Jamie Blumenthal, Petitioner V City Of Southfield, Respondent

Page 1

Yr) 

City of Sotiglifiald 

26000 Evergreen Rd. 

+ P.O. Box 2055 

» Southfield, MI 48037-2055 

» www.cilyolsouthfield.com 

November 25, 2025 

Ms. Samantha M. Welton, Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, Michigan 48909 

RE: 

JAMIE BLUMENTHAL 

Docket No.: 

 25-003352 

Parcel No(s): 

76-24-25-206-004 

Dear Ms. Welton: 

Enclosed for filing please find Respondent's Motion to Dismiss Petitioner's Petition for the above 

referenced docket number and parcel located 

in the City of Southfield, with Proof of Service 

thereon. 

Thank you for your kind attention. 

If you should have any questions or concerns, please feel free 

to contact me. 

Sincerely, 

—- 

Justin E. Prybylski, MMAO(4), PPE 

City Assessor 

City of Southfield 

Enclosures 

cc: 

Stephen Polter, Representative for Petitioner 

Jamie Blumenthal, Petitioner

Page 2

MTT Docket No. 25-003352 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLUMENTHAL, JAMIE, 

Petitioner, 

V. 

MTT Docket No.: 25-003352 

Parcel No(s): 76-24-25-206-004 

CITY OF SOUTHFIELD, 

Respondent 

& 

Stephen Polter 

Justin E. Prybylski, MMAO(4) 

Attorney for Petitioner 

City Assessor 

Polter Law Group — EPTA 

City of Southfield 

2600 W Big Beaver, Suite L100 

26000 Evergreen Rd. 

Troy, IN 

48084 

Southfield, MI 

48076 

spolter@polterlaw.com 

iprybylski@ecityofsouthfield.com 

(248) 

213-6800 

(248) 

796-5240 

MOTION TO DISMISS PETITIONER’S PETITION 

NOW COMES Respondent, CITY OF SOUTHFIELD, by and through 

its Representative, and for its 

Motion to Dismiss Petitioner’s Petition, states as follows: 

1. 

Petitioner’s Petition, with Proof of Service, is dated and postmarked July 14, 2025. 

2. 

Respondent did timely mail form L-4400, “Notice of Assessment, Taxable Valuation and Property 

Classification”, to Petitioner within the required time-period, 14 days prior to the March Board of 

Review, pursuant to MCL 211.24¢(4), on February 14, 2025, using the mailing address provided 

by Petitioner. 

3. 

A petition was filed with the City of Southfield’s March Board of Review on March 7, 2025. This

Page 3

MTT Docket No. 25-003352 

6. 

Since the property owner’s petition with the March Board of Review did not contain identifying 

characteristics in addition to the parcel code, and was a letter appeal without personal appearance, 

petitioner’s actual property was not appealed to the March Board of Review due to petitioner’s 

error in transposition of the parcel number on form 618, L-4035, “Petition to Board of Review”. 

7. 

Petitioner’s property is classified 401 — Residential Improved and is required to appeal to the local 

March Board of Review, in accordance with MCL 205.73 

5a of the Tax Tribunal Act. 

8. 

Therefore, Petitioner failed to appeal their property’s assessed value to the March Board of Review, 

in accordance with MCL 205.735a(3) of the Tax Tribunal Act, Act 186 of 1973. 

WHEREFORE, Respondent respectfully requests that this honorable Tribunal affirm 

this Motion to 

Dismiss Petitioners Petition and Dismiss the Petition with prejudice. 

Dated: November 25, 2025 

Respectfully submitted, 

Ld 

Justin E. Prybyiski, M.A.A.0.(3) 

City Assessor || City of Southfield 

26000 Evergreen Rd 

Southfield, MI 48076 

0: (248) 796-5240 

F: (248) 796-5255 

iprybylski@ecityofsouthfield.com

Page 4

MTT Docket No. 25-003352 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLUMENTHAL, JAMIE, 

Petitioner, 

Vv. 

MTT Docket No.: 25-003352 

Parcel No(s): 76-24-25-206-004 

CITY OF SOUTHFIELD, 

Respondent 

Proof of Service 

Justin E. Prybylski, MMAO(4), Assessor for the City of Southfield, certifies that on Tuesday, 

November 25, 2025, copies of Respondent’s Motion to Dismiss Petitioners Petition were served 

to: 

Jamie Blumenthal 

15977 Addison St 

Southfield, MI 

48075 

And 

Stephen Polter 

Polter Law Group — EPTA 

2600 W Big Beaver, Suite L100 

Troy, MI 

48084 

By certified mail and 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 

48909 

By e-file and first-class mail through placing said document in envelopes addressed to the above 

parties with postage fully prepaid, and by depositing said envelopes in a receptacle for United 

States Mail. 

le 

Justin'E Prybylski, MMAO(4)

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 

Jamie Blumenthal, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 25-003352 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER VACATING NOVEMBER 14, 2025 ORDER HOLDING RESPONDENT IN 

DEFAULT 

 

ORDER GRANTING RESPONDENT’S MOTION TO DISMISS 

 

On November 25, 2025, Respondent filed a motion requesting that the Tribunal dismiss 

the appeal in the above-captioned case. In the motion, Respondent states that its 

March Board of Review (BOR) was not able to consider the appeal because it contained 

the wrong parcel number (Parcel No. 76-24-25-203-004) and because neither Petitioner 

nor an authorized representative appeared at the BOR. 

