Nco Parking 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 Parking LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002805 

 

City of Detroit, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

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

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

 

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

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

indicated. 

 

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

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

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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-002805 

Page 2 of 2 

 

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

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

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

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

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

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

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

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

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

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

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

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

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

8.66%. 

 

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

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

By

 

 

Entered: July 25, 2025 

jcr 

 

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

25-002805

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Parking LLC, 

Petitioner, 

MTT Docket No. 25-002805 

v. 

Parcel No. 04001536-40 

City of Detroit, 

Respondent, 

Stipulation for Entry of Consent Judgment 

1. 

The parcel is located in Wayne County. 

2. 

The case is pending in the X Entire Tribunal OR __ Small Claims Division. 

3. 

Property Parcel No: 04001536-40 

4. 

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

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$23,718,800 

$11,859,400 

$2,546,775 

5. 

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

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2025 

$15,719,200 

$7,859,600 

$2,546,775 

6. 

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

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

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

years (attach additional page if necessary): 

N/A 

7. 

List separately any special terms or conditions being proposed by the parties that would 

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

payment of the refund, the waiver of interest, etc.: N/A

Page 2

8. 

List separately any special terms or conditions being proposed by the parties that would 

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

payment of the refund, the waiver of interest, etc.: 

N/A 

HONIGMAN LLP 

Attorneys for Petitioner, 

Stewart Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(313) 465-7420 

slmandell@honigman.com 

Dated: June 13, 2025 

CITY OF DETROIT LAW DEPARTMENT 

Attorneys for Respondent, 

Kevin Richard (P43417) 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, MI 48226 

(313) 237-3061 

richkc@detroitmi.gov 

Dated: June 17, 2025 

MN 

By Jk 

Nr 

Alvin Horhn, Deputy CFO/Assessor 

CAYMC - 2 Woodward Avenue, 

Suite 804 

Detroit, 

MI 48226 

Dated: \) 

Ne Np $ 

By:

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 Parking LLC, 

Petitioner, 

) 

MTT Docket No. 

<7 

Vv. 

Parcel No. 04001536-40 

City of Detroit, 

Respondent, 

<-002%05 

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 

Proof of Service 

Lisa Joseph states that on 7 / 23 [2 LP she did serve a copy of Petitioner's Petition, 

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

Dated: 1 53 

/ 25 

(4 

Hein 

Joséph 

~() 

: he 

59427327.1 

25-0090

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 

594273271 

25-0115

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

25-002805

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Parking LLC, 

Petitioner, 

MTT Docket No. 25-002805 

v. 

Parcel No. 04001536-40 

City of Detroit, 

Respondent, 

Stipulation for Entry of Consent Judgment 

1. 

The parcel is located in Wayne County. 

2. 

The case is pending in the X Entire Tribunal OR __ Small Claims Division. 

3. 

Property Parcel No: 04001536-40 

4. 

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

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$23,718,800 

$11,859,400 

$2,546,775 

5. 

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

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2025 

$15,719,200 

$7,859,600 

$2,546,775 

6. 

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

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

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

years (attach additional page if necessary): 

N/A 

7. 

List separately any special terms or conditions being proposed by the parties that would 

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

payment of the refund, the waiver of interest, etc.: N/A

Page 2

8. 

List separately any special terms or conditions being proposed by the parties that would 

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

payment of the refund, the waiver of interest, etc.: 

N/A 

HONIGMAN LLP 

Attorneys for Petitioner, 

Stewart Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(313) 465-7420 

slmandell@honigman.com 

Dated: June 13, 2025 

CITY OF DETROIT LAW DEPARTMENT 

Attorneys for Respondent, 

Kevin Richard (P43417) 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, MI 48226 

(313) 237-3061 

richkc@detroitmi.gov 

Dated: June 17, 2025 

MN 

By Jk 

Nr 

Alvin Horhn, Deputy CFO/Assessor 

CAYMC - 2 Woodward Avenue, 

Suite 804 

Detroit, 

MI 48226 

Dated: \) 

