Midtown Hotel Group, LLC, Petitioner Vs. City Of Detroit, Respondent

Page 1

Court of Appeals, State of Michigan 

ORDER 

MIDTOWN HOTEL GROUP LLC V CITY OF DETROIT 

Docket No. 

377749 

LC No. 

25-003116 

Christopher M. Murray, Judge, acting under MCR 7.211(E)(2), orders: 

The motion to hold the appeal in abeyance is GRANTED pending the resolution of this 

Court’s decision in Docket No. 377649. 

January 13, 2026

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Page 1

RECEIVED 

-— TE 

0CT 14205 W\~ 

STATE OF MICHIGAN 

COURT OF APPEALS 

MICHIGAN TAX TRIBUNAL 

Midtown Hotel Group, LLC, 

Petitioner-Appellant, 

v 

Court of Appeals Case No. 

City Of Detroit, 

MTT Docket No. 25-003116 

Respondent-Appellee. 

Stewart Mandell (P33781) 

Kevin C. Richard (P43417) 

Jackie J. Cook (P68781) 

City of Detroit Law Department 

Christina Grossi (P67482) 

Attorneys for Respondent-Appellee 

Honigman LLP 

Coleman A. Young Municipal Center 

Attorneys for Petitioner-Appellant 

2 Woodward Avenue, Suite 500 

39400 Woodward Avenue, Suite 101 

Detroit, MI 48226 

Bloomfield Hills, MI 48304-5151 

(313) 237-3061 

(313) 465-7420 

richkc@detroitmi.gov 

slmandell@honigman.com 

jcook@honigman,.com 

cgrossi@honigman.com 

Notice of Filing Claim of Appeal 

TO: 

Chief Clerk 

Michigan Tax Tribunal 

611 W. Ottawa 

Lansing, MI 48933 

PLEASE TAKE NOTICE that on October 14, 2025, the attached Claim of Appeal was 

filed electronically with the Court of Appeals.

Page 2

JIS Code: COA 

STATE OF bIGAL DISTRICT 

CASE NO. 

CIRCUIT 

Michigan 

Tax 

Tribunal 

JUDICIAL CIRCUIT 

gan 

Tax 

Tribuna 

COUNTY 

CLAIM OF APPEAL 

DISTRICT 

3.003116 

[/]IN THE COURT OF APPEALS 

PROBATE 

Court address 

Court telephone no. 

Plaintiffs/Petitioner’s name(s) and address(es) 

[¥] Appetiant 

Midtown Hotel Group, LLC 

Olappeltes 

Defendant's/Respondent’s nama(s) and address(es) 

[i] Appellant 

City of Detroit 

¥] Appetiee 

Plaintiff's attorney, bar no., address, and telephone no. 

Stewart L. Mandell (P33781), Jackie J. Cook {P68781), 

Christina Grossi (P67482), Honigman LLP, 39400 Woodward 

Avenue, Suite 101, Bloomfield Hills, M1 48304, 

(313) 465-7420, {248) 566-8474 

Defendant's attorney, bar no., address, and telephone no. 

Kevin Richard {P43417), City of Detroit Law Department, 

CAYMC - 2 Woodward Avenue, Suite 500, Detroit, MI 48226, 

{313) 237-3061 

In the matter of 

Other Interested party(ies) of probate matter 

1. Midtown Hotel Group LLC 

Name 

September 25, 2025 

in the Michigan Tax Tribunal 

claims an appeal from a final judgment or final order entered on 

Court of the State of Michigan, 

Date 

Court name and number or county 

by 

Odistrictjudge 

 Cloircuitjudge 

[probate judge 

[district court magistrate 

Presiding Judge Patricia L. Halm 

P48096 

. 

Name of judge or district court magistrate 

Bar no. 

2. Bondon appealis 

 [lfiled. 

attached. 

[Jwaived. 

 [inotrequired. 

3 . Oa. The transcript has been ordered. 

[1b. The transcript has been filed, 

¢. No record was made.

Page 3

Clalm of Appeal 

(9/23) 

Page al 

Case No, 25-003116 

714. THIS CASE INVOLVES 

(Ja. ACONTEST 

AS TO THE CUSTODY OF A MINOR CHILD. 

