Macomb-Garfield LLC, Petitioner Vs. Township Of Clinton, 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

Macomb-Garfield LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002211

Township Of Clinton,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: September 17, 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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Macomb-Garfield LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002211

Township Of Clinton,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: September 17, 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 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

Macomb-Garfield LLC, 

Petitioner, 

V. 

Charter Township of Clinton, 

Respondent. 

MTT Docket No. 25-002211 

 

 

BRIAN E. ETZEL (P54905) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, PC 

Attorney for Petitioner 

380 N. Old Woodward Ave., Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

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 

 

 

 

STIPULATION TO WITHDRAW APPEAL 

Petitioner Macomb-Garfield, LLC, and Respondent, Charter Township of Clinton, by and 

through their respective attorneys, hereby stipulate the withdrawal of this appeal without costs or 

fees to any party. 

 

WILLIAMS WILLIAMS RATTNER 

 

 

HALLAHAN & ASSOCIATES, P.C. 

 & PLUNKETT PC 

 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

By: /s/ Laura M. Hallahan 

 

 

 Brian E. Etzel (P54905) 

 

 

 Laura M. Hallahan (P42101) 

 Attorney for Petitioner 

 

 

 

 Attorney for Respondent 

 

Dated: September 17, 2026

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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: 25-002211

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

Party Filing Document 

Joint

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Stipulation to Withdraw Appeal

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

8 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

MACOMB-GARFIELD, LLC, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Docket No. 25-002211 

 

Petitioner, 

 

 

 

 

 

 

 

v. 

 

CHARTER TOWNSHIP OF CLINTON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

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, Michigan 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PROOF OF SERVICE 

 

I certify that I am an employee of Williams, Williams, Rattner & Plunkett, P.C., and that on 

March 30, 2026, I served a copy of Petitioner’s Responses to Respondent’s First Request for 

Production of Documents, Petitioner’s Document Production Identified as PETITIONER 000001 – 

PETITIONER 000219, and this Proof of Service via e-mail upon: 

 

Laura M. Hallahan, Esq. 

Seth A. O’Loughlin, Esq. 

Kelsea M. Melcher, Esq. 

HALLAHAN & ASSOCIATES, P.C. 

lhallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

 

 “I declare under penalty of perjury that the statements above are true to the best of my knowledge, 

information and belief. 

 

 

 

 

 

 

/s/ Sarah E. Conner 

 

 

 

 

 

 

 

Sarah E. Conner

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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

NOTICE OF JANUARY 19 - 29, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Macomb-Garfield LLC,

Petitioner,

v

 

 

Township Of Clinton,

Respondent.

 MTT Docket No. 25-002211

Please be advised that 25-002211 has been placed on a two-week Prehearing General 

Call commencing January 19, 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. 25-002211

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 September 22, 2026. 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 September 22, 2026. 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 

September 22, 2026, 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 

January 19, 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

Page 3

MTT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

MACOMB-GARFIELD, LLC, 

 

 

 

Petitioner, 

 

v 

 

CHARTER TOWNSHIP OF CLINTON, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-002211 

Parcel No. 16-11-07-426-015 

 

 

_____________________________________________________________________________/ 

 

BRIAN E. ETZEL (P54905) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Attorney for Petitioner 

380 N. Old Woodward Avenue, Suite 300 

(248) 642-0333 

 

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, Charter Township of Clinton, by and through its attorneys, Hallahan & 

Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 

The Parties 

1. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the assertions set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

The Subject Property 

 

3. 

Respondent admits the allegations in Paragraph 3 as to parcel number and 

address. As to the remainder of the allegations set forth, Respondent lacks the information and

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

knowledge necessary to respond to the truth of said allegations and, therefore, leaves Petitioner 

to its proofs. 

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5. 

 

The 2025 Assessment 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

The values for the property identified above as established by Respondent’s 

Board of Review are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$4,962,400 

$2,481,200 

$1,623,857 

 

8. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$4,962,400 

$2,481,200 

$1,623,857 

 

9. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$0 

$0 

$0 

 

10. 

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

but denies said issues have merit. Respondent further denies Petitioner has the right to raise 

issues not identified in its Petition at a later date. Moreover, Respondent denies Petitioner is 

entitled to any relief. 

 

11. 

Respondent denies the allegations in Paragraph 11, including subsections (a)-(d), 

for the reason that the same are untrue. 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. 

 

12. 

Respondent admits the subject property was uniformly assessed. Respondent 

denies that the subject property’s values were in any way overestimated. 

 

Conclusion and Relief Requested 

13. 

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 above.

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

 

WHEREFORE, Respondent, Charter Township of Clinton, 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: September 19, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Charter Township of Clinton, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 

(1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

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

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

its agents.

Page 4

Entire Tribunal Property Tax Answer 

Page 4 of 5 

 

5. 

Petitioner has failed to allege that the mode and method of assessing

Page 5

Enti

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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. 25-002211

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Clinton (MACOMB)

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

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

MACOMB-GARFIELD, LLC,

Petitioner,

v.

CHARTER TOWNSHP OF CLINTON,

Respondent.

