Nco Acquisition LLC, Petitioner Vs. City Of Detroit, 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

NCO Acquisition LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-002808

City of Detroit,

Respondent.

ORDER GRANTING PETITIONER’S MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that Petitioner 

has filed a Motion to Withdraw the appeal. Petitioner’s motion was filed prior to the 

answer being filed. Therefore,

IT IS ORDERED that Petitioner’s 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:____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 29, 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

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

NCO Acquisition LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 25-002808

City of Detroit,

Respondent.

ORDER GRANTING PETITIONER’S MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that Petitioner 

has filed a Motion to Withdraw the appeal. Petitioner’s motion was filed prior to the 

answer being filed. Therefore,

IT IS ORDERED that Petitioner’s 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:____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 29, 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

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Acquisition, LLC, 

Petitioner, 

v 

City of Detroit, 

Respondent. 

MTT Docket No. 25-002808 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Kevin C. Richard (P43417) 

City of Detroit Law Department 

Attorneys for Respondent 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, MI 48226 

(313) 237-3061 

richkc@detroitmi.gov

Motion to Withdraw Appeal

For this Motion, Petitioner states: 

Petitioner desires to withdraw its Petition and files this Motion pursuant to Tax Tribunal 

Rule 231, R 792.10231 and MCL 205.732(c). Respondent’s counsel has confirmed that 

Respondent concurs in the Tribunal granting this Motion as requested herein. 

WHEREFORE, Petitioner requests that the Tribunal enter an Order allowing the Petition 

to be withdrawn, or dismissing this case, with each party bearing its own costs. 

 

Respectfully submitted, 

HONIGMAN LLP, 

Attorneys for Petitioner 

By: __/s/ Stewart Mandell_____ 

Stewart Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

Dated: August 28, 2025 

slmandell@honigman.com

Page 2

2 

61143251.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Acquisition, LLC,

Petitioner, 

v 

City of Detroit, 

Respondent. 

MTT Docket No. 25-002808 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Kevin C. Richard (P43417) 

City of Detroit Law Department 

Attorneys for Respondent 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, MI 48226 

(313) 237-3061 

richkc@detroitmi.gov

Proof of Service

Stewart Mandell states that that on August 28, 2025, he did serve a copy of the foregoing 

Motion to Withdraw Appeal via electronic mail, upon: 

Kevin C. Richard (P43417) 

City of Detroit Law Department 

Attorneys for Respondent 

richkc@detroitmi.gov

/s/ Stewart Mandell 

Dated: August 28, 2025 

Stewart 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.

Page 1

ENE 

WC", 

RECEIVED 

QA 

JN 

N 09 

2025 

cee 

# 

pl he 

Ca 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Acquisition LLC, 

Petitioner, 

MTT Docket No. 

Vv. 

Parcel No. 02001098-101 

City of Detroit, 

Respondent, 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

} 

sity 

pnrate 

& 

e 

39400 Woodward Avenue, Suite 101 

Traninfo:4606 

2021219 1 

06/03/25 

. 

Chkit: 

040625 

Amt: $400.00 

Bloomfield Hills, MI 48304-5151 

10: 

HONTGHAN LLP 

(313) 465-7420 

slmandell@honigman.com 

Petition 

NCO Acquisition LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

15 

Petitioner's principal office address is 31700 Middlebelt Rd., Suite 225, Farmington 

Hills, MI 48334. Petitioner is a party in interest with respect to property taxes on tax parcel number 

02001098-101 ("Petitioner's Property"), with an address of 3031 W. Grand Blvd., Detroit, located 

in Wayne County, Michigan. 

2: 

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

Page 2

4. 

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: 

(a) valuation, 

(b) assessment, and (c) 

uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

The 2025 assessment imposed on Petitioner's Property is invalid and unlawful for 

the reasons that: 

(a) 

The assessment, 

including 

state equalized 

value, exceeds 

the amount 

permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, is at a higher percentage 

of true cash value than permissible under the Michigan Constitution and applicable statutes; 

(c) 

The assessment, including 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 

assessment, 

including 

state 

equalized 

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 and state equalized value of Petitioner's Property from $17,440,400 

to

Page 3

Dated: June 2, 2025 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Page 4

Honiaman LLP 

COSTS ADVANCED ACCOUNT 

Invoice Date 

Invoice Number 

Invoice Narrative 

6/2/25 

|] 

24254/16864/SLM 

21074678.1 

Filing Fee for Petition for Parcel 

02001098-101 

— 

Payment Amount

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

NCO Acquisition LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002808

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: July 22, 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

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

ENE 

WC", 

RECEIVED 

QA 

JN 

N 09 

2025 

cee 

# 

pl he 

Ca 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Acquisition LLC, 

Petitioner, 

MTT Docket No. 

Vv. 

Parcel No. 02001098-101 

City of Detroit, 

Respondent, 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

} 

sity 

pnrate 

& 

e 

39400 Woodward Avenue, Suite 101 

Traninfo:4606 

2021219 1 

06/03/25 

. 

Chkit: 

040625 

Amt: $400.00 

Bloomfield Hills, MI 48304-5151 

10: 

HONTGHAN LLP 

(313) 465-7420 

slmandell@honigman.com 

Petition 

NCO Acquisition LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

15 

Petitioner's principal office address is 31700 Middlebelt Rd., Suite 225, Farmington 

Hills, MI 48334. Petitioner is a party in interest with respect to property taxes on tax parcel number 

02001098-101 ("Petitioner's Property"), with an address of 3031 W. Grand Blvd., Detroit, located 

in Wayne County, Michigan. 

2: 

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

Page 2

4. 

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: 

(a) valuation, 

(b) assessment, and (c) 

uniformity. 

6. 

No March Board of Review protest was required for Petitioner’s Property. 

7. 

The 2025 assessment imposed on Petitioner's Property is invalid and unlawful for 

the reasons that: 

(a) 

The assessment, 

including 

state equalized 

value, exceeds 

the amount 

permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value, is at a higher percentage 

of true cash value than permissible under the Michigan Constitution and applicable statutes; 

(c) 

The assessment, including 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 

assessment, 

including 

state 

equalized 

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 and state equalized value of Petitioner's Property from $17,440,400 

to

Page 3

Dated: June 2, 2025 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Page 4

Honiaman LLP 

COSTS ADVANCED ACCOUNT 

Invoice Date 

Invoice Number 

Invoice Narrative 

6/2/25 

|] 

24254/16864/SLM 

21074678.1 

Filing Fee for Petition for Parcel 

02001098-101 

— 

Payment Amount

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.