Ob. ANADULT OR MINOR GUARDIANSHIP UNDER THE ESTATES AND PROTECTED INDIVIDUALS CODE OR 

UNDER THE MENTAL HEALTH CODE. 

[Jc AN INVOLUNTARY MENTAL HEALTH TREATMENT CASE UNDER THE MENTAL HEALTH CODE. 

Wd. ARULING THAT A PROVISION OF THE MICHIGAN CONSTITUTION, A MICHIGAN STATUTE, 

A RULE OR 

REGULATION INCLUDED IN THE MICHIGAN ADMINISTRATIVE CODE, OR ANY OTHER ACTION OF THE 

LEGISLATIVE OR EXECUTIVE BRANCH OF STATE GOVERNMENT IS INVALID. 

Je. AN ADOPTION ORDER UNDER CHAPTER X OF THE PROBATE CODE, 

Jf. 

AFREEDOM OF INFORMATION ACT ISSUE. 

10/14/2025 

Stewart L, Mandell 

Date 

Appellant/Attorney signature 

PROOF OF SERVICE 

| certify that copies of this claim of appeal and bond (if required) were served on 

Kevin Richard 

on 10/14/2025 

by 

[personal service. 

first-class mail. 

Name 

Date 

on 

by 

[personal service. 

[lfirst-class mail. 

Name 

Date 

on 

by 

[personal service. 

[first-class mail. 

Name 

Date 

10/14/2025 

/s/ Lisa Joseph 

Dale 

Signature

Page 4

Michigan Court of Appeals 

Lower Court/Tribunai: Michigan Tax Tribunal 

Jurisdictional Checklist 

25-003116 

Lower Court Case No.: 

case Name: Midtown Hotel Group, LLC v City of Detroit 

INSTRUCTIONS: For 

a civil claim of appeal, please complete the following statements. 

[SELECT ONE] An appeal of right may be filed because the order is: 

MCR 7.203(A) 

] 

A final order of the circuit court under MCR 7.202(6). Specify subsection: 

A probate court order that falls within MCR 5.801(A). Specify subsection: 

MI Const. ant 6, sec 28; MCL 205.7531); MCR 7.203(A)(2) 

Appealable as of right by law or court rule. Specify law or rule; 

[SELECT ONE] This claim of appeal is timely because it is being filed: 

MCR 7.204(A) 

Within 21 days from entry of the order appealed from (as identified above). 

[] 

Within 21 days of an order deciding a motion for new trial, rehearing, reconsideration, or other relief from 

the order appealed, and the postiudgment motion was filed within 21 days of the order appealed from. 

] 

Other: 

INSTRUCTIONS: Please complete the checklist and file with your claim of appeal. 

Failure to file all required documents and requisite fees may result in rejection of 

MCR 7.201(B)(2) 

your claim of appeal. 

A signed claim of appeal. The caption must list all of the parties in each lower court 

MCR 7.204(B)(1) & (D) 

case appealed, 

A copy of the order you are appealing (as identified in Jurisdiction section). 

MCR 7.204(C)(1) 

An official current register of actions from the lower court or tribunal showing entry 

MCR 7.204(C)(5) 

of the order appealed. 

The filing fee or exception (example: motion to waive fees). 

MCR 7.202(3), 

MCR 7.204(B)(2) 

Evidence of the transcript (Select one): 

MCR 7.204(C)}(2) 

J The complete transcript has been ordered. 

MCR 7.210(B){1)(a) 

No transcript will be filed. 

MCR 7.204(C)(2)

Page 5

Order Appealed

Page 6

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Midtown Hotel Group LLC, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MTT Docket No. 25-003116 

City of Detroit, 

Presiding Judge 

Respondent. 

Patricia L. Halm 

ORDER OF DISMISSAL 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner's appeal. The pleadings indicate that Petitioner is appealing the true cash 

value, state equalized value, and taxable value (TV) for Parcel No.

Page 7

MTT

Page 8

MTT

Page 9

O

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Page 1

RECEIVED! 

SEP 25 2025 

STATE OF MICHIGAN 

i 

i 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS CHIGAN TAX TRIBUNAL 

MICHIGAN TAX TRIBUNAL 

Midtown Hotel Group, LLC, 

Petitioner, 

Pp] 

v. 

