Jot II, LLC, Petitioner Vs. City Of Farmington Hills, 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 

JOT II LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001763 

 

City of Farmington Hills, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. 

 

Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001763 

Page 2 of 2 

 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, and (xviii) after June 30, 2025, through December 31, 2025, at the rate of 

8.66%.

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC, and Halsted Farmington, LLC 

Petitioners, 

 

 

 

 

MTT Docket No. 25-001763 

v 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel # 22 23 18 200 008 

City of Farmington Hills, 

 

 

 

 

 

 

 

 

Respondent. 

_____________________________/ 

 

 

 

 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

 

1. The case is pending in the Entire Tribunal. 

 

2. The subject property is in Oakland County. 

 

3. The subject property parcel number is 22 23 18 200 008. 

 

4. The values for the properties identified above as established by Respondent’s Board of 

Review are: 

 

 Tax year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

4,422,660 

2,211,330 

1,952,620 

 

5. The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

 

Tax year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

2,200,000 

1,100,000 

1,100,000 

 

6. If this stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax years 

(attach additional page if necessary): 

 

7. List all reasons (with explanation) why the stipulation’s taxable value does not equal the 

prior year TV multiplied by the applicable inflation rate. (e.g. transfer of ownership, 

additions, losses, omitted property etc . . .)

Page 2

8. List any special terms or conditions being proposed by the parties that would affect the 

execution of this Consent Judgment including, but not limited to, the joint payment of the 

refund, the waiver of interest, etc. (attach additional page if necessary): 

 

Petitioner waives the interest that may otherwise be due on any refund. 

 

Any refund will be made payable to “Halsted Farmington LLC and Peter Ellenson PC” 

and mailed to counsel, Peter Ellenson, 30500 Northwestern Highway, Suite 500, 

Farmington Hills, MI 48334. Petitioner may communicate directly with municipal and 

county treasurers to effectuate this provision. 

 

 

Signature of Petitioner’s Authorized Representative: 

 

 

 /s/ Peter Ellenson 

__________________________________________________________________ 

Printed Name: Peter Ellenson, Petitioner’s Representative 

Date: October 9, 2025 

 

 

 

Signature of Respondent’s Authorized Representative: 

 

 

 

__________________________________________________________________ 

 Printed Name: Debra Walling, Respondent’s Representative 

 Date: 

 

 

 

 

/s/ Debra A. Walling

October 13, 2025

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC, and Halsted Farmington, LLC 

Petitioners, 

 

 

 

 

MTT Docket No. 25-001763 

v 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel # 22 23 18 200 008 

City of Farmington Hills, 

 

 

 

 

 

 

 

 

Respondent. 

_____________________________/ 

 

 

 

 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

AND CONSENT JUDGMENT 

 

1. The case is pending in the Entire Tribunal. 

 

2. The subject property is in Oakland County. 

 

3. The subject property parcel number is 22 23 18 200 008. 

 

4. The values for the properties identified above as established by Respondent’s Board of 

Review are: 

 

 Tax year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

4,422,660 

2,211,330 

1,952,620 

 

5. The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

 

Tax year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

2,200,000 

1,100,000 

1,100,000 

 

6. If this stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax years 

(attach additional page if necessary): 

 

7. List all reasons (with explanation) why the stipulation’s taxable value does not equal the 

prior year TV multiplied by the applicable inflation rate. (e.g. transfer of ownership, 

additions, losses, omitted property etc . . .)

Page 2

8. List any special terms or conditions being proposed by the parties that would affect the 

execution of this Consent Judgment including, but not limited to, the joint payment of the 

refund, the waiver of interest, etc. (attach additional page if necessary): 

 

Petitioner waives the interest that may otherwise be due on any refund. 

 

Any refund will be made payable to “Halsted Farmington LLC and Peter Ellenson PC” 

and mailed to counsel, Peter Ellenson, 30500 Northwestern Highway, Suite 500, 

Farmington Hills, MI 48334. Petitioner may communicate directly with municipal and 

county treasurers to effectuate this provision. 

 

 

Signature of Petitioner’s Authorized Representative: 

 

 

 /s/ Peter Ellenson 

__________________________________________________________________ 

Printed Name: Peter Ellenson, Petitioner’s Representative 

Date: October 9, 2025 

 

 

 

Signature of Respondent’s Authorized Representative: 

 

 

 

__________________________________________________________________ 

 Printed Name: Debra Walling, Respondent’s Representative 

 Date: 

 

 

 

 

/s/ Debra A. Walling

October 13, 2025

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Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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

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

JOT II LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001763 

 

City of Farmington Hills, 

 

Presiding Judge 

Respondent. 