 

On December 2, 2025, Petitioner filed a response indicating that the Tribunal has 

authority under its rules to allow an amended petition. Petitioner contends that the 

correct parcel number is 76-24-25-206-004. Petitioner further contends that 

Respondent is not prejudiced and is inappropriately seeking dismissal where it is not 

warranted. 

 

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

has no authority over Petitioner’s appeal. A protest to the March BOR is a prerequisite 

to invoking the Tribunal’s jurisdiction over residential properties under MCL 205.735a. 

While a protest was filed with the March BOR in regard to Parcel No. 76-24-25-203-004, 

Respondent was unable to consider the protest and issue a final decision. The petition 

filed in this matter indicates that Petitioner is appealing the state equalized and taxable 

values for that same parcel of property, and the petition further indicates that the 

property is classified as residential. Petitioner contends that the Tribunal has the power 

to order an amended petition to correct the parcel number. However, the Tribunal only 

has such power in matters in which it has jurisdiction.1 In this case, the March BOR did 

not issue a decision relative to either parcel and as such, the Tribunal lacks jurisdiction 

to hear Petitioner’s appeal. 

 

Petitioner also contends that the BOR should have considered the petition despite the 

typographical error. The Michigan Supreme Court recently reaffirmed that the Tribunal 

lacks any equitable authority to assume jurisdiction in cases presenting potential due-

 

1 MCL 205.732(c).

Page 2

MTT Docket No. 25-003352 

Page 2 of 3 

 

process violations when the statutory requirements for filing an appeal under MCL 

205.735a have not been met and that jurisdiction in such cases may only be vested 

upon the Tribunal by a judicial body with powers of equity.2 

 

As such, and because the Tribunal has no equitable power to disregard a statutory filing 

prerequisite,3 it has no authority to grant Petitioner the relief requested. Further, and as 

a result of the foregoing, Respondent’s default shall be vacated. 

 

Therefore, 

 

IT IS ORDERED that the November 14, 2025 Order Holding Respondent in Default is 

VACATED. 

 

IT IS FURTHER ORDERED that Respondent’s Motion to Dismiss is GRANTED. 

 

This order resolves all pending claims in this matter and closes this case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the

Page 3

MTT

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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

Jamie Blumenthal,

Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

v

 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

ORDER OF DEFAULT

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

Respondent failed to identify the proper parcel number(s) of the property or properties 

at issue. Respondent must file an amended answer identifying the correct parcel 

number(s) within 14 days of the entry of this order.

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.i 

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:_______________________________

Entered: November 14, 2025

Patricia L. Halm, Tribunal Chair

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

i “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

Page 2

MTT Docket No. 25-003352

Page 2 of 6

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 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

Jamie Blumenthal,

Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

v

 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

ORDER OF DEFAULT

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

Respondent failed to identify the proper parcel number(s) of the property or properties 

at issue. Respondent must file an amended answer identifying the correct parcel 

number(s) within 14 days of the entry of this order.

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.ii 

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:_______________________________

Entered: November 14, 2025

Patricia L. Halm, Tribunal Chair

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

ii “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

Page 4

MTT

Page 5

STAT

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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 

Jamie Blumenthal, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, SMALL CLAIMS DIVISION 

 

v 

 

MTT Docket No. 25-003352 

 

City of Southfield, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER VACATING NOVEMBER 14, 2025 ORDER HOLDING RESPONDENT IN 

DEFAULT 

 

ORDER GRANTING RESPONDENT’S MOTION TO DISMISS 

 

On November 25, 2025, Respondent filed a motion requesting that the Tribunal dismiss 

the appeal in the above-captioned case. In the motion, Respondent states that its 

March Board of Review (BOR) was not able to consider the appeal because it contained 

the wrong parcel number (Parcel No. 76-24-25-203-004) and because neither Petitioner 

nor an authorized representative appeared at the BOR. 

 

On December 2, 2025, Petitioner filed a response indicating that the Tribunal has 

authority under its rules to allow an amended petition. Petitioner contends that the 

correct parcel number is 76-24-25-206-004. Petitioner further contends that 

Respondent is not prejudiced and is inappropriately seeking dismissal where it is not 

warranted. 

