Order: 

(i) reducing the 2026 assessed and state equalized value from 

$4,526,090 

to $2,340,000 

; (ii) reducing the 2026 taxable value from $3,083,526 

to $2,340,000 

; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled.

Page 3

Dated: 

May 15, 2026 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: /s/ Daniel L. Stanley 

Daniel L. Stanley (P57052) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517)377-0714 

(313) 465-7270 

dstanley@honigman.com 

jcook@honigman.com

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

HD DEVELOPMENT OF MARYLAND, INC., 

Petitioner, 

Vv. 

MTT Docket No. 25-002265 

SOUTHFIELD, 

Respondent. 

/ 

Proof of Service 

Lisa Joseph affirms that on May 15, 2026 _ she served a copy of Petitioner's Motion to 

Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service 

in 

connection with the above-entitled cause upon the following: 

L Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

lhallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

via electronic mail. 

Dated: May 15, 2026 

/s/ Lisa Joseph 

Lisa Joseph

Page 5

Honigman LLP 

COSTS ADVANCED ACCOUNT 

040713 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

5/14/26 

040713 

DLS/278324/547716 

300.00 

Motion to Amend 25-002265 

24559387.1

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

HD Development of Maryland, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002265 

 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

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 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-002405 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of the big box store 

commonly known as Home Depot – Parcel No. 76-24-11-426-027 - located in Oakland County. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-002405 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

Page 2

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-002405) has not yet been resolved. A Prehearing Conference is scheduled for 

October 30, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

002405 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

002405 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

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

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

002405. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-002405.

Page 3

3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ Daniel Stanley (w/ consent)_____________ 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

 

 

Dated: September 24, 2025 

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 

(248) 731-3089 

 

Dated: September 24, 2025

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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 

HD Development of Maryland Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002265 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

On September 24, 2025, the parties filed a joint motion requesting that the Tribunal hold 

this case in abeyance pending resolution of MTT Docket No. 24-002405, which is 

currently pending before the Tribunal. In the motion, the parties state that the above-

mentioned case pertains to the same parties, property, and claims as the subject 

appeal, and its resolution could impact the proceedings in this matter. It could waste 

time and resources for both the parties and the Tribunal to proceed in this matter while 

MTT Docket No. 24-002405 is still pending. 

 

The Tribunal has considered the motion and the case file and finds that placing this 

case in abeyance pending resolution of MTT Docket No. 24-002405 will facilitate the 

efficient administration of justice, as that resolution may have a direct bearing on the 

outcome of the instant appeal. Therefore, 

 

IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of the resolution of MTT Docket No. 24-002405 as to the need for further 

proceedings in this matter. 

 

 

 

Entered: September 24, 2025 

 

 

By _____________________________ 

cs 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

HD Development of Maryland, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002265 

 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

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 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-002405 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of the big box store 

commonly known as Home Depot – Parcel No. 76-24-11-426-027 - located in Oakland County. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-002405 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

Page 2

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-002405) has not yet been resolved. A Prehearing Conference is scheduled for 

October 30, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

002405 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

002405 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

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

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

002405. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-002405.

Page 3

3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ Daniel Stanley (w/ consent)_____________ 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

 

 

Dated: September 24, 2025 

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 

(248) 731-3089 

 

Dated: September 24, 2025

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Page 1

RECEIVED 

JUL.01 2025 

STATE OF MICHIGAN 

NAL 

MICHIGAN TAX TRIBUNAL 

MICHIGAN TAX TRIBU 

HD DEVELOPMENT OF MARYLAND, INC., 

Petitioner, 

Docket No. 25-002265 

v 

CITY OF SOUTHFIELD, 

Respondent. 

/ 

MICHAEL B. SHAPIRO (P20282) 

LAURA M. HALLAHAN (P42101) 

DANIEL L. STANLEY (P57052) 

SETH A. O’LOUGHLIN (P80257) 

HONIGMAN LLP 

KELSEA M. MELCHER (P85821) 

Attorneys for Petitioner 

HALLAHAN & ASSOCIATES, P.C. 

39400 Woodward Avenue, Suite 101 

Attorneys for Respondent 

Bloomfield Hills, MI 48304-5151 

1750 S. Telegraph Road, Suite 202 

(313) 465-7622 

Bloomfield Hills, MI 48302 

(248) 731-3089 

ANSWER TO SEVERED 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 admits the allegations in Paragraph 

1 as to parcel number and address. 

Respondent lacks the information and knowledge necessary to respond to the remainder of the 

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

Page 2

4. 

Respondent admits that subject property is classified as commercial real. With 

respect to the remaining allegations in Paragraph 4, Respondent lacks knowledge or information 

sufficient to form a belief as to the truth of the allegations contained therein and leaves Petitioner 

to its proofs. 

S. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies 

that Petitioner’s claims have merit and further denies that Petitioner is entitled to any relief. 

6. 

Respondent denies the allegations in Paragraph 6. 

7. 

Respondent neither admits nor denies the statement in Paragraph 7 for the reason 

that no assertion was made. In further answer, Petitioner only sets forth a hypothetical condition 

(i.e., “if P.A. 174 of 2006 requires a board of review protest 

. 

. .) but then fails to state whether or 

not a protest was made. 

8. 

Respondent denies the allegations in Paragraph 8, including subparagraphs (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. 

9. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent, City of Southfield, requests the Tribunal dismiss the Petition,

Page 3

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: June 27, 2025 

(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 Cov 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. 

