Jk Novi LLC Petitioner Vs. City Of Novi Respondent

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

NOTICE OF SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

JK Novi LLC,

Petitioner,

v

 

 

City Of Novi,

Respondent.

 MTT Docket No. 26-001086

Please be advised that 26-001086 has been placed on a two-week Prehearing General 

Call commencing September 16, 2027. Unless ordered otherwise, parties will be 

notified at least 28 days before they are scheduled to appear. Scheduling will not 

necessarily occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

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

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the 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covered by the order will not be published.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.

In accordance with MCR 1.109(D)(9) and TTR 209, 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 submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 26-001086

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by May 20, 2027. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by May 20, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

May 20, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

September 16, 2027, which means all discovery has been requested, all Motions to 

Compel have been filed, and all requested or ordered discovery has been exchanged 

by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s 

valuation disclosure, the opposing party’s valuation expert, and the witnesses identified 

on the opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 16, 2026

Page 3

MTT Docket No. 26-001086

Page 3 of 3

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 provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 4

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

NOTICE OF SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

JK

Page 5

MTT

Page 6

M

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JK NOVI, LLC, 

 

 

Petitioner, 

 

 

MTT Docket No. 26-001086 

v. 

 

CITY OF NOVI, 

 

 

Respondent. 

 

HALLAHAN & ASSOCIATES, P.C. 

LAURA M. HALLAHAN (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

lhallahan@hallahanlaw.com 

ROSATI, SCHULTZ, JOPPICH 

 & AMTSBUECHLER, P.C. 

Jeremy J. Romer (P77287) 

Gopi P. Patel (P77727) 

Attorneys for Respondent 

27555 Executive Drive 

Suite 250 

Farmington Hills, MI 48331-3550 

(248) 489-4100 

jromer@rsjalaw.com 

gpatel@rsjalaw.com 

 

Respondent's Answer to Petition 

 

 

NOW COMES Respondent, City of Novi, by and through its Attorneys, ROSATI, 

SCHULTZ, JOPPICH & AMTSBUECHLER, P.C. and for its Answer to Petitioner's Petition, 

states as follows: 

1. 

As to the allegations contained in Paragraph 1 of the Petition, Respondent 

admits the same. 

2. 

As to the allegations contained in Paragraph 2 of the Petition, no allegation is 

made, so no response is necessary. 

3. 

As to the allegations contained in Paragraph 3 of the Petition, Respondent 

admits the same.

Page 2

2 

 

4. 

As to the allegations contained in Paragraph 4 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

5. 

As to the allegations contained in Paragraph 5 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

6. 

As to the allegations contained in Paragraph 6 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

7. 

As to the allegations contained in Paragraph 7 of the Petition, Respondent 

admits the same. 

8. 

As to the allegations contained in Paragraph 8 of the Petition, Respondent 

admits the same. 

9. 

As to the allegations contained in Paragraph 9 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

10. 

As to the allegations contained in Paragraph 10 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs.

Page 3

3 

 

11. 

As to the allegations contained in Paragraph 11 and its subparts of the 

Petition, Respondent denies the same as untrue. 

12. 

Respondent further states the ratio of the average level of assessment in 

relation to true cash value in the assessment district is 50%, and the equalization factor was 

uniformly applied in the assessment district for the year in question. 

WHEREFORE, Respondent, City of Novi, denies that Petitioner is entitled to the 

relief it seeks and respectfully requests that the Respondent's assessment and taxable value 

of the subject property be affirmed or increased, that Petitioner's Petition be dismissed with 

prejudice and that Respondent be granted costs and attorney fees so wrongfully sustained. 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

ROSATI, SCHULTZ, JOPPICH 

& AMTSBUECHLER, P.C. 

 

 

 

 

 

 

 

/s/ Jeremy J. Romer 

 

 

 

 

 

 

 

 

JEREMY J. ROMER (P77287) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

27555 Executive Drive, Suite 250 

 

 

 

 

 

 

Farmington Hills, MI 48331 

 

 

 

 

 

 

(248) 489-4100 

 

 

 

 

 

 

jromer@rsjalaw.com 

 

Dated: August 19, 2026

Page 4

4 

 

Affirmative Defenses 

 

 

For its further Answer to Petitioner's Petition and by way of its Affirmative Defenses, 

Respondent states as follows and demands an answer from Petitioner as to each: 

 

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. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of 

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

Respondent. 

 

3. 

Petitioner fails to allege that the mode and method of appraising its property 

failed to conform with the mode and method applied in the case of all of the properties in the 

Respondent's taxing unit for the year in question. 

 

4. 

Petitioner fails to allege specific and sufficient facts to establish the true cash 

value, assessed value and taxable value of its property. 

 

5. 

Petitioner fails to allege specific and sufficient facts to support its allegation 

that the assessed value of its property, as equalized, is at a factor other than 50% and also 

fails to allege specific and sufficient facts to support its allegations that the property's taxable 

value is improper. 

 

6. 

Petitioner fails to show that any rate other than 50% after equalization was 

applied to the true cash value of its property, as well as to the properties of all others to arrive 

at the respective equalized assessments. 

 

7. 

Petitioner, in essence, asks that this Honorable Tribunal grant it an illegal 

preference by application of a method of assessment different from that employed in the 

assessment of other properties in the Respondent's taxing unit. 

 

8. 

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

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

Page 5

5 

 

 

9. 

If Petitioner appeared at the Board of Review, Petitioner failed in its 

appearance before the Board of Review to specifically allege: 

A. 

The equalized assessment of the property is more than 50% of its true 

cash value and that the taxable value is in

Page 6

6

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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. 26-001086

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Novi (OAKLAND)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jeremy

M.I.