 

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

has no authority over Petitioner’s appeal. A protest to the March BOR is a prerequisite 

to invoking the Tribunal’s jurisdiction over residential properties under MCL 205.735a. 

While a protest was filed with the March BOR in regard to Parcel No. 76-24-25-203-004, 

Respondent was unable to consider the protest and issue a final decision. The petition 

filed in this matter indicates that Petitioner is appealing the state equalized and taxable 

values for that same parcel of property, and the petition further indicates that the 

property is classified as residential. Petitioner contends that the Tribunal has the power 

to order an amended petition to correct the parcel number. However, the Tribunal only 

has such power in matters in which it has jurisdiction.1 In this case, the March BOR did 

not issue a decision relative to either parcel and as such, the Tribunal lacks jurisdiction 

to hear Petitioner’s appeal. 

 

Petitioner also contends that the BOR should have considered the petition despite the 

typographical error. The Michigan Supreme Court recently reaffirmed that the Tribunal 

lacks any equitable authority to assume jurisdiction in cases presenting potential due-

 

1 MCL 205.732(c).

Page 2

MTT Docket No. 25-003352 

Page 2 of 3 

 

process violations when the statutory requirements for filing an appeal under MCL 

205.735a have not been met and that jurisdiction in such cases may only be vested 

upon the Tribunal by a judicial body with powers of equity.2 

 

As such, and because the Tribunal has no equitable power to disregard a statutory filing 

prerequisite,3 it has no authority to grant Petitioner the relief requested. Further, and as 

a result of the foregoing, Respondent’s default shall be vacated. 

 

Therefore, 

 

IT IS ORDERED that the November 14, 2025 Order Holding Respondent in Default is 

VACATED. 

 

IT IS FURTHER ORDERED that Respondent’s Motion to Dismiss is GRANTED. 

 

This order resolves all pending claims in this matter and closes this case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the

Page 3

MTT

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Page 1

BE 

RECEIVED 

DEC 04 2025 

STATE OF MICHIGAN "mH 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

Jamie Blumenthal 

Petitioner, 

MTT Docket No.: 25-003352 

Parcel No.: 76-24-25-206-004 (Correct Parcel) 

Vs. 

City of Southfield, 

Respondent. 

Stephen Polter 

Justin Prybylski 

Polter Law Group 

Assessor, Southfield 

2600 W Big Beaver, Ste L100 

26000 Evergreen Rd. 

Troy, MI 48084 

Southfield, MI 48076 

248-213-6800 

248-796-5240 

Spolter@polterlaw.com 

iprybylski@cityofsouthfield.com 

PETITIONER’S RESPONSE IN OPPOSITION TO RESPONDENT’S MOTION TO DISMISS 

Petitioner, Jamie Blumenthal, through counsel, submits this Response opposing Respondent City 

of Southfield’s Motion to Dismiss. Respondent seeks dismissal solely on the basis that 

Petitioner’s original Small Claims petition referenced an incorrect parcel identification number 

differing by one digit from the correct parcel number. For the reasons set forth below, 

Respondent’s Motion should be denied, and this matter should proceed on the merits. 

I. INTRODUCTION 

Respondent’s Motion to Dismiss rests entirely on a minor clerical error in the Parcel 

Identification Number listed in Petitioner’s original filing. The correct parcel number is 76-24- 

25-206-604, but the petition inadvertently listed 76-24-25-203-004. This error was purely

Page 2

IL STATEMENT OF FACTS 

1. 

Petitioner timely filed a Small Claims petition challenging the assessment for the tax year 

at issue, as even Respondent, in its motion, concedes. 

2. 

The petition clearly identified Petitioner by name and stated the basis for the assessment 

dispute. 

3. 

Due to an inadvertent clerical mistake, the Parcel Identification Number was listed as 76- 

24-25-203-004 instead of 76-24-25-206-004, differing by only one digit. 

4. 

The City of Southfield was fully aware of the property owned by Petitioner and the 

subject of the assessment challenge, as the Petitioner owns only one parcel within the city 

under their name. 

5. 

Respondent has alleged no prejudice, confusion, or inability to identify the correct 

parcel. 

6. 

Respondent moves for dismissal solely based on this single-digit error in the P.LN, 

II. ARGUMENT 

A. The Petition Substantially Complied with MTT Filing Requirements 

Michigan jurisprudence distinguishes between “mandatory” requirements and “directory” or 

procedural requirements. Minor clerical defects—particularly those not affecting substantive 

rights—do not deprive the Tribunal of jurisdiction. 

The Tribunal has repeatedly recognized that substantial compliance is sufficient where the 

petition clearly identifies the taxpayer, the nature of the appeal, and the intended property. A 

one-digit error in the parcel number does not defeat substantial compliance, particularly where 

Respondent had no difficulty identifying the Petitioner or the nature of the appeal. 