 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION TO JOIN 

 

ORDER UPDATING DOCKET 

 

On September 5, 2025, Petitioner filed a motion requesting that the Tribunal join 

Halsted Farmington, LLC, as a petitioner in this matter. In the motion, Petitioner states 

that Halsted Farmington, LLC purchased the property from Petitioner on June 26, 2025; 

therefore, it is also a party in interest to this appeal. 

 

Respondent has not filed a response to the motion. 

 

The Tribunal has considered the motion and case file and finds that “parties may be 

added or removed by order of the tribunal on its own initiative or on motion of any 

interested person at any stage of the contested case as justice requires.”1 Halsted 

Farmington LLC became the record owner of the property at issue on or about June 26, 

2025, and inasmuch as both Halsted Farmington, LLC and Petitioner are parties in 

interest in this appeal, the Tribunal finds that the motion is proper.2 Therefore, 

 

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

 

IT IS FURTHER ORDERED that the docket shall be updated to reflect Halsted 

Farmington, LLC as Co-Petitioner in this matter. 

 

 

Entered: October 8, 2025 

 

 

By _____________________________ 

sw/jcr 

 

 

 

 

 

1 TTR 229(6). 

2 The Michigan Court of Appeals has held that “a ‘party in interest’ . . . includes persons or entities with a 

property interest in the property being assessed.” Spartan Stores, Inc v City of Grand Rapids, 307 Mich 

App 565, 567 (2014).

Page 2

MTT Docket No. 25-001763 

Page 2 of 2 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC and 

HALSTED FARMINGTON, LLC 

 

Petitioner and Co-Petitioner, 

v 

 

 

 

 

 

 

 

MTT No. 25-001763 

 

 

 

 

 

 

 

 

 

CITY OF FARMINGTON HILLS, 

 

 

 

 

 

Respondent. 

 

 

 

 

Parcel No. 22 23 18 200 008 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

ROSATI, SCHULTZ, JOPPICH & 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

AMTSBUECHLER, P.C. 

Attorney for Petitioner and Co-Petitioner 

 

 

DEBRA WALLING (P37067) 

30500 Northwestern Highway, Suite 500 

 

 

27555 Executive Drive, Suite 250 

Farmington Hills, MI 48334 

 

 

 

Farmington Hills, MI 48331 

248 406 4443 

 

 

 

 

 

(248) 489-4100 

peter@ellensonlaw.com 

 

 

 

 

dwalling@rsjalaw.com 

______________________________________/ 

 

 

MOTION TO ADD CO-PETITIONER 

HALSTED FARMINGTON, LLC 

 

 

NOW COMES Petitioner JOT II, LLC, and proposed Co-Petitioner, HALSTED 

FARMINGTON, LLC, through their attorney, PETER ELLENSON, and states as follows in 

support of this Motion, pursuant to TR 229 and 231: 

1. 

On or about May 29, 2025, Petitioner filed a timely 2025 petition with respect to 

parcel number 22 23 18 200 008, located at 27675 Halsted, Farmington Hills, MI 48331. 

2. 

This Honorable Tribunal assigned docket number 25-001763. 

3. 

On or about June 26, 2025, proposed Co-Petitioner Halsted Farmington, LLC 

purchased the property from Petitioner JOT II, LLC. As such, Halsted Farmington, LLC is an 

interested party to this appeal.

Page 2

4. 

Co-Petitioner’s principal office address is 41100 Plymouth Road, Suite B1-130, 

Plymouth, MI 48170. 

5. 

TTR 229 allows the Tribunal to add a party at any time as justice requires. 

 

 

WHEREFORE, the Petitioner and proposed Co-Petitioner request that this Honorable 

Tribunal add Halsted Farmington, LLC as Co-Petitioner in this appeal. 

 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: August 22, 2025 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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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 

JOT II LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001763 

 

City of Farmington Hills, 

 

Presiding Judge 

Respondent. 

 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION TO JOIN 

 

ORDER UPDATING DOCKET 

 

On September 5, 2025, Petitioner filed a motion requesting that the Tribunal join 

Halsted Farmington, LLC, as a petitioner in this matter. In the motion, Petitioner states 

that Halsted Farmington, LLC purchased the property from Petitioner on June 26, 2025; 

therefore, it is also a party in interest to this appeal. 

 

Respondent has not filed a response to the motion. 

