Jp Th Properties - Warren LLC Petitioner Vs. City Of Warren Respondent
- Petitioner
- Jp Th Properties - Warren LLC
- Respondent
- City Of Warren
Case overview
- Docket number
- 26-001435-TT
- Status
- Answer Due
- CaseType
- ET Property
- Division
- ET
- County
- Macomb
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 5 | Answer was received | RESP | Not recorded | 10/03/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | Not recorded | Not recorded | 08/27/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 08/11/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 08/11/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/26/2026 | $425.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
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STATE OF MICHIGAN DEPARTMNET OF LICENSING & REGULATORY AFAFIRS MICHIGAN TAX TRIBUNAL JP TH PROPERTIES – WARREN LLC, Petitioner, v City of Warren, Respondent. Docket No. 26-001435 _____________________________________________________________________________/ JOSHUA T. SHILLAIR (P72674) COLLIERS INTERNATIONAL Attorney for Petitioner 400 W. 4th Street, Suite 350 Royal Oak, MI 48067 (248) 226-1632 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ ANSWER TO PETITION AND AFFIRMATIVE DEFENSES ANSWER Respondent, City of Warren, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent admits the allegations in Paragraph 1 as to parcel numbers. However, Respondent lacks the information and knowledge necessary to respond to the truth of the remainder of the allegations set forth in Paragraph 1 and therefore leaves Petitioner to its proofs. 2. Respondent admits the allegations in Paragraph 2. 3. Respondent admits the allegations in Paragraph 3.
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Entire Tribunal Property Tax Answer Page 2 of 5 4. Respondent admits that the subject property is classified as commercial real property but lacks the knowledge and information necessary to respond to the remainder of the allegations set forth in Paragraph 4 and, therefore, leaves Petitioner to its proofs. 5. Respondent admits that Petitioner did not protest its assessment to the 2026 Board of Review, but neither admits nor denies the remaining allegations in Paragraph 5 for the reason that the General Property Tax Act speaks for itself. 6. Respondent admits the allegations in Paragraph 6. 7. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies that those issues have merit and further denies Petitioner is entitled to any relief. 8. Respondent acknowledges Petitioner’s belief as to an issue with the 2026 tax year but denies any issue with said year. 9. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 12-13-14-226-025 $331,580 $165,790 $94,412 2026 12-63-14-226-025 $608,760 $304,380 $304,380 10. Respondent denies the allegations in Paragraph 10, including subparagraphs (a) – (d) for the reason that they are untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage for true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 11. Respondent contends that the values for the property identified above are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 12-13-14-226-025 $331,580 $165,790 $94,412 2026 12-63-14-226-025 $608,760 $304,380 $304,380 12. The values in dispute for the property identified above are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 $0 $0 $0 2026 $0 $0 $0 13. Respondent denies the allegations in Paragraph 13 for the reason that they are untrue.
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Entire Tribunal Property Tax Answer Page 3 of 5 14. Respondent acknowledges the relief requested by Petitioner in the final paragraph of its Petition but denies that Petitioner is entitled to said relief for the reasons stated in the preceding paragraphs. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage for true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. WHEREFORE, Respondent, City of Warren, requests the Tribunal dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan___________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 Dated: October 3, 2026 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent, City of Warren, asserts the following affirmative defenses: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. 2. The Tribunal is charged with finding a property’s true cash value to determine the property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 3. Petitioner has the burden of establishing the property’s true cash value. See MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974).
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Entire Tribunal Property Tax Answer Page 4 of 5 4. Petitioner has failed to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles, or illegality on the part of Respondent or its agents. 5. Petitioner has failed to allege that the mode and method of assessing the subject property fails to conform to the mode and method applied in the case of all other properties in Respondent’s taxing unit for the year in question. 6. Petitioner has failed to show that any factor other than fifty percent (50%) was applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the respective
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Entire
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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. 26-001435 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Warren (MACOMB) First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) Section 2: Attorney/Authorized Representative’s Contact Information First Name Laura M.I. 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 Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Laura M. Hallahan /s/
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v Warren Parcel Number: 12-13-14-226-025; 12-63-14-226-025 MTT Docket No.: 26-001435 Page 1 of 2 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL JP TH PROPERTIES - WARREN LLC, Petitioner, v MTT Docket No. 26-001435 WARREN, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Senior Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com City of Warren Assessing Department 1 City Square, Suite 425 Warren, MI 48093 586-574-4557 _____________________________________________________________________________/ PROOF OF SERVICE STATE OF MICHIGAN ) )ss COUNTY OF OAKLAND ) Jennifer Lunsford, states that on 8/27/2026, in compliance with TTR 221, she did place in the US mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number as well as this Proof of Service of Petition for the above captioned appeal to the units of government listed on the second page of this Proof of Service of Petition. /s/Jennifer Lunsford Jennifer Lunsford Karen Cameron states that she submitted electronically on 8/27/2026, to the Michigan Tax Tribunal a copy of this Proof of Service of Petition at eFile through www.etaxappeal.lara.state.mi.us. /s/Karen Cameron Karen Cameron
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v Warren Parcel Number: 12-13-14-226-025; 12-63-14-226-025 MTT Docket No.: 26-001435 Page 2 of 2 By Certified Mail Assessor’s Office City of Warren Assessing Department 1 City Square, Suite 425 Warren, MI 48093 Office of the City/Township Clerk Warren Clerk's Office 1 City Square, Suite 425 Warren, MI 48093 By First Class Mail Director of Equalization Macomb County Equalization Director 120 N Main Street Mt. Clemens, MI 48043 County Clerk’s Office Macomb County Clerk’s Office 40 N Main Street Mt. Clemens, MI 48043 Secretary of the School Board Warren Woods Public Schools 12900 Frazho Road Warren, MI 48089 Treasurer for the State of Michigan Michigan Department of Treasury Lansing, MI 48922