J

Last Name

Romer

Firm Name (if any)

Rosati, Schultz, Joppich & Amtsbuechler, P.C.

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

27555 Executive Drive

Suite 250

City or Town

Farmington Hills

State

 Michigan

ZIP Code

48331

Telephone Number

248-489-4100

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

jromer@rsjalaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Jeremy J. Romer

/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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

JK Novi LLC, 

 

Petitioner, 

 

vs. 

 

City of Novi, 

Respondent.

 

 

 

MTT Docket No. 26-001086 

 

_____________________________________________________________________________/ 

 

 

PROOF OF SERVICE 

(Property Tax Petition) 

 

On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: 

 

City Assessor 

City of Novi 

45175 W. Ten Mile Rd 

Novi, MI 48375 

City Clerk 

City of Novi 

45175 W. Ten Mile Rd 

Novi, MI 48375 

 

On the date below I sent by first class mail a copy of the Petition to: 

 

Equalization Director 

Oakland County 

250 Elizabeth Lake Rd, Ste 1000W 

Pontiac, MI 48341 

County Clerk 

Oakland County 

1200 N Telegraph Rd, Bldg 12E 

Pontiac, MI 48341 

Secretary, Board of Education 

Novi Community School District 

25345 Taft Rd 

Novi, MI 48374

State Treasurer 

Department of Treasury 

430 W Allegan Street 

Lansing, MI 48922

 

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

 

 

 

/s/ Laura M. Hallahan 

 

Dated: August 14, 2026

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

JK NOVI, LLC, 

Petitioner, 

v 

CITY OF NOVI, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-001086______ 

Parcel No. 50-22-14-301-006 

_____________________________________________________________________________/ 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1.

☒ The property that is the subject of this appeal is one real property parcel:

Parcel Number 

50-22-14-301-006

Address 

43200 Crescent Blvd 

Classification 

201-Commercial

Use 

Retail 

County 

Oakland 

Sch Dist Novi School District 

2.

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s:

☐March, ☐ July, ☐ December Board of Review.

3.

Respondent, identified above, assesses and collects taxes on the subject property.

4.

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject

property.

5.

The Petitioner’s principal office/legal residence address is: 390 Park St., Suite 201,

Birmingham, MI 48009.

6.

This appeal involves issues related to:

☒

the subject property’s true cash and taxable values

☐

the subject property’s taxable value only

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No

☐

uniformity of the subject property’s assessment

☐

the subject property’s exemption from ad valorem taxation under MCL ______

7.

The tax year at issue is 2026.

Page 3

Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

1,956,980 

978,490 

949,290 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

1,400,000 

700,000 

700,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

556,980 

278,490 

249,290 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values 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 assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 4

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 18, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $400

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001086

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: 2026 Petition - POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

JK NOVI, LLC, 

 

Petitioner, 

 

v 

 

CITY OF NOVI, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-_____________ 

Parcel No. 50-22-14-301-006 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. 

☒ The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

50-22-14-301-006 

Address 

43200 Crescent Blvd 

Classification 

201-Commercial 

Use 

Retail 

County 

Oakland 

Sch Dist Novi School District 

 

2. 

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 390 Park St., Suite 201, 

Birmingham, MI 48009. 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ 

uniformity of the subject property’s assessment 

☐ 

the subject property’s exemption from ad valorem taxation under MCL ______ 

7. 

The tax year at issue is 2026.

Page 2

Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

1,956,980 

978,490 

949,290 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

1,400,000 

700,000 

700,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

556,980 

278,490 

249,290 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values 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 assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 18, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $400

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

JK Novi LLC

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

390 Park Street, Suite 201

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2487018529

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

lhallahan@hallahanlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Halahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302-2073

Telephone Number

2487313090

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

lhallahan@hallahanlaw.com

 

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]

43200 Crescent Blvd

Novi

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48375

Taxing Authority (City or Township)

City Of Novi (OAKLAND) 

County

Oakland

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

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

50-22-14-301-006

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:

978490

Current Taxable Value as established by the Board of Review:

949290

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

1400000

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

700000

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

700000

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/ Laura M. Hallahan

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051885992666

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

JK Novi LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001086

City Of Novi, 

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: July 16, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

JK NOVI, LLC, 

 

Petitioner, 

 

v 

 

CITY OF NOVI, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-_____________ 

Parcel No. 50-22-14-301-006 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. 

☒ The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

50-22-14-301-006 

Address 

43200 Crescent Blvd 

Classification 

201-Commercial 

Use 

Retail 

County 

Oakland 

Sch Dist Novi School District 

 

2. 

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: 390 Park St., Suite 201, 

Birmingham, MI 48009. 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ 

uniformity of the subject property’s assessment 

☐ 

the subject property’s exemption from ad valorem taxation under MCL ______ 

7. 

The tax year at issue is 2026.

Page 2

Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

1,956,980 

978,490 

949,290 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

1,400,000 

700,000 

700,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

50-22-14-301-006 

556,980 

278,490 

249,290 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values 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 assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 18, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $400

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

JK Novi LLC

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

390 Park Street, Suite 201

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2487018529

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

lhallahan@hallahanlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Halahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302-2073

Telephone Number

2487313090

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

lhallahan@hallahanlaw.com

 

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]

43200 Crescent Blvd

Novi

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48375

Taxing Authority (City or Township)

City Of Novi (OAKLAND) 

County

Oakland

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

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

50-22-14-301-006

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:

978490

Current Taxable Value as established by the Board of Review:

949290

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

1400000

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

700000

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

700000

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/ Laura M. Hallahan

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051885992666

Supporting Waiver Documents:

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