 

The Tribunal has considered the motion and case file and finds that “parties may be 

added or removed by order of the tribunal on its own initiative or on motion of any 

interested person at any stage of the contested case as justice requires.”1 Halsted 

Farmington LLC became the record owner of the property at issue on or about June 26, 

2025, and inasmuch as both Halsted Farmington, LLC and Petitioner are parties in 

interest in this appeal, the Tribunal finds that the motion is proper.2 Therefore, 

 

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

 

IT IS FURTHER ORDERED that the docket shall be updated to reflect Halsted 

Farmington, LLC as Co-Petitioner in this matter. 

 

 

Entered: October 8, 2025 

 

 

By _____________________________ 

sw/jcr 

 

 

 

 

 

1 TTR 229(6). 

2 The Michigan Court of Appeals has held that “a ‘party in interest’ . . . includes persons or entities with a 

property interest in the property being assessed.” Spartan Stores, Inc v City of Grand Rapids, 307 Mich 

App 565, 567 (2014).

Page 2

MTT Docket No. 25-001763 

Page 2 of 2 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

PROOF OF SERVICE 

 

 

___________________________________ states that on ___________________ he/she 

[Name of person serving/mailing petition] 

 

 

[date of service] 

 

served a copy of the ___________________ relative to the above-captioned matter upon: 

 

[Provide name and address of the party/people being served] 

 

________________________________________________ 

 

________________________________________________ 

 

________________________________________________ 

 

________________________________________________ 

 

 

 

 

 

 

 

 

 

 

_________________________________________ 

[Signature of person who is serving/mailing copy] 

 

_________________________________________ 

[Print/type name of person serving/mailing copy] 

 

 

 

 

JOT II, LLC and Halsted Farmington, LLC

25-001763

City of Farmington Hills

Peter Ellenson

9/5/25

Motion to Add Co Petitioner

Debra Walling, attorney for Respondent, by email attachment to:

dwalling@rsjalaw.com

sbodenbach@rsjalaw.com

/s/ Peter Ellenson

Peter Ellenson

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Page 1

Buyer's Final Settlement Statement 

Print Date: 

Halsted Farmington LLC 

41100 Plymouth Road, Suite B1-130, Plymouth, MI 48170 

JOT Ii, LLC 

4858 Willow Lane, Orchard Lake, Mi 48324 

Lake Michigan Credit Union 

P.O. Box 2088, Grand Rapids, MI, 49501 

First American Title Insurance Company 

Et All TH 

300 East Long Lake Road, Suite 300 *Bloomfield Hills, MI 48304 

Office Phone: (248)540-4102 Office Fax:(866)550-1079 

Property Address: 

27675 Halsted Road, 

File No: 

1027130 

Farmington Hills, MI 48331 

Officer: 

Pat Flinchum/KE 

Settlement Date: 

06/26/2025 

Disbursement Date: 

06/26/2025 

06/25/2025, 5:05 PM 

Charge Description 

Buyer Charge 

Buyer Credit 

Consideration: 

Total Consideration 

2,200,000.00 

B 

Deposits in Escrow: 

ry 

GH (——— 

Receipt No. 3121106527 on 05/16/2025 by BCS Property Management LLC 

I 

80,000.00 

Prorations: 

i. 

Pi FR 

TT 

[Sie 

- 

Summer Tax 08/26/25 to 07/01/25 @$81,376.36/yr 

TA 

1,114.74 

er 

Winter Tax_08/26/25 to 12/01/25 @$25,312.314r 

10,957.11 

New Loan(s): 

—_— 

Lender: Lake Michigan Credit Union 

Wi 

Loan Amount 

- Lake Michigan Credit Union 

1,600,000,00 

Membership Deposit to Lake Michigan Credit Union 

5.00 

LMCU Fee 

to Lake Michigan Credit Union 

4,000.00 

Flood 

to Lake Michigan Credit Union 

14.00 

Appraisal/Valuation 

to Lake Michigan Credit Union 

1,862.50 

RE Tax Fee 

lo Lake Michigan Credit Union 

95.00 

Title/Escrow Charges to: 

7 

Recording Processing Fee - Escrow to First American Title Insurance Company 

75.00 

Settlement/Closing Fee 

to First American Title Insurance Company 

1,400.00 

But] 