MTT Docket No. 

> 

~ 0 2) 

. 

42 

00 

City-of Detroif, 

Parcel No. 01004205.001 

Respondent, 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

jcook@honigman.com 

Proof of Service 

Lisa Joseph states that on 

4 [25/25 

shedid serve a copy of Petitioner's Petition, 

with docket number, upon the parties named on the attached list. 

-— 

7/ sl 

/d Foon Dgacph 

Lida J 0séph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

ASSESSOR 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WAYNE COUNTY 

CAYMC, 2 WOODWARD AVENUE #211 

DETROIT, MI 48226 

DIRECTOR OF EQUALIZATION 

WAYNE COUNTY 

500 GRISWOLD ST. 21ST FLOOR 

DETROIT, MI 48226 

SECRETARY OF SCHOOL BOARD 

DETROIT PUBLIC SCHOOLS 

7321 2ND AVENUE, 14TH FLOOR 

DETROIT, MI 48202-4050 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0059

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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 

Midtown Hotel Group LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-003116 

 

City of Detroit, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner’s appeal. The pleadings indicate that Petitioner is appealing the true cash 

value, state equalized value, and taxable value (TV) for Parcel No. 01004205.001 for 

the 2025 tax year. The Tribunal has no authority over that parcel under MCL 

205.735a(6), however, because the subject property is classified as commercial and, as 

such, the deadline for filing an appeal in this case was June 2, 2025.1 Petitioner filed 

the petition on August 7, 2025, and as such, failed to appeal the assessment to the 

Tribunal by the statutory deadline. 

 

Petitioner’s failure to file the appeal by the statutory deadline is a failure to invoke the 

Tribunal’s statutory jurisdiction over this proceeding.2 In Sixarp, the Michigan Supreme 

Court reiterated previous appellate decisions in its reasoning that the Tribunal’s 

jurisdiction is statutory by nature. The Court stated: 

 

MCL 205.735a(3) “is not a notice statute, but is a jurisdictional statute that 

governs when and how a petitioner invokes the Tax Tribunal’s jurisdiction.” 

We therefore overrule Parkview3 to the extent that it incorrectly held that the 

protest requirement of . . . the precursor to MCL 205.735a . . . is a mere 

“procedural requirement for perfecting an appeal in the Tax Tribunal” and 

not an express limitation on the MTT’s jurisdiction. Instead, the protest 

requirement of MCL 205.735a(3) may only be waived by the court if 

necessary to remedy a constitutional due-process violation that deprived 

the taxpayer of their ability to invoke the right to protest.4 

 

The Tribunal finds that the same reasoning relied upon by the Sixarp court is applicable 

to MCL 205.735a(6) in this case. The Legislature created a statutory jurisdiction 

 

1 MCL 205.735a(6) states in pertinent part: “The jurisdiction of the tribunal in an assessment dispute as to 

property classified . . . as commercial real property . . . is invoked by a party in interest, as petitioner, filing 

a written petition on or before May 31 of the tax year involved.” Further, the deadline was extended to 

June 2, 2025 because May 31 fell on a Saturday. See MCL 205.735a(8). 

2 See Sixarp, LLC v Byron Twp, __Mich __; __ NW3d __ (2025) (Docket No 166190) at 8. 

3 Parkview Memorial Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (Parkview) (1990). 

4 See Sixarp at 8 (citations omitted).

Page 2

MTT Docket No. 25-003116 

Page 2 of 3 

 

requirement that a commercial property valuation appeal be filed with the Tribunal by 

May 31 of the tax year under appeal. This statutory subsection, like MCL 205.735a(3), 

controls the Tribunal’s jurisdiction over an appeal. The Tribunal has no equitable power 

to disregard a statutory filing deadline.5 “[S]imply because the plaintiffs' underlying 

claim has a constitutional dimension, and may even be meritorious, does not excuse the 

plaintiffs' failure to assert their claim within the applicable statutory period of limitation.”6 

 

The Tribunal notes that the petition in this case contends that Petitioner did not receive 

the notice of assessment until “[a]fter July 6, 2025.”7 Petitioner also pleads that there is 

a dispute as to loss,8 and the Tribunal notes that any potential contention affecting TV 

requires a “mandatory and automatic” review to properly consider the determination of 