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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: 26-001435 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: POS_JP_TH_PROPERTIES_-_WARREN_LLC_26-001435 Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 1 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL JP TH PROPERTIES - WARREN LLC, Petitioner, v MTT Docket No. City of Warren, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com City of Warren Assessing Office One City Square, Warren, MI 48093 (586) 574-4500 _____________________________________________________________________________/ 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. The Petitioner in this matter, JP TH PROPERTIES - WARREN LLC, has the legal residence or principal office address of 4150 TULLER, SUITE 236,DUBLIN, OH 43017. Petitioner is a party in interest with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject Property) 12-13-14-226-025 , 12-63-14-226-025. If the Subject Property in this petition includes more than one (1) real property tax parcel, the Subject Property’s tax parcels are contiguous. 2. The Subject Property is located in Macomb County.
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 2 of 5 3. Respondent, City of Warren of Macomb County, assesses and collects property taxes on the Subject Property. 4. The Subject Property is real property and is classified as Commercial. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. Protest to the 2026 Board of Review was not made and is not required by law for the Subject Property. 6. The Subject Property’s address is: 28877 SCHOENHERR, WARREN, MI 48088 28877 SCHOENHERR, Warren, MI 48088 7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. 8. The tax year(s) at issue are: 2026 9. The values for the Subject Property as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 12-13-14-226- 025 $331,580.00 $165,790.00 $94,412.00 2026 12-63-14-226- 025 $608,760.00 $304,380.00 $304,380.00 10. The 2026 assessment, assessed value, state equalized value and taxable value imposed upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that:
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 3 of 5 a. The assessment, assessed value, state equalized value and/or taxable value exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law; b. The assessment, assessed value, state equalized value and/or taxable value are at higher percentages of true cash value than permissible under the Michigan Constitution, applicable statutes and case law; c. The assessment, assessed value, state equalized value and/or taxable value are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and d. The assessment, assessed value, state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and denies Petitioner its constitutional rights to uniformity, equal protection and dues process of law. 11. Petitioner contends that the actual values for the Subject Property are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 12-13-14-226- 025 $165,960.00 $82,980.00 $82,980.00 2026 12-63-14-226- 025 $368,800.00 $184,400.00 $184,400.00 12. The amount of value in contention for the Subject Property is: Tax Year Parcel Number Assessed Value in Contention 2026 12-13-14-226-025 $82,810.00 2026 12-63-14-226-025 $119,980.00
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 4 of 5 13. Petitioner relies on the following specific facts to support the relief requested: Market sales and income data indicates that the subject property’s assessed value, state equalized value and taxable value exceed 50% of its actual market value. In addition, the cost less depreciation method Respondent utilizes to establish the Subject Property’s assessment at issue is not related to the Subject Property’s actual market value. WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully Submitted, COLLIERS INTERNATIONAL Representative for Petitioner By:_/s/ Joshua T. Shillair__Dated:05/1/2026 Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal 400 E 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com
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2026 Entire
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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 JP TH PROPERTIES - WARREN LLC Home Address (No., Street, P.O. Box or Rural Route) 4150 TULLER, SUITE 236 City or Town DUBLIN State Ohio ZIP Code 43017 Telephone Number 2482261632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Joshua M.I. Thomas Last Name Shillair Firm Name (if any) Colliers International Address (No., Street, P.O. Box or Rural Route) 400 W 4th Street, Suite 350 City or Town Royal Oak State Michigan ZIP Code 48067 Telephone Number 248-226-1632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 2 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 28877 SCHOENHERR WARREN
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48088 Taxing Authority (City or Township) City Of Warren (MACOMB) County Macomb If you are appealing more than one parcel, are they contiguous or adjoining? (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.) Yes Section 5: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values If “Other”, please explain: Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 12-13-14-226-025 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: 165790 Current Taxable Value as established by the Board of Review: 94412 What do you believe is the fair market value (also known as True Cash Value)? 165960 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 82980 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 12-63-14-226-025 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: 304380 Current Taxable Value as established by the Board of Review:
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 304380 What do you believe is the fair market value (also known as True Cash Value)? 368800 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 184400 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Fee Information The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed. If the State Equalized Value or Taxable Value in contention is: Your filing fee is: $100,000.00 and under $250.00 $100,000.01 to $500,000.00 $400.00 $Over $500,000.00 $600.00 * Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00. 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/ /s/Joshua T. Shillair Payment Information Amount: 425 Success: True Message: "" Waiver Code: Transaction Number: 26052686953528 Supporting Waiver Documents:
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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 JP TH Properties - Warren LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001435 City Of Warren, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: Tribunal Clerk Entered: August 11, 2026 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 JP TH Properties - Warren LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001435 City Of Warren, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: Tribunal Clerk Entered: August 11, 2026 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 1 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL JP TH PROPERTIES - WARREN LLC, Petitioner, v MTT Docket No. City of Warren, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com City of Warren Assessing Office One City Square, Warren, MI 48093 (586) 574-4500 _____________________________________________________________________________/ 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. The Petitioner in this matter, JP TH PROPERTIES - WARREN LLC, has the legal residence or principal office address of 4150 TULLER, SUITE 236,DUBLIN, OH 43017. Petitioner is a party in interest with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject Property) 12-13-14-226-025 , 12-63-14-226-025. If the Subject Property in this petition includes more than one (1) real property tax parcel, the Subject Property’s tax parcels are contiguous. 2. The Subject Property is located in Macomb County.
