Iip-Mi 4 LLC Petitioner Vs. City Of Warren Respondent

Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

IIP-MI 4 LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF WARREN, 

 

 

 

Respondent. 

 

 

MTT Docket No. 26-001376 

 

Parcel No. 12-13-35-301-011 

 

_____________________________________________________________________________/ 

 

SARAH R. BELLOLI 

RYAN LLC 

Representative for Petitioner 

101 W. Big Beaver Road, Suite 945 

Troy, MI 48084 

(313) 230-0104 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Warren, 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. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent neither admits nor denies the allegations in Paragraph 3 as no claim is 

made. 

 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 as no claim is 

made.

Page 2

2 

 

 

5. 

Respondent neither admits nor denies the allegations in Paragraph 5 as no claim is 

made. 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent admits no protest before the Board of Review was made but neither 

admits nor denies the necessity of such a protest as the General Property Tax Act speaks for itself. 

 

8. 

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

Review as the General Property Tax Act speaks for itself. 

 

9. 

Respondent neither admits nor denies the timeliness of Petitioner’s Petition as 

Petitioner’s Petition and the General Property Tax Act speak for themselves. 

 

10. 

Respondent admits the allegations in Paragraph 10. 

 

11. 

Respondent admits the allegations in Paragraph 11. 

 

12. 

Respondent lacks the information and knowledge necessary to respond to the truth 

of the allegations set forth in Paragraph 12 and, therefore, leaves Petitioner to its proofs. 

 

13. 

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

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

 

14. 

Respondent acknowledges Petitioner’s identification of the 2026 tax year as being 

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

 

15. 

Respondent neither admits nor denies the allegations in Paragraph 15 as no claim 

is made. 

16. 

 

 

17. 

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 

$13,713,420 

$6,856,710 

$6,266,217 

 

18. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$13,713,420 

$6,856,710 

$6,266,217

Page 3

3 

 

19. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

20. 

Respondent acknowledges the relief requested by Petitioner in Paragraph 19 but 

denies that Petitioner is entitled to said relief for the reasons set forth above. 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 principles, and the values and Respondent’s mode of assessment are 

non-discriminatory and constitutional. 

 

21. 

Respondent denies the allegations in Paragraph 20, including subparagraphs (A) 

and (B), for the reason that the same are untrue. 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 

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

constitutional. 

 

 

WHEREFORE, Respondent, City of Warren, 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/Seth A. O’Loughlin______________ 

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 18, 2026 

 

 

 

(258) 731-3089

Page 4

4 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Warren, 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. 

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

Page 5

5

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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. 26-001376

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Warren (MACOMB)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

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

mtt@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Seth A. O'Loughlin

/s/

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Page 1

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Tel. (313) 230-0104 

Fax (313) 230-0114 

RECEIVED 

JUL 15 2028 

July 13, 2026 

State of Michigan Treasurer 

Treasury Building, 430 West Allegan Street 

MICHIGA 

Lansing, MI 48922 

N TAX TRIBUNAL 

Re: ITP-MI 4 LLC v City of Warren 

MTT Docket No.: 26-001376 

Dear Chief Clerk: 

Petitioner hereby serves all parties provided for in Michigan Tax Tribunal Rule 221 with its petition in 

this matter. Pursuant to the rule, the petition notes the docket number assigned by the Tribunal and is 

served within 45-days of the issuance of the notice of docket number. 

If you have any questions regarding the enclosed pleading, please do not hesitate to contact our office 

directly at (313) 230-0104. 

Respectfully, 

Sarah R. Belloli 

Ryan, LLC 

cc: 

State of Michigan Treasurer 

Van Dyke Public Schools 

Macomb County Equalization Director 

Macomb County Clerk 

CITY OF WARREN Assessor 

CITY OF WARREN Clerk 

Enclosures

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

IIP-MI 4 LLC, 

MTT Docket No.: 26-001376 

Petitioner, 

v 

City of Warren, 

Respondent. 