TV.9 Notwithstanding, these contentions of improper notice, if actionable, would require 

a determination by an applicable authority that the purported error resulted in a due-

process violation. As explained above, the Tribunal lacks any equitable authority to 

consider a potential due-process violation. The Tribunal’s jurisdiction as a result of a 

failure of a unit of government to comply with a statutory obligation, if there was any, 

may be vested upon the Tribunal by a judicial body only as a matter of equity.10 As 

opposed to what is stated in the petition in this case, reliance on Parkview is not 

appropriate as that case was overruled by Sixarp.11 Lacking jurisdiction, the only 

appropriate action is dismissal. Therefore, 

 

IT IS ORDERED that the case is DISMISSED. 

 

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

 

APPEAL RIGHTS 

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

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

Appeals. 

 

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

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

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

 

5 The Tribunal’s powers are limited to those authorized by statute and do not include powers of equity. 

See Federal-Mogul Corp v Dep’t of Treasury, 161 Mich App 346 (1987), Elec Data Sys Corp v Flint Twp, 

253 Mich App 538 (2002), and VanderWerp v Plainfield Twp, 278 Mich App 624 (2008). 

6 See Szymanski v City of Westland, 420 Mich 301, 303; 362 NW2d 224, 225 (1984). 

7 Petition at paragraph 11. 

8 Id. at paragraph 9. 

9 See Michigan Properties, LLC v Meridian Twp, 491 Mich 518, 531; 817 NW2d 548 (2012). 

10 See Sixarp at 4, 8. The court held respectively that “the Court of Appeals remedied the violation by 

vesting the MTT with jurisdiction to consider the exemption claim as a matter of equity” and that Petitioner 

was required to demonstrate that Respondent

Page 3

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Midtown Hotel Group, LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. 

Parcel No. 01004205.001 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

Petition 

Petitioner Midtown Hotel Group, LLC (“Petitioner”), through its attorneys, Honigman 

LLP, says: 

1.

Petitioner's principal office address is 31100 Stephenson Highway, Madison 

Heights, MI 48071. 

2.

Petitioner is a party in interest with respect to property taxes on tax parcel number 

01004205.001 ("Petitioner's Property"). Petitioner’s Property has an address of 4 E. Alexandrine 

Street, Detroit, MI, located in Wayne County, Michigan. 

3.

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's 

Property.

Page 2

2 

61658867.1 

4.

For the 2025 tax year, Respondent’s March Board of Review set the assessed value 

and taxable value of Petitioner’s Property at $2,799,500, and that has resulted in a state equalized 

value of $2,799,500. 

5.

Petitioner’s Property is classified as commercial real. 

6.

Petitioner’s Property is presently used or available for use for commercial purposes. 

7.

Petitioner believes that Petitioner’s Property was originally designed to be used for 

commercial purposes. 

8.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, (d) due process and equal protection under the Constitutions of the United States and the 

State of Michigan, (e) the assessment notice requirements of the General Property Tax Act, and 

(f) uniformity. 

9.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

10.

No board of review protest was required for Petitioner’s Property. 

11.

After July 6, 2025, was the first time that Respondent provided, and Petitioner 

received, a proper and correct notice of the 2025 taxation of Petitioner’s Property. 

12.

Under the due process and equal protection guarantees of the Constitution of the 

United States, the Michigan Constitution, and precedent that includes and is not limited to 

Parkview Mem Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (1990) and Michigan 

State University v City of Lansing, unpublished opinion per curiam of the Court of Appeals, issued 

February 15, 2005 (Docket No. 250813), the Tribunal has jurisdiction over this case. 

13.

In Michigan State University v City of Lansing, unpublished opinion per curiam of 

the Court of Appeals, issued February 15, 2005 (Docket No. 250813), the taxpayer was entitled to

Page 3

3 

61658867.1 

pursue its Tribunal appeal where it filed its Tribunal Petition within thirty-five days of receiving 

its summer tax bill in July because that was the first notice it received of the assessment. Here, 

Petitioner also is filing this Petition within thirty-five days of receiving its summer tax bill and 

notice of the property’s taxation, and therefore Petitioner is entitled to pursue this appeal. 