ALTA Loan Policy 

to First American Tifle Insurance Company 

1,000.00 

[ALTA 25] Same as Survey 

to First American Title Insurance Company 

250.00 

oh 

(ALTA 9] Restrictions, Encroachments, Minerals - Loan Policy 

to First American Title 

500.00 

Insurance Company 

Record Deed 

to Oakland County Register 

of Deeds 

30.00 

Deed Tax Certification 

to Oakland County Treasurer 

5.00 

Record /Courler Fee 

250.00 

to Register of Deeds 

Cash (X From) ( To) Buyer 

541,558.35 

Totals 

2,221,558.35 

2,221,558.35 

Initials: 

Page 1 0f 2 

re

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC and 

HALSTED FARMINGTON, LLC 

 

Petitioner and Co-Petitioner, 

v 

 

 

 

 

 

 

 

MTT No. 25-001763 

 

 

 

 

 

 

 

 

 

CITY OF FARMINGTON HILLS, 

 

 

 

 

 

Respondent. 

 

 

 

 

Parcel No. 22 23 18 200 008 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

ROSATI, SCHULTZ, JOPPICH & 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

AMTSBUECHLER, P.C. 

Attorney for Petitioner and Co-Petitioner 

 

 

DEBRA WALLING (P37067) 

30500 Northwestern Highway, Suite 500 

 

 

27555 Executive Drive, Suite 250 

Farmington Hills, MI 48334 

 

 

 

Farmington Hills, MI 48331 

248 406 4443 

 

 

 

 

 

(248) 489-4100 

peter@ellensonlaw.com 

 

 

 

 

dwalling@rsjalaw.com 

______________________________________/ 

 

 

MOTION TO ADD CO-PETITIONER 

HALSTED FARMINGTON, LLC 

 

 

NOW COMES Petitioner JOT II, LLC, and proposed Co-Petitioner, HALSTED 

FARMINGTON, LLC, through their attorney, PETER ELLENSON, and states as follows in 

support of this Motion, pursuant to TR 229 and 231: 

1. 

On or about May 29, 2025, Petitioner filed a timely 2025 petition with respect to 

parcel number 22 23 18 200 008, located at 27675 Halsted, Farmington Hills, MI 48331. 

2. 

This Honorable Tribunal assigned docket number 25-001763. 

3. 

On or about June 26, 2025, proposed Co-Petitioner Halsted Farmington, LLC 

purchased the property from Petitioner JOT II, LLC. As such, Halsted Farmington, LLC is an 

interested party to this appeal.

Page 2

4. 

Co-Petitioner’s principal office address is 41100 Plymouth Road, Suite B1-130, 

Plymouth, MI 48170. 

5. 

TTR 229 allows the Tribunal to add a party at any time as justice requires. 

 

 

WHEREFORE, the Petitioner and proposed Co-Petitioner request that this Honorable 

Tribunal add Halsted Farmington, LLC as Co-Petitioner in this appeal. 

 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: August 22, 2025 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC, 

 

 

Petitioner, 

 

 

 

 

MTT Docket No. 25-001763 

-vs- 

 

 

 

 

 

 

Parcel No. 22-23-18-200-008 

 

 

 

 

 

 

 

 

CITY OF FARMINGTON HILLS, 

 

 

Respondent. 

 

LAW OFFICE OF PETER ELLENSON, P.C. 

Peter Ellenson (P47383) 

Attorney for Petitioner 

30500 Northwestern Hwy., Ste. 500 

Farmington Hills, MI 48334 

(248) 406-4443 

peter@ellensonlaw.com 

ROSATI, SCHULTZ JOPPICH & 

 AMTSBUECHLER, P.C. 

Debra A. Walling (P37067) 

Attorney for Respondent 

27555 Executive Drive, Suite 250 

Farmington Hills, MI 48331-3554 

(248) 489-4100 

dwalling@rsjalaw.com 

 

RESPONDENT’S ANSWER TO PETITION 

 

NOW COMES Respondent, CITY OF FARMINGTON HILLS, by and through its 

Attorneys, ROSATI SCHULTZ JOPPICH & AMTSBUECHLER PC, and for its Answer to 

Petitioners’ Petition, states as follows: 

1. 

As to Paragraph 1, Respondent neither admits nor denies the allegations contained 

therein, lacking knowledge or information sufficient to form a belief as to the truth of the 

allegations and, therefore, leaves Petitioner to its proofs. 

2. 

As to Paragraph 2, Respondent neither admits nor denies the allegations contained 

therein, lacking knowledge or information sufficient to form a belief as to the truth of the 

allegations and, therefore, leaves Petitioner to its proofs. 

3. 