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 2 of 5 3. Respondent, City of Warren of Macomb County, assesses and collects property taxes on the Subject Property. 4. The Subject Property is real property and is classified as Commercial. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. Protest to the 2026 Board of Review was not made and is not required by law for the Subject Property. 6. The Subject Property’s address is: 28877 SCHOENHERR, WARREN, MI 48088 28877 SCHOENHERR, Warren, MI 48088 7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. 8. The tax year(s) at issue are: 2026 9. The values for the Subject Property as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 12-13-14-226- 025 $331,580.00 $165,790.00 $94,412.00 2026 12-63-14-226- 025 $608,760.00 $304,380.00 $304,380.00 10. The 2026 assessment, assessed value, state equalized value and taxable value imposed upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that:
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 3 of 5 a. The assessment, assessed value, state equalized value and/or taxable value exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law; b. The assessment, assessed value, state equalized value and/or taxable value are at higher percentages of true cash value than permissible under the Michigan Constitution, applicable statutes and case law; c. The assessment, assessed value, state equalized value and/or taxable value are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and d. The assessment, assessed value, state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and denies Petitioner its constitutional rights to uniformity, equal protection and dues process of law. 11. Petitioner contends that the actual values for the Subject Property are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 12-13-14-226- 025 $165,960.00 $82,980.00 $82,980.00 2026 12-63-14-226- 025 $368,800.00 $184,400.00 $184,400.00 12. The amount of value in contention for the Subject Property is: Tax Year Parcel Number Assessed Value in Contention 2026 12-13-14-226-025 $82,810.00 2026 12-63-14-226-025 $119,980.00
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2026 Entire Tribunal Property Tax Petition & Proof of Service JP TH PROPERTIES - WARREN LLC v City of Warren Parcel Number: 12-13-14-226-025 , 12-63-14-226-025 MTT Docket No.: Page 4 of 5 13. Petitioner relies on the following specific facts to support the relief requested: Market sales and income data indicates that the subject property’s assessed value, state equalized value and taxable value exceed 50% of its actual market value. In addition, the cost less depreciation method Respondent utilizes to establish the Subject Property’s assessment at issue is not related to the Subject Property’s actual market value. WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully Submitted, COLLIERS INTERNATIONAL Representative for Petitioner By:_/s/ Joshua T. Shillair__Dated:05/1/2026 Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal 400 E 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com
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2026 Entire
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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 JP TH PROPERTIES - WARREN LLC Home Address (No., Street, P.O. Box or Rural Route) 4150 TULLER, SUITE 236 City or Town DUBLIN State Ohio ZIP Code 43017 Telephone Number 2482261632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Joshua M.I. Thomas Last Name Shillair Firm Name (if any) Colliers International Address (No., Street, P.O. Box or Rural Route) 400 W 4th Street, Suite 350 City or Town Royal Oak State Michigan ZIP Code 48067 Telephone Number 248-226-1632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 2 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 28877 SCHOENHERR WARREN
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48088 Taxing Authority (City or Township) City Of Warren (MACOMB) County Macomb If you are appealing more than one parcel, are they contiguous or adjoining? (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.) Yes Section 5: Check which of the following you are appealing (check all that apply) True Cash and Taxable Values If “Other”, please explain: Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 12-13-14-226-025 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: 165790 Current Taxable Value as established by the Board of Review: 94412 What do you believe is the fair market value (also known as True Cash Value)? 165960 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 82980 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 12-63-14-226-025 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: 304380 Current Taxable Value as established by the Board of Review:
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 304380 What do you believe is the fair market value (also known as True Cash Value)? 368800 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 184400 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Fee Information The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed. If the State Equalized Value or Taxable Value in contention is: Your filing fee is: $100,000.00 and under $250.00 $100,000.01 to $500,000.00 $400.00 $Over $500,000.00 $600.00 * Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00. 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/ /s/Joshua T. Shillair Payment Information Amount: 425 Success: True Message: "" Waiver Code: Transaction Number: 26052686953528 Supporting Waiver Documents:
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