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.

Page 4

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 the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

13. 

Respondent reserves the right to raise additional affirmative defenses as the same 

may become known to it during the course of these proceedings. 

HALLAHAN & ASSOCIATES, P.C. 

/s/ Laura M. Hallahan 

LAURA M. HALLAHAN (P42101) 

SETH A.

Page 5

PROO

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Page 1

RECEIVED © 

JN 06205 

% 

\ 

MICHIGAN TAX TRIBUNA 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

HD Development of Maryland, Inc., 

Petitioner, 

Vv. 

MTT Docket No. 25-002265 

Parcel No. 76-24-11-426-027 

Southfield, 

Respondent. 

PROOF OF SERVICE 

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

that on 

G/ b 

/ 25, she did serve a copy of Petitioner's Severed Petition, with docket 

number, upon the parties named on the attached list. 

/s/ Leon Qpeesh 

Lisa Joseph 

4 

7

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

SOUTHFIELD 

26000 EVERGREEN ROAD 

SOUTHFIELD, MI 48076 

ASSESSOR 

SOUTHFIELD 

26000 EVERGREEN ROAD 

SOUTHFIELD, MI 48076 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

SECRETARY OF SCHOOL BOARD 

SOUTHFIELD PUBLIC SCHOOLS 

24661 LAHSER ROAD 

SOUTHFIELD, MI 48033-3238 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

VIA ELECTRONIC MAIL 

Laura M. Hallahan

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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

HD Development of Maryland Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002265

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: June 6, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

HD Development of Maryland Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002265

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: June 6, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

25-0088 

60794158.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

HD Development of Maryland, Inc., 

Petitioner, 

v. 

MTT Docket No. 25-002265 

 

[Parcel No(s). 76-24-11-426-027] 

Southfield, 

Respondent. 

_________________________/ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.colm 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

/

 

SEVERED PETITION 

HD Development of Maryland, Inc. (“Petitioner”), through its attorneys, HONIGMAN 

LLP, says: 

1. 

Petitioner's principal office address is 2455 Paces Ferry Road, Atlanta, GA 30339. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 76-24-11-426-

027 ("Petitioner's Property"), also known as Store No. 2711 at 29801 Southfield Road located in

Page 2

2 

60794158.1 

Oakland County, Michigan. If this petition includes more than one (1) real property tax parcel, 

the tax parcels are contiguous. 

2. 

Respondent, Southfield, assesses and collects property taxes on Petitioner's 

Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$3,002,460 and assessed Petitioner's Property at $3,002,460, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4. 

Petitioner's Property is classified as Commercial Real. Petitioner's Property is 

presently used or available for use for Retail purposes. Petitioner believes that Petitioner's Property 

was originally designed to be used for Retail purposes. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value and (d) uniformity. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's 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, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes;

Page 3

3 

60794158.1 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, are 

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

Property that is taxable under Michigan law, and are based upon the application of wrong 

principles; and, 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value of Petitioner's Property from $3,002,460 to $2,340,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $3,002,460 to $2,340,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs.

Page 4

4 

60794158.1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: June 5, 2025 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

By: __________________________________________ 

 

Michael B. Shapiro (P20282) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

By: ______________________________________ 

Daniel L. Stanley (P57052) 

dsanley@honigman.com 

 

/s/ Michael B. Shapiro

/s/ Daniel L. Stanley

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 

HD Development of Maryland Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket Nos. 24-002405 

 

 

& 25-002265 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION TO AMEND 

 

ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT TO 

DOCKET NUMBER 25-002265 

 

On May 9, 2025, Petitioner filed a motion requesting that the Tribunal permit it to amend 

the petition filed in this case to include tax year 2025. 

 

On May 30, 2025, Respondent filed a response to the motion. In the response, 

Respondent objects to amending the petition to include tax year 2025 as valuation 

disclosures are due June 20, 2025, and the parties have not conducted discovery as to 

tax year 2025. Respondent further states that if the Tribunal should grant the motion, 

that the 2025 tax year be severed from this appeal and proceed separately, given the 

stage of proceedings in this matter. 

 

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

Petitioner timely filed its Motion to Amend, included the necessary information and filing 

fee, and otherwise met all requirements set forth in MCL 205.737 and MCL 205.735a. 

Due to the stage in which this case is at, however, and in the interest of judicial 

efficiency, the 2025 tax year shall be severed from this case and assigned to a new 

docket number. Therefore, 

 

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. 

 

IT IS FURTHER ORDERED that Petitioner’s assessment appeal for the 2025 tax year is 

SEVERED and ASSIGNED to Docket No. 25-002265. 

 

IT IS FURTHER ORDERED that Petitioner shall file a petition for the 2025 tax year 

within 21 days of entry of this order. The petition shall note the docket number assigned 

by the Tribunal for the 2025 tax year and if filed utilizing the Tribunal’s e-filing system, 

must be filed on the assigned 2025 docket as a “Severed Petition.”1 

 

1 Alternatively, the petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via 

United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition

Page 2

MTT Docket Nos. 24-002405 & 25-002265 

Page 2 of 2 

 

Failure to comply with this order may result in Petitioner being held in default, as 

provided by TTR 237. 

 

 

Entered: June 4, 2025 

 

 

 

By _____________________________ 

cs 

 

 

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 

 

 

 

 

 

may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax 

Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933.

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.