As to Paragraph 3, Respondent admits the allegations contained therein. 

4. 

As to Paragraph 4, Respondent admits the allegations contained therein 

5. 

As to Paragraph 5, Respondent admits the allegations contained therein.

Page 2

2 

 

6. 

As to Paragraph 6, Respondent neither admits nor denies the allegations contained 

therein, lacking knowledge or information sufficient to form a belief as to the truth of the 

allegations and, therefore, leaves Petitioner to its proofs. 

7. 

As to Paragraph 7, Respondent admits the allegations contained therein. 

8. 

As to Paragraph 8, Respondent admits the allegations contained therein. 

9. 

As to Paragraph 9, Respondent admits the allegations contained therein. 

10. 

As to Paragraph 10, Respondent denies Petitioner’s contentions of value are 

accurate. 

11. 

As to Paragraph 11, Respondent neither admits nor denies the allegations contained 

therein, lacking knowledge or information sufficient to form a belief as to the truth of the 

allegations and, therefore, leaves Petitioner to its proofs. 

12. 

As to Paragraph 12, Respondent denies that Petitioner is entitled to the relief 

requested. 

13. 

As to Paragraph 13, Respondent neither admits nor denies the allegations contained 

therein, lacking knowledge or information sufficient to form a belief as to the truth of the 

allegations and, therefore, leaves Petitioner to its proofs. 

WHEREFORE, Respondent, CITY OF FARMINGTON HILLS, requests the Tribunal 

dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state 

equalization, and award Respondent its costs and attorney fees. 

ROSATI SCHULTZ JOPPICH 

& AMTSBUECHLER, PC 

 

 

 

 

 

 

 

 /s/ Debra A. Walling 

 

 

DEBRA A. WALLING (P37067) 

Attorney for Respondent 

27555 Executive Drive, Suite 250 

Farmington Hills, MI 48331 

(248) 489-4100

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3 

 

AFFIRMATIVE DEFENSES 

 

Respondent CITY OF FARMINGTON HILLS asserts the following affirmative defenses: 

1. 

Petitioner has failed to allege specific and sufficient facts to set forth a cause of 

action against Respondent and to support its claim for relief. 

2. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

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

or its agents. 

3. 

Petitioner has failed to allege that the mode and method of

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001763

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Farmington Hills (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Debra

M.I.

A

Last Name

Walling

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

Fax Number

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

dwalling@rsjalaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Debra A. Walling

/s/

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

le 

: 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 25-001763 

City of Farmington Hills 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Peter Ellenson 

states that on August 11, 2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. 

Assessor (via certified mail): 

Farmington Hills Assessor,31555 W 11 Mile Rd, Farmington Hills, MI 48336 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

Farmington Hills Clerk, 31555 W 11 Mile Rd. Farmington Hills, MI 48336 

3. 

County Equalization Director (via first class mail or personal service): 

Oakland County Equalization Director, 250 Elizabeth Lake Rd # 1000W, Pontiac, MI 48341 

4. 

County Clerk (via first class mail or personal service): 

Oakland County Clerk, 1200 N Telegraph, 

Pontiac. MI 48341 

5. 

Secretary of the local school board (via first class mail or personal service): 

Secretary of the Board of Ed, Farmington Public Schools, 33000 Freedom Rd., Farmington MI 48336 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

/s/ Peter Ellenson 

Peter Ellenson 

[Signature of person who is serving/mailing copy] 

[Print/type name of person serving/mailing copy] 

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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC 

 

Petitioner, 

v 

 

 

 

 

 

 

 

MTT Dkt. No. 

 

 

 

 

 

 

 

 

 

CITY OF FARMINGTON HILLS, 

 

 

 

 

 

Respondent. 

 

 

 

 

Parcel No. 22 23 18 200 008 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

 

Attorney for Petitioner 

 

 

 

 

 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

248 406 4443 

peter@ellensonlaw.com 

______________________________________/ 

 

 

ENTIRE TRIBUNAL TAX PETITION 

 

 

NOW COMES Petitioner, JOT II, LLC, through its attorney, PETER ELLENSON, and 

states as follows in support of this Petition: 

1. 

Petitioner is a party in interest with respect to the property taxes for the following 

parcel number: 22 23 18 200 008, located at 27675 Halsted, Farmington Hills, MI 48331. 

 

2. 

Petitioner’s principal office address is 4858 Willow Lane, Orchard Lake, MI 

48324. 

3. 

Respondent City of Farmington Hills assesses and collects the ad valorem 

property taxes associated with the subject parcel. 