B. The Tribunal Has Authority to Allow Amendments and Correct Non-Jurisdictional Defects 

Under the Tribunal’s Rules of Practice (including MTTR 215 for Small Claims matters), the 

Tribunal may accept amendments that correct clerical or technical defects. Such authority 

routinely applies to: 

+ 

Incorrect parcel numbers

Page 3

Petitioner respectfully requests that the Tribunal accept the corrected parcel number 76-24-25- 

- 206-004 as an amendment nunc pro tunc. 

C. Respondent Suffered No Prejudice and Had Actual Notice of the Appeal 

Dismissal is inappropriate when: 

1. 

Respondent was not misled, 

2. 

Respondent could easily determine the subject property, and 

3. 

No prejudice resulted. 

All three conditions are met here: 

+ 

Petitioner owns only one residential property in Southfield with this parcel number. 

«The City’s assessor’s office could immediately identify the correct parcel associated with 

Petitioner’s name. 

« 

Respondent articulates no harm, confusion, or inability to prepare its defense. 

Case law and Tribunal practice both support the principle that actual notice cures technical 

defects. 

D. Dismissal Would Result in an Unjust Forfeiture of Petitioner's Statutory Right to Appeal 

Michigan law strongly favors allowing taxpayers to have their assessments heard on the merits. 

Dismissing an appeal due to an immaterial clerical defect would produce an inequitable outcome 

inconsistent with the intent of the property tax appeal process. 

The Tribunal, sitting in equity, should avoid a result that denies Petitioner access to review 

merely because of a harmless typographical error. 

IV. CONCLUSION 

For the foregoing reasons, Petitioner respectfully requests that the Tribunal: 

1. DENY Respondent’s Motion to Dismiss; 

2. 

Accept the corrected

Page 4

g

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Page 1

Yr) 

City of Sotiglifiald 

26000 Evergreen Rd. 

+ P.O. Box 2055 

» Southfield, MI 48037-2055 

» www.cilyolsouthfield.com 

November 25, 2025 

Ms. Samantha M. Welton, Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, Michigan 48909 

RE: 

JAMIE BLUMENTHAL 

Docket No.: 

 25-003352 

Parcel No(s): 

76-24-25-206-004 

Dear Ms. Welton: 

Enclosed for filing please find Respondent's Motion to Dismiss Petitioner's Petition for the above 

referenced docket number and parcel located 

in the City of Southfield, with Proof of Service 

thereon. 

Thank you for your kind attention. 

If you should have any questions or concerns, please feel free 

to contact me. 

Sincerely, 

—- 

Justin E. Prybylski, MMAO(4), PPE 

City Assessor 

City of Southfield 

Enclosures 

cc: 

Stephen Polter, Representative for Petitioner 

Jamie Blumenthal, Petitioner

Page 2

MTT Docket No. 25-003352 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLUMENTHAL, JAMIE, 

Petitioner, 

V. 

MTT Docket No.: 25-003352 

Parcel No(s): 76-24-25-206-004 

CITY OF SOUTHFIELD, 

Respondent 

& 

Stephen Polter 

Justin E. Prybylski, MMAO(4) 

Attorney for Petitioner 

City Assessor 

Polter Law Group — EPTA 

City of Southfield 

2600 W Big Beaver, Suite L100 

26000 Evergreen Rd. 

Troy, IN 

48084 

Southfield, MI 

48076 

spolter@polterlaw.com 

iprybylski@ecityofsouthfield.com 

(248) 

213-6800 

(248) 

796-5240 

MOTION TO DISMISS PETITIONER’S PETITION 

NOW COMES Respondent, CITY OF SOUTHFIELD, by and through 

its Representative, and for its 

Motion to Dismiss Petitioner’s Petition, states as follows: 

1. 

Petitioner’s Petition, with Proof of Service, is dated and postmarked July 14, 2025. 

2. 

Respondent did timely mail form L-4400, “Notice of Assessment, Taxable Valuation and Property 

Classification”, to Petitioner within the required time-period, 14 days prior to the March Board of 

Review, pursuant to MCL 211.24¢(4), on February 14, 2025, using the mailing address provided 

by Petitioner. 

3. 

A petition was filed with the City of Southfield’s March Board of Review on March 7, 2025. This

Page 3

MTT Docket No. 25-003352 

6. 

Since the property owner’s petition with the March Board of Review did not contain identifying 

characteristics in addition to the parcel code, and was a letter appeal without personal appearance, 

petitioner’s actual property was not appealed to the March Board of Review due to petitioner’s 

error in transposition of the parcel number on form 618, L-4035, “Petition to Board of Review”. 

7. 

Petitioner’s property is classified 401 — Residential Improved and is required to appeal to the local 

March Board of Review, in accordance with MCL 205.73 

5a of the Tax Tribunal Act. 

8. 

Therefore, Petitioner failed to appeal their property’s assessed value to the March Board of Review, 

in accordance with MCL 205.735a(3) of the Tax Tribunal Act, Act 186 of 1973. 