Proof of Service 

Joan Kleiner, being duly sworn, deposes and says that on July 13, 2026, she served a copy of the Petition with noted 

docket number relative to the above-captioned matter upon the following parties as required by the Tribunal’s 

service rules: 

VIA CERTIFIED MAIL 

CITY OF WARREN Assessor: 

City of Warren Assessor, 

1 City Square SUITE 205, Warren, MI 48093 

CITY OF WARREN Clerk: 

City of Warren Clerk , 

1 City Square, Warren, MI 48093 

VIA FIRST-CLASS MAIL 

Macomb County Equalization Director: 

Macomb County Equalization Director, 

1 S$ Main St, Mount Clemens, MI 48043 

Macomb County Clerk: 

Macomb County Clerk, 

1 S Main St, Mount Clemens, MI 48043 

Van Dyke Public Schools — School Board Secretary: 

Van Dyke Public Schools, 23500 Macarthur Blvd, Warren, MI 48089 

Treasurer of the State of Michigan: 

State of Michigan Treasurer, Treasury Building, 430 West Allegan Street, Lansing, MI 48922 

With proper postage affixed thereto. Proof of service submitted within 45 days afler issuance of the notice of docket number as 

required by the Tribunal’s service rules. 

/s/ Joan Kleiner 

Joan Kleiner 

July 13, 2026

Page 3

101 West Big Beaver Road 

Suite 945 

Ryan )) 

Troy, Michigan 48084 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

R €Ceiveq 

JL 15 ggg 

LAR

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 

 

IIP-MI 4 LLC, 

Petitioner(s) 

v 

City of Warren, 

Respondent(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. Property Parcel No: 12-13-35-301-011 

2. The property identified above is ☑ real ☐ personal. 

3. If more than one parcel of real property is under appeal, are the properties 

contiguous? ☐ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.) 

N/A 

4. Are all of the parcels of personal property located on a parcel of real property under 

appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not 

located on a parcel of real property under appeal.) 

N/A 

5. If parcels of personal property are under appeal, when were the personal property statements filed by 

parcel number (attach additional page if necessary): 

N/A 

6. The property identified above is classified as 301 Industrial-Improved 

7. If the assessment or assessments at issue were protested, the protest was made to 

Respondent’s ☐ March ☐ July ☐ December Board of Review. 

No protest to the Board of Review was required. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

Page 2

MTT Docket No. ____________________ 

Page 2 of 4 

8. If a protest was required and no protest was made, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach 

additional page if necessary): 

N/A 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or 

classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate 

and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

N/A 

10. The property or properties at issue are located in Macomb County. The property’s address is: 

21590 Hoover Rd, Warren, MI 48089 

11. The assessment or assessments at issue were established by the (applicable local governmental unit): 

City of Warren 

12. Petitioner’s legal residence or principal office address is: 

11440 WEST BERNARDO CT , STE 100 , SAN DIEGO, CA 92127 

13. This appeal involves issues relating to the (check all that are applicable): 

☑ the property or properties’ true cash and taxable values 

☐ the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or 

loss? ☐ Yes ☐ No 

☐ uniformity of the property or properties’ assessment 

☐ the property or the properties’ exemption from ad valorem taxation under MCL ______ 

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

Page 3

MTT Docket No. ____________________ 

Page 3 of 4 

15. If more than the current tax year is being appealed, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page 

if necessary): 

N/A 

16. The values for the property identified above as established by Respondent’s Board of Review are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$13,713,420 

$6,856,710 

$6,266,217 

17. Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$9,100,000 

$4,550,000 

$4,550,000 

18. The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$4,613,420 

$2,306,710 

$1,716,217 

19. Petitioner requests the following relief (attach additional page if necessary): 

Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026 

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set 

forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess 

of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just 

and equitable. 

20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach 

additional page if necessary): 

A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash 

value in violation of the applicable statutory and constitutional limitations. 

B. The assessment is based on improper or inaccurate valuation methodology, including but not 

limited to the use of non-representative data, failure to account for relevant property characteristics, 

and/or application of incorrect assumptions. As a result, the assessment is not uniform with 

comparable properties and results in an excessive and unlawful tax burden.