PROOF OF SERVICE FOR PETITION AND NOTICE OF DOCKET NUMBER

019991 18.DOCX

Docket No. 25-002211

Parcel No. 16-11-07-426-015

Brian E. Etzel (P54905)

WILLIAMS, WILLIAMS, RATTNER

& PLUNKETT, PC

Attorneysfor Petitioner

380 N. Old Woodward Ave., Ste. 300

Birmingham, MI 48009

(248) 642-0333

bee@wwrplaw.com

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN ADMINISTRATIVE HEARING SYSTEM

MICHIGAN TAX TRIBUNAL

Page 2

PROOF OF SERVICE FOR PETITION AND NOTICE OF DOCKET NUMBER

Sarah Conner states that she served copies of the Entire Tribunal Property Tax Petition,

Notice of Docket Number and this Proof of Service, on the persons listed below, by placing

copies of those documents in a duly stamped, addressed envelope and placing the envelope in the

United States mail on August 22, 2025.

PERSONS SERVED:

VIA CERTIFIED MAIL

VIA US FIRST CLASS MAIL

019991 18.DOCX

Clinton Township Clerk

40700 Romeo Plank Road

Clinton Township, MI 48038

Macomb County

Equalization Director

1 S. Main, 6th Fl.

Mt. Clemens, MI 48043

Macomb County Clerk

120 N. Main

Mt. Clemens, MI 48043

State Treasurer

Michigan Department of Treasury

Austin Building

430 W. Allegan

Lansing, MI

48922

Secretary of School Board

Chippewa Valley School District

19120 Cass Avenue

Clinton Township, MI 48038

G

Sarah Conner

Clinton Township Assessor

40700 Romeo Plank Road

Clinton Township, MI 48038

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Page 1

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

MACOMB-GARFIELD, LLC, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

Docket No. 25- 

 

 

 

 

 

 

 

 

Parcel No. 16-11-07-426-015 

 

v. 

 

CHARTER TOWNSHIP OF CLINTON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

Petitioner MACOMB-GARFIELD, LLC, by and through its attorneys, Williams, 

Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner MACOMB-GARFIELD, LLC, is a Domestic limited liability company 

with its registered office located at 263 Pine Ridge, Bloomfield Hills, Michigan 48304. 

2. 

Respondent the Charter Township of Clinton is a Michigan charter township with 

its principal offices located at 40700 Romeo Plank Road, Clinton Township, Michigan 48038.

Page 2

2 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 16-11-07-426-015 and commonly 

known as 41597 Garfield Road, Clinton Township, Michigan 48035 (the “Subject Property”). 

4. 

The Subject Property is located in Macomb County and is within the Chippewa 

Valley School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Property. 

The 2025 Assessment 

6. 

For the 2025 tax year, Respondent classified the Subject Property as commercial 

real property. 

7. 

For the 2025 tax year, Respondent established the Subject Property’s assessment 

for property taxes as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $4,962,400 

 

$2,481,200 

 

 

$1,623,857 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for the 2025 

tax year cannot exceed the following amounts: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $2,000,000 

 

$1,000,000 

 

 

$1,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $2,962,400 

 

$1,481,200 

 

 

$623,857 

 

10. 

This Petition presents issues involving the Subject Property’s valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),

Page 3

3 

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property’s 2025 assessment (a) violates the Michigan Constitution, the 

GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based 

on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2025 assessment is not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Property’s 2025 assessment to be consistent with the values set forth 

in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under 

Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

Dated: June 2, 2025 

 

 

 

Attorneys for Petitioner

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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

Macomb-Garfield LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002211

Township Of Clinton, 

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 15, 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

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

MACOMB-GARFIELD, LLC, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

 

Docket No. 25- 

 

 

 

 

 

 

 

 

Parcel No. 16-11-07-426-015 

 

v. 

 

CHARTER TOWNSHIP OF CLINTON, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

Petitioner MACOMB-GARFIELD, LLC, by and through its attorneys, Williams, 

Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner MACOMB-GARFIELD, LLC, is a Domestic limited liability company 

with its registered office located at 263 Pine Ridge, Bloomfield Hills, Michigan 48304. 

2. 

Respondent the Charter Township of Clinton is a Michigan charter township with 

its principal offices located at 40700 Romeo Plank Road, Clinton Township, Michigan 48038.

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The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 16-11-07-426-015 and commonly 

known as 41597 Garfield Road, Clinton Township, Michigan 48035 (the “Subject Property”). 

4. 

The Subject Property is located in Macomb County and is within the Chippewa 

Valley School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Property. 

The 2025 Assessment 

6. 

For the 2025 tax year, Respondent classified the Subject Property as commercial 

real property. 

7. 

For the 2025 tax year, Respondent established the Subject Property’s assessment 

for property taxes as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $4,962,400 

 

$2,481,200 

 

 

$1,623,857 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for the 2025 

tax year cannot exceed the following amounts: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $2,000,000 

 

$1,000,000 

 

 

$1,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $2,962,400 

 

$1,481,200 

 

 

$623,857 

 

10. 

This Petition presents issues involving the Subject Property’s valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),

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defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property’s 2025 assessment (a) violates the Michigan Constitution, the 

GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based 

on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2025 assessment is not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Property’s 2025 assessment to be consistent with the values set forth 

in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under 

Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

Dated: June 2, 2025 

 

 

 

Attorneys for Petitioner

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

MACOMB-GARFIELD, LLC

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

263 Pine Ridge

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

248-642-0333

Fax Number

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

beetzel@wwrplaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

E

Last Name

Etzel

Firm Name (if any)

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

380 N Old Woodward Ave

Suite 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-642-0333

Fax Number

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

beetzel@wwrplaw.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]

41597 Garfield Road

Clinton Township

Michigan

48035

Taxing Authority (City or Township)

Township Of Clinton (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.)

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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:

16-11-07-426-015

Classification of Property: Real 

Commercial

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

2481200

Current Taxable Value as established by the Board of Review:

1623857

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?

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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 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/ Brian E. Etzel

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.