WHEREFORE, Respondent respectfully requests that this honorable Tribunal affirm 

this Motion to 

Dismiss Petitioners Petition and Dismiss the Petition with prejudice. 

Dated: November 25, 2025 

Respectfully submitted, 

Ld 

Justin E. Prybyiski, M.A.A.0.(3) 

City Assessor || City of Southfield 

26000 Evergreen Rd 

Southfield, MI 48076 

0: (248) 796-5240 

F: (248) 796-5255 

iprybylski@ecityofsouthfield.com

Page 4

MTT Docket No. 25-003352 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLUMENTHAL, JAMIE, 

Petitioner, 

Vv. 

MTT Docket No.: 25-003352 

Parcel No(s): 76-24-25-206-004 

CITY OF SOUTHFIELD, 

Respondent 

Proof of Service 

Justin E. Prybylski, MMAO(4), Assessor for the City of Southfield, certifies that on Tuesday, 

November 25, 2025, copies of Respondent’s Motion to Dismiss Petitioners Petition were served 

to: 

Jamie Blumenthal 

15977 Addison St 

Southfield, MI 

48075 

And 

Stephen Polter 

Polter Law Group — EPTA 

2600 W Big Beaver, Suite L100 

Troy, MI 

48084 

By certified mail and 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 

48909 

By e-file and first-class mail through placing said document in envelopes addressed to the above 

parties with postage fully prepaid, and by depositing said envelopes in a receptacle for United 

States Mail. 

le 

Justin'E Prybylski, MMAO(4)

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

Jamie Blumenthal,

Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

v

 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

ORDER OF DEFAULT

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

Respondent failed to identify the proper parcel number(s) of the property or properties 

at issue. Respondent must file an amended answer identifying the correct parcel 

number(s) within 14 days of the entry of this order.

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.i 

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:_______________________________

Entered: November 14, 2025

Patricia L. Halm, Tribunal Chair

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

i “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

Page 2

MTT Docket No. 25-003352

Page 2 of 6

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 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

Jamie Blumenthal,

Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

v

 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

ORDER OF DEFAULT

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

Respondent failed to identify the proper parcel number(s) of the property or properties 

at issue. Respondent must file an amended answer identifying the correct parcel 

number(s) within 14 days of the entry of this order.

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.ii 

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:_______________________________

Entered: November 14, 2025

Patricia L. Halm, Tribunal Chair

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

ii “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

Page 4

MTT

Page 5

STAT

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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

Jamie Blumenthal,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Users who file documents with the Michigan Tax Tribunal are advised that filed 

documents are public records and will appear for public viewing on the Tax 

Docket Lookup. Users who file documents are responsible for ensuring sensitive or 

personal identifying information is withheld or redacted. See TTR 209. If a user wishes 

to file a document for consideration by the Michigan Tax Tribunal and prevent its 

publication on the Tax Docket Lookup, the user MUST file a Motion for Protective Order 

under MCR 2.302(C)(8). If a Protective Order is issued, documents covered by the 

Order will not be published. Documents filed prior to the issuance of a Protective Order 

will be published.

The responsibility for excluding or redacting personal identifying information (PII) from 

all documents filed with or offered to the Tribunal rests solely with the parties and 

their attorneys. The Tribunal is not responsible for or required to review, redact, or 

screen documents at the time of filing for PII whether filed electronically or on paper. A 

party, representative, or interested person (i.e. third party not part of an appeal) may 

request that the Tribunal redact PII contained in a previously-filed document by

Page 2

MTT Docket No. 25-003352

Page 2 of 6

submitting a Request for Redactions. The Request for Redactions form will be 

available on the Entire Tribunal and Small Claims pages of our website. 

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this 

case through an informal settlement conference. An informal settlement conference 

is a meeting between the parties and/or their representatives to discuss the issues in a 

case in an effort to settle the case. This process may be an alternative to a hearing with 

a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

NOTE: The parties may not request an informal settlement conference to discuss an 

appeal of a principal residence exemption that was denied by either the Michigan 

Department of Treasury or a County. Also, state taxes levied by the Michigan 

Department of Treasury, such as income taxes, are not subject to the informal 

settlement conference process.

MEDIATION: Parties have the option of handling this case through mediation. 

Mediation is a voluntary process where a mediator facilitates communication between 

the parties, assists in identifying issues, and helps explore solutions to promote a 

mutually acceptable settlement. This process may be an alternative to a hearing with a 

judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

If you have any questions, please contact the Tribunal by phone at (517) 335-9760 or 

email

Page 3

STATE OF

Page 4

MTT

Page 5

STATE

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Page 1

City of Southfield 

26000 Evergreen Rd. 

« P.O. Box 2055 

+ Southfield, M1 48037-2055 

» www.cityolsouthficld.com 

October 7, 2025 

Ms. Samantha M. Welton, Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, Michigan 48909 

RE: 

JAMIE BLUMENTHAL 

Docket No.: 

 25-003352 

Parcel No(s): 

76-24-25-206-004 

Dear Ms. Welton: 

Enclosed 

for 

filing 

please 

find Respondent's Answer 

to 

Petitioner's 

Petition 

for the above 

referenced docket number and parcel located 

in the City of Southfield, with Proof of Service 

thereon. 