Ne Np $ 

By:

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 AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NCO PARKING, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 25-002805 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

PROOF OF SERVICE 

 

On July 23, 2025, I served via first class U.S. Mail and email a copy of Respondent’s Answer with 

Affirmative Defenses in the instant matter to: 

 

Stewart L. Mandell 

Honigman LLP 

39400 Woodward Ave., Suite 101 

Bloomfield Hills, Michigan 48304 

slmandell@honigman.com 

 

I declare that the statement above is true to the best of my information, knowledge, and belief. 

 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Senior Assistant Corporation Counsel 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Dated: July 23, 2025 

Detroit, Michigan 48226

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

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NCO PARKING, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 25-002805 

 

CITY OF DETROIT, 

 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

2. Respondent admits. 

3. Respondent admits. 

4. Respondent admits. 

5. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

involving valuation, assessment, and uniformity, however, Respondent denies that any 

such allegations have merit. 

6. Respondent admits. 

7. Respondent denies as untrue. 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

1. Petitioner’s claims are barred by the applicable statute of limitations.

Page 2

2 

 

2. Petitioner has failed to state a claim for which relief may be granted. 

3. Petitioner lacks standing. 

4. This Tribunal lacks subject matter jurisdiction. 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

(313) 237-3061 

Dated: July 23, 2025

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 - Respondent

MOAHR DOCKET NO. 25-002805

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City of Detroit (Wayne)

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

Kevin

M.I.

C

Last Name

Richard

Firm Name (if any)

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

2 Woodward Avenue, Suite 500

City of Detroit Law Department

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-237-3061

Fax Number

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

richkc@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kevin C Richard

/s/

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

Honieman LLP 

COSTS ADVANCED ACCOUNT 

I 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

6/2/25 

[ 

99997/997594/SLM 

#45§600,00%+* 

Filing Fee for Petition — NCO Parking 

Parcel 04001536-40 

RECEIVE" 

JUN 04 20. 

MICHIGAN TAX TRIBL 

TranInfo:4606 

 26021217-1 

06/03/25 

Chik: 

040621 

At: $600.00 

ID: 

HONIGHAN LLP 

21074678.1

Page 2

RECEIVED 

wT 

JUN 09 2025 

™ 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Parking LLC, 

Petitioner, 

MTT Docket No. 

v. 

Parcel No. 04001536-40 

City of Detroit, 

Respondent, 

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 

Petition 

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

1. 

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 

04001536-40 ("Petitioner's Property"), with an address of 2943 W. Grand Blvd., Detroit, located 

in Wayne County, Michigan. 

2; 

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

Property.

Page 3

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; 

(©) 

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 $11,859,400 to

Page 4

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

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 Parking LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002805

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

Honieman LLP 

COSTS ADVANCED ACCOUNT 

I 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

6/2/25 

[ 

99997/997594/SLM 

#45§600,00%+* 

Filing Fee for Petition — NCO Parking 

Parcel 04001536-40 

RECEIVE" 

JUN 04 20. 

MICHIGAN TAX TRIBL 

TranInfo:4606 

 26021217-1 

06/03/25 

Chik: 

040621 

At: $600.00 

ID: 

HONIGHAN LLP 

21074678.1

Page 2

RECEIVED 

wT 

JUN 09 2025 

™ 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NCO Parking LLC, 

Petitioner, 

MTT Docket No. 

v. 

Parcel No. 04001536-40 

City of Detroit, 

Respondent, 

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 

Petition 

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

1. 

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 

04001536-40 ("Petitioner's Property"), with an address of 2943 W. Grand Blvd., Detroit, located 

in Wayne County, Michigan. 

2; 

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

Property.

Page 3

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; 

(©) 

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 $11,859,400 to

Page 4

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

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.