14.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The 2025 assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The 2025 assessment, including state equalized value and/or taxable value, 

is at a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The 2025 assessment, including taxable value and/or state equalized value, 

is based upon an erroneous determination of the true cash value of that portion of Petitioner’s 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and, 

(d) 

The 2025 assessment, including state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

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

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: 

(i) reducing the 2025 assessed value, state equalized value, and taxable value of Petitioner’s 

Property from $2,799,500 to $1,000,000; (ii) requiring payment to Petitioner of the refunds

Page 4

4 

61658867.1 

attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief 

to which it is entitled. 

Dated: August 7, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.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

Midtown Hotel Group, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-003116

City of Detroit, 

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 20, 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 & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Midtown Hotel Group, LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. 

Parcel No. 01004205.001 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

Petition 

Petitioner Midtown Hotel Group, LLC (“Petitioner”), through its attorneys, Honigman 

LLP, says: 

1.

Petitioner's principal office address is 31100 Stephenson Highway, Madison 

Heights, MI 48071. 

2.

Petitioner is a party in interest with respect to property taxes on tax parcel number 

01004205.001 ("Petitioner's Property"). Petitioner’s Property has an address of 4 E. Alexandrine 

Street, Detroit, MI, located in Wayne County, Michigan. 

3.

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's 

Property.

Page 2

2 

61658867.1 

4.

For the 2025 tax year, Respondent’s March Board of Review set the assessed value 

and taxable value of Petitioner’s Property at $2,799,500, and that has resulted in a state equalized 

value of $2,799,500. 

5.

Petitioner’s Property is classified as commercial real. 

6.

Petitioner’s Property is presently used or available for use for commercial purposes. 

7.

Petitioner believes that Petitioner’s Property was originally designed to be used for 

commercial purposes. 

8.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, (d) due process and equal protection under the Constitutions of the United States and the 

State of Michigan, (e) the assessment notice requirements of the General Property Tax Act, and 

(f) uniformity. 

9.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

10.

No board of review protest was required for Petitioner’s Property. 

11.

After July 6, 2025, was the first time that Respondent provided, and Petitioner 

received, a proper and correct notice of the 2025 taxation of Petitioner’s Property. 

12.

Under the due process and equal protection guarantees of the Constitution of the 

United States, the Michigan Constitution, and precedent that includes and is not limited to 

Parkview Mem Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (1990) and Michigan 

State University v City of Lansing, unpublished opinion per curiam of the Court of Appeals, issued 

February 15, 2005 (Docket No. 250813), the Tribunal has jurisdiction over this case. 

13.

In Michigan State University v City of Lansing, unpublished opinion per curiam of 

the Court of Appeals, issued February 15, 2005 (Docket No. 250813), the taxpayer was entitled to

Page 3

3 

61658867.1 

pursue its Tribunal appeal where it filed its Tribunal Petition within thirty-five days of receiving 

its summer tax bill in July because that was the first notice it received of the assessment. Here, 

Petitioner also is filing this Petition within thirty-five days of receiving its summer tax bill and 

notice of the property’s taxation, and therefore Petitioner is entitled to pursue this appeal. 

14.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The 2025 assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The 2025 assessment, including state equalized value and/or taxable value, 

is at a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The 2025 assessment, including taxable value and/or state equalized value, 

is based upon an erroneous determination of the true cash value of that portion of Petitioner’s 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and, 

(d) 

The 2025 assessment, including state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

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

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: 

(i) reducing the 2025 assessed value, state equalized value, and taxable value of Petitioner’s 

Property from $2,799,500 to $1,000,000; (ii) requiring payment to Petitioner of the refunds

Page 4

4 

61658867.1 

attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief 

to which it is entitled. 

Dated: August 7, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

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

Midtown Hotel Group, LLC

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

31100 Stephenson Highway

City or Town

Madison Heights

State

Michigan

ZIP Code

48071

Telephone Number

2485668300

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

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

slmandell@honigman.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]

Michigan

Taxing Authority (City or Township)

City of Detroit (Wayne)

County

Wayne

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:

01004205.001

Classification of Property: Real 

Commercial

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

2799500

Current Taxable Value as established by the Board of Review:

2799500

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 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/ Stewart L. Mandell

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.