Thank you for your kind attention. 

If you should have any questions or concerns, please feel free 

to contact me. 

Sincerely, 

Justin E. 

Prybylski, MMAO(4), PPE 

City Assessor 

City of Southfield 

Enclosures 

cc: 

Stephen Polter, Representative for Petitioner 

Jamie Blumenthal, Petitioner

Page 2

MTT Docket No. 25-003352 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLUMENTHAL, JAMIE, 

Petitioner, 

V. 

MTT Docket No.: 25-003352 

Parcel No.: 76-24-25-206-004 

CITY OF SOUTHFIELD, 

Respondent. 

/ 

Proof of Service 

Justin E. Prybylski, MMAO(4), Assessor for the City of Southfield, certifies that on Tuesday, 

October 7, 2025, copies of Respondent’s Answer to Petitioner’s Petition were served to: 

Polter Law Group — EPTA 

c/o Stephen Polter 

2600 W Big Beaver Rd 

Troy, MI 48084 

and 

Jamie Blumenthal 

15977 Addison St 

Southfield, MI 

48075 

and 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 

48909 

By e-file and first-class mail through placing said document in envelopes addressed to the above 

parties with postage fully prepaid, and by depositing said envelopes in a receptacle for United 

States Mail.

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

ORLENE HAWKS

DIRECTOR

PROPERTY TAX APPEAL ANSWER FORM

VALUATION / EXEMPTION / CLASSIFICATION APPEAL

MOAHR DOCKET NO. 25-003352

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government City Of Southfield (OAKLAND)

First Name

M.I.

Last Name/Company Name/Unit of Government

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

E-mail Address

Section 2: Respondent’s Attorney/Authorized Representative’s Contact Information

First Name

Justin

M.I.

E

Last Name

Prybylski

Firm Name (if any)

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

26000 Evergreen Rd.

City or Town

Southfield

State

Michigan

ZIP Code

48076

Telephone Number

248-796-5240

Fax Number

E-mail Address

jprybylski@cityofsouthfield.com

Section 3: Subject Property Information

Does the subject property have a Principal Residence Exemption of 50% or more? 

No

Are the parcels listed by Petitioner contiguous or adjoining? If not, list which parcels adjoin one another.

N/A 

Section 4: Explain Your Answer to this Appeal

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review 

Decision, Notice of Uncapping, or Assessment Change Notice) with this Small Claims Answer, if applicable. If you do not submit this 

document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Respondent denies Petitioner's claims that the property is over assessed as untrue and leaves Petitioner to its strict proofs. 

Petitioner's property is classified as 401 - Residential Improved and is thereby required to be appealed to the March Board of Review prior to the Michigan Tax 

Tribunal having jurisdiction over the appeal. Petitioner erred in properly appealing the property's assessed value to Respondent's March Board of Review 

adjournment in accordance with MCL 205.735a and the appeal should therefore be dismissed with prejudice. 

In addition to this Answer, Respondent has submitted a Motion to Dismiss Petitioner's Petition. 

Section 5: Jurisdictional Issues

IF PETITIONER IS APPEALING THE TRUE CASH AND/OR TAXABLE VALUES

Did Petitioner protest the assessment at a Board of Review (BOR)? No

If yes, check which BOR Petitioner attended: 

If no, was the Notice of Assessment properly sent to Petitioner prior to the March BOR? *Submit a copy of the Notice of Assessment with the Answer.

If the July or December BOR revised the assessment(s) at issue, did it have authority? 

If yes, cite the Board’s authority.

Was the assessment(s) at issue established as the result of a clerical error or mutual mistake of fact? No

If yes, explain.

Is Petitioner appealing from a State Tax Commission Order? 

If so, what is the issue date?

IF PETITIONER IS APPEALING THE UNCAPPING OF TAXABLE VALUE

When was the Notice of Uncapping, if applicable, issued?

Under what statutory section was the Taxable Value uncapped?

IF PETITIONER IS APPEALING THE DENIAL OF A POVERTY EXEMPTION

Did Petitioner request a Poverty Exemption at a BOR? 

If Yes, check which BOR Petitioner attended: 

List the date the BOR denied Petitioner’s Poverty Exemption:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

IF PETITIONER IS APPEALING THE DENIAL OF AN EXEMPTION 

OTHER THAN POVERTY, PRINCIPAL RESIDENCE, OR QUALIFIED AGRICULTURAL EXEMPTIONS

Did Petitioner request the exemption at the BOR? 