4. 

The subject property is classified as commercial improved (201). 

5. 

The subject property is located in Oakland County. 

6. 

This appeal involves the property’s true cash and taxable values.

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7. 

The tax year at issue is 2025. 

8. 

No Board of Review protest was required or filed for the property. 

9. 

The values for the subject property as established by the Respondent are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

4,422,660 

 

 

2,211,330 

 

 

1,952,620 

 

10. 

Petitioner contends that the values for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

2,000,000 

 

 

1,000,000 

 

 

1,000,000 

 

11. 

The values in dispute for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

2,422,660 

 

 

1,211,330 

 

 

952,620 

 

12. 

Petitioner requests that this Honorable Tribunal order the assessing entity to 

correct its tax rolls to reflect taxable, assessed and state equalized values as indicated above (or 

on the attached supplement) to issue refunds as appropriate, and to pay interest and costs. 

13. 

The basis for the requested relief is that the assessed and taxable values exceed 

50% of the true cash value of the subject property. 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: May 29, 2025 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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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

JOT II, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001763

City Of Farmington Hills, 

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 23, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOT II, LLC 

 

Petitioner, 

v 

 

 

 

 

 

 

 

MTT Dkt. No. 

 

 

 

 

 

 

 

 

 

CITY OF FARMINGTON HILLS, 

 

 

 

 

 

Respondent. 

 

 

 

 

Parcel No. 22 23 18 200 008 

______________________________________/ 

 

 

 

 

 

PETER ELLENSON (P 47383) 

 

 

 

 

LAW OFFICE OF PETER ELLENSON, P.C. 

 

 

Attorney for Petitioner 

 

 

 

 

 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

248 406 4443 

peter@ellensonlaw.com 

______________________________________/ 

 

 

ENTIRE TRIBUNAL TAX PETITION 

 

 

NOW COMES Petitioner, JOT II, LLC, through its attorney, PETER ELLENSON, and 

states as follows in support of this Petition: 

1. 

Petitioner is a party in interest with respect to the property taxes for the following 

parcel number: 22 23 18 200 008, located at 27675 Halsted, Farmington Hills, MI 48331. 

 

2. 

Petitioner’s principal office address is 4858 Willow Lane, Orchard Lake, MI 

48324. 

3. 

Respondent City of Farmington Hills assesses and collects the ad valorem 

property taxes associated with the subject parcel. 

4. 

The subject property is classified as commercial improved (201). 

5. 

The subject property is located in Oakland County. 

6. 

This appeal involves the property’s true cash and taxable values.

Page 2

7. 

The tax year at issue is 2025. 

8. 

No Board of Review protest was required or filed for the property. 

9. 

The values for the subject property as established by the Respondent are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

4,422,660 

 

 

2,211,330 

 

 

1,952,620 

 

10. 

Petitioner contends that the values for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

2,000,000 

 

 

1,000,000 

 

 

1,000,000 

 

11. 

The values in dispute for the subject property are: 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

2,422,660 

 

 

1,211,330 

 

 

952,620 

 

12. 

Petitioner requests that this Honorable Tribunal order the assessing entity to 

correct its tax rolls to reflect taxable, assessed and state equalized values as indicated above (or 

on the attached supplement) to issue refunds as appropriate, and to pay interest and costs. 

13. 

The basis for the requested relief is that the assessed and taxable values exceed 

50% of the true cash value of the subject property. 

 

Respectfully submitted, 

 

/s/ Peter Ellenson 

_______________________________ 

 

Date: May 29, 2025 

PETER ELLENSON (P 47383) 

Attorney for Petitioner 

248 406 4443 

peter@ellensonlaw.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

JOT II, LLC

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

4858 Willow Lane

City or Town

Orchard Lake

State

Michigan

ZIP Code

48324

Telephone Number

2484064443

Fax Number

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

peter@ellensonlaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Peter

M.I.

Last Name

Ellenson

Firm Name (if any)

Peter Ellenson PC

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

30500 Northwestern Hwy

Suite 500

City or Town

Farmington Hills

State

Michigan

ZIP Code

48334

Telephone Number

248-406-4443

Fax Number

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

peter@ellensonlaw.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

27675 Halsted

Farmington Hills

Michigan

48331

Taxing Authority (City or Township)

City Of Farmington Hills (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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

22 23 18 200 008

Classification of Property: Real 

Commercial

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

2211330

Current Taxable Value as established by the Board of Review:

1952620

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

2000000

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

1000000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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

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