Page 4

MTT Docket No. ____________________ 

Page 4 of 4 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Sarah R. Belloli 

Email Address: 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

Mailing Address: 

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Telephone Number: 

(313) 230-0104 

Date: 

2026-05-25

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

IIP-MI 4 LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

Ryan LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.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]

21590 Hoover Rd

Warren

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48089

Taxing Authority (City or Township)

City Of Warren (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:

12-13-35-301-011

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:

6856710

Current Taxable Value as established by the Board of Review:

6266217

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

9100000

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

4550000

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

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Sarah R. Belloli

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052586819687

Supporting Waiver Documents:

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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

IIP-MI 4 LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001376

City Of Warren, 

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 6, 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

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND 

REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

IIP-MI 4 LLC, 

Petitioner(s) 

v 

City of Warren, 

Respondent(s) 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. Property Parcel No: 12-13-35-301-011 

2. The property identified above is ☑ real ☐ personal. 

3. If more than one parcel of real property is under appeal, are the properties 

contiguous? ☐ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.) 

N/A 

4. Are all of the parcels of personal property located on a parcel of real property under 

appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not 

located on a parcel of real property under appeal.) 

N/A 

5. If parcels of personal property are under appeal, when were the personal property statements filed by 

parcel number (attach additional page if necessary): 

N/A 

6. The property identified above is classified as 301 Industrial-Improved 

7. If the assessment or assessments at issue were protested, the protest was made to 

Respondent’s ☐ March ☐ July ☐ December Board of Review. 

No protest to the Board of Review was required. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

Page 2

MTT Docket No. ____________________ 

Page 2 of 4 

8. If a protest was required and no protest was made, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach 

additional page if necessary): 

N/A 

9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or 

classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate 

and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

N/A 

10. The property or properties at issue are located in Macomb County. The property’s address is: 

21590 Hoover Rd, Warren, MI 48089 

11. The assessment or assessments at issue were established by the (applicable local governmental unit): 

City of Warren 

12. Petitioner’s legal residence or principal office address is: 

11440 WEST BERNARDO CT , STE 100 , SAN DIEGO, CA 92127 

13. This appeal involves issues relating to the (check all that are applicable): 

☑ the property or properties’ true cash and taxable values 

☐ the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or 

loss? ☐ Yes ☐ No 

☐ uniformity of the property or properties’ assessment 

☐ the property or the properties’ exemption from ad valorem taxation under MCL ______ 

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

Page 3

MTT Docket No. ____________________ 

Page 3 of 4 

15. If more than the current tax year is being appealed, list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page 

if necessary): 

N/A 

16. The values for the property identified above as established by Respondent’s Board of Review are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$13,713,420 

$6,856,710 

$6,266,217 

17. Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$9,100,000 

$4,550,000 

$4,550,000 

18. The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$4,613,420 

$2,306,710 

$1,716,217 

19. Petitioner requests the following relief (attach additional page if necessary): 

Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026 

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set 

forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess 

of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just 

and equitable. 

20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach 

additional page if necessary): 

A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash 

value in violation of the applicable statutory and constitutional limitations. 

B. The assessment is based on improper or inaccurate valuation methodology, including but not 

limited to the use of non-representative data, failure to account for relevant property characteristics, 

and/or application of incorrect assumptions. As a result, the assessment is not uniform with 

comparable properties and results in an excessive and unlawful tax burden.

Page 4

MTT Docket No. ____________________ 

Page 4 of 4 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

/s/ Sarah R. Belloli 

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: 

Sarah R. Belloli 

Email Address: 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

Mailing Address: 

101 West Big Beaver, Suite 945 

Troy, Michigan 48084 

Telephone Number: 

(313) 230-0104 

Date: 

2026-05-25

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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

IIP-MI 4 LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Sarah

M.I.

Last Name

Belloli

Firm Name (if any)

Ryan LLC

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

101 W. Big Beaver

Suite 945

City or Town

Troy

State

Michigan

ZIP Code

48048

Telephone Number

3132300104

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

sarah.belloli@ryan.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]

21590 Hoover Rd

Warren

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48089

Taxing Authority (City or Township)

City Of Warren (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:

12-13-35-301-011

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:

6856710

Current Taxable Value as established by the Board of Review:

6266217

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

9100000

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

4550000

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

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Sarah R. Belloli

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052586819687

Supporting Waiver Documents:

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