If Yes, check which BOR Petitioner attended:

Tax Year(s) denied:

List the date the exemption was denied:

What statutory section did Petitioner request the subject property be exempt?

IF PETITIONER IS APPEALING THE CLASSIFICATION OF PROPERTY

What do you believe the classification should be: 

Section 6: Valuation Information *Use the multiple parcel form for additional, contiguous parcels.

Parcel Identification Number:

76-24-25-206-004

Classification of Property:

Real 

Residential

Current Assessed Value (also known as State Equalized Value) as established by the BOR:

127,050

Current Taxable Value as established by the BOR:

122,276

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

254,100

Multiply the True Cash Value by. 5 and enter here. This is your contention of Assessed Value.

127,050

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

122,276

Electronic

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Page 1

RECEIVED 

JUL 172025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

PROPERTY TAX APPEAL PETITION FORM 

VALUATION / EXEMPTION / CLASSIFICATION APPEAL 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricuitural Exemption, Speciat Assessment, or 

Non-Property tax disputes. 

Pursuant to Michigan Tax Tribunal Rule (TTR) 279, you MUST submit a copy of the notice giving rise to the appeal 

(e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. if you do not 

submit this document, you may be held in default, 

Section 1: Petitioner's Contact Information 

First Name 

M.A. 

Last Name/Company Name 

Biumenthal 

Jamie 

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

15977 Addison St 

City or Town 

State 

ZI? Code 

Sfid 

Mi 

48075 

Telephone Number 

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

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information 

First Name 

M.l. 

Last Name 

Stephen 

Polter 

Firm 

Name 

(if 

any) 

mene ™polter Law Group - EPTA 

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

2600 W Big Beaver, Ste L100 

City or Town 

State 

ZIP Code 

Troy 

= 

= 

Telephone Number 2482136800 

Emall Address (do not enter unless you want MTT to send alf correspondence via email) 

spolter@polterlaw.com 

Section 3: Subject Property Information 

How many 

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

parcelsarayou | ["] vest 

[44 No™ 

appealing? 

*if yes, use a multiple parcel form for Information regarding any contiguous parcels. 

1 

**If no, you must file separate appeals for each non-contiguous or non-adjoining parcel or you will be defaulted.

Page 2

RECEIVED 

JUL 17-2025 

= f2 

i FAN 

MICHIGAN TAX TRIBUNAL 

EXPRESS PROPERTY TAX APPEALS LLC 

A division of Polter Law Group 

July 14, 2025 

SOM — MTT 

POB 30232 

Lansing, MI 48909 

Re: 

Multiple SC 

To whom it may concern, 

Herein enclosed please find five (“5”) filings/cases (three (3) original, two (2) default cures), 

as follows: 

1. 

SC appeal Przygoda v. Birmingham (following MBOR denial /rejection), along 

with fee $125. 

2. 

SC appeal Pecchia v. BH (following MBOR denial/ rejection), along with fee $125. 

3. 

Blumenthal v. Sfld. (following “ostensible” MBOR denial/rejection), along with 

fee $125. 

4. 

Flint v. Anna Maria (24-002182) corrected figures, pursuant to Order of Default 

(enclosed). Cured. 

5. 

SXM LLC, 2D2M LLC (25-002623/2701) corrected severed petition, pursuant to 

Otdet of Default (enclosed). Cured. Tribunal also appears to require Petitioner to 

remit separate $125 payment 

for ostensible separate severed petition/parcel, 

however, 

see 

enclosed proof of original payment(s) 

with 

original 

petition 

submission on or about May 27, 2025. You'll notice that although 

I may have 

erroneously filed as multi contiguous parcel (now corrected), I did not merely remit 

$125 + $25 pursuant to MTT Rules, but rather in fee remittance I treated these as 

two separate submissions and in fact paid 2 x $125. Therefore, the Tribunal’s order 

including the fee requirement should be reconsidered and rendered moot, as the 

at least the fees were originally propertly remitted. 

If, however, Tribunal is 

still 

unconvinced, I would appreciate it stating/noticing along with its basis therefor 

and allowing Petitioner an additional fourteen 

(“14”) 

days within which to 

cure/remit same.

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Section 4: Issues Being Appealed (check 

at that apply) 

True Cash and Taxable Value 

[J Poverty Exemption 

{1 Taxable Value Only (catculation) 

[J Disabled Veterans Exemption 

Uncapping of Taxable Value 

[J 

Eligible Manufacturing Personal Property (ESA) 

[] Exemption from Taxation {other than the denial of a 

[O Classification 

Principal Residence or Qualified Agricultural Exemption) 

Section 5: Explain the Reason for this Appeal 

See attached cover letter to MBOR 

Section 6: Jurisdictional Issues 

Year(s) you are appealing: 

2025 

Did you protest the assessment at a Board of Review (BOR)? 

Yes 

[No 

If Yes, check which BOR you attended AND attach the BOR decision: [#4 March 

[1 yuly 

[J December 

if No, check the applicable reason(s): 

Not required to attend 

Assessment Change Notice was not received by Petitioner

Page 4

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY

Page 5

S

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

Jamie Blumenthal,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: September 9, 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

Jamie Blumenthal,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003352

City Of Southfield,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: September 9, 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

RECEIVED 

JUL 172025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

PROPERTY TAX APPEAL PETITION FORM 

VALUATION / EXEMPTION / CLASSIFICATION APPEAL 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricuitural Exemption, Speciat Assessment, or 

Non-Property tax disputes. 

Pursuant to Michigan Tax Tribunal Rule (TTR) 279, you MUST submit a copy of the notice giving rise to the appeal 

(e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. if you do not 

submit this document, you may be held in default, 

Section 1: Petitioner's Contact Information 

First Name 

M.A. 

Last Name/Company Name 

Biumenthal 

Jamie 

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

15977 Addison St 

City or Town 

State 

ZI? Code 

Sfid 

Mi 

48075 

Telephone Number 

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

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information 

First Name 

M.l. 

Last Name 

Stephen 

Polter 

Firm 

Name 

(if 

any) 

mene ™polter Law Group - EPTA 

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

2600 W Big Beaver, Ste L100 

City or Town 

State 

ZIP Code 

Troy 

= 

= 

Telephone Number 2482136800 

Emall Address (do not enter unless you want MTT to send alf correspondence via email) 

spolter@polterlaw.com 

Section 3: Subject Property Information 

How many 

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

parcelsarayou | ["] vest 

[44 No™ 

appealing? 

*if yes, use a multiple parcel form for Information regarding any contiguous parcels. 

1 

**If no, you must file separate appeals for each non-contiguous or non-adjoining parcel or you will be defaulted.

Page 2

RECEIVED 

JUL 17-2025 

= f2 

i FAN 

MICHIGAN TAX TRIBUNAL 

EXPRESS PROPERTY TAX APPEALS LLC 

A division of Polter Law Group 

July 14, 2025 

SOM — MTT 

POB 30232 

Lansing, MI 48909 

Re: 

Multiple SC 

To whom it may concern, 

Herein enclosed please find five (“5”) filings/cases (three (3) original, two (2) default cures), 

as follows: 

1. 

SC appeal Przygoda v. Birmingham (following MBOR denial /rejection), along 

with fee $125. 

2. 

SC appeal Pecchia v. BH (following MBOR denial/ rejection), along with fee $125. 

3. 

Blumenthal v. Sfld. (following “ostensible” MBOR denial/rejection), along with 

fee $125. 

4. 

Flint v. Anna Maria (24-002182) corrected figures, pursuant to Order of Default 

(enclosed). Cured. 

5. 

SXM LLC, 2D2M LLC (25-002623/2701) corrected severed petition, pursuant to 

Otdet of Default (enclosed). Cured. Tribunal also appears to require Petitioner to 

remit separate $125 payment 

for ostensible separate severed petition/parcel, 

however, 

see 

enclosed proof of original payment(s) 

with 

original 

petition 

submission on or about May 27, 2025. You'll notice that although 

I may have 

erroneously filed as multi contiguous parcel (now corrected), I did not merely remit 

$125 + $25 pursuant to MTT Rules, but rather in fee remittance I treated these as 

two separate submissions and in fact paid 2 x $125. Therefore, the Tribunal’s order 

including the fee requirement should be reconsidered and rendered moot, as the 

at least the fees were originally propertly remitted. 

If, however, Tribunal is 

still 

unconvinced, I would appreciate it stating/noticing along with its basis therefor 

and allowing Petitioner an additional fourteen 

(“14”) 

days within which to 

cure/remit same.

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Section 4: Issues Being Appealed (check 

at that apply) 

True Cash and Taxable Value 

[J Poverty Exemption 

{1 Taxable Value Only (catculation) 

[J Disabled Veterans Exemption 

Uncapping of Taxable Value 

[J 

Eligible Manufacturing Personal Property (ESA) 

[] Exemption from Taxation {other than the denial of a 

[O Classification 

Principal Residence or Qualified Agricultural Exemption) 

Section 5: Explain the Reason for this Appeal 

See attached cover letter to MBOR 

Section 6: Jurisdictional Issues 

Year(s) you are appealing: 

2025 

Did you protest the assessment at a Board of Review (BOR)? 

Yes 

[No 

If Yes, check which BOR you attended AND attach the BOR decision: [#4 March 

[1 yuly 

[J December 

if No, check the applicable reason(s): 

Not required to attend 

Assessment Change Notice was not received by Petitioner

Page 4

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY

Page 5

S

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