Newburg Meadows Partners LLC Petitioner Vs. City Of Tecumseh Respondent
- Petitioner
- Newburg Meadows Partners LLC
- Respondent
- City Of Tecumseh
Case overview
- Docket number
- 26-002823-TT
- Status
- Ready Schedule
- CaseType
- ET Property
- Division
- ET
- County
- Lenawee
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 5 | Answer was received | RESP | Not recorded | 08/25/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 07/28/2026 | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 07/27/2026 | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 07/27/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/22/2026 | $600.00 | Download |
Documents
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Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Newburg Meadows Partners LLC, Petitioner, MTT Docket No. 26-002823 v Parcel No. XT0-121-4600-00 City of Tecumseh, Respondent. _____________________________________________________________________________/ L. RIDER BRICE, III (P60741) LAURA M. HALLAHAN (P42101) TAFT STETTINIUS & HOLLISTER LLP SETH A. O’LOUGHLIN (P80257) Attorney for Petitioner KELSEA M. MELCHER (P85821) 27777 Franklin Road, Suite 2500 HALLAHAN & ASSOCIATES, P.C. Southfield, MI 48034 Attorneys for Respondent (248) 351-3000 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ ANSWER TO PETITION AND AFFIRMATIVE DEFENSES ANSWER Respondent, City of Tecumseh, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent lacks the information necessary to respond to the allegations in Paragraph 1 and leaves Petitioner to its proofs. 2. Respondent admits the allegations as to the parcel number and the address but leaves Petitioner to its proofs as to the party in interest claim. 3. Respondent admits the allegations in Paragraph 3.
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4. Respondent admits the allegations in Paragraph 4. 5. Respondent admits the allegations in Paragraph 5 based on information and belief. 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 2026 $5,300,400 $2,650,200 $2,238,746 8. Respondent contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $5,300,400 $2,650,200 $2,238,746 9. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $0 $0 $0 10. Respondent acknowledges the issues raised by Petitioner in Paragraph 10 but denies that Petitioner’s claims have merit or that Petitioner is entitled to relief in this case. 11. Respondent denies the allegations in Paragraph 11, including all subparagraphs, for the reason that the same are untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of 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 acknowledges the relief requested by Petitioner in the final paragraph of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in the above Paragraphs. 2
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WHEREFORE, Respondent, City of Tecumseh, 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/ Seth A. O’Loughlin______________ 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: August 25, 2026 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent, City of Tecumseh, 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. 3
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5. Petitioner has failed to allege that the mode and method of assessing the subject property fails to conform to the mode and method applied in the case of all other properties in Respondent’s taxing unit for the year in question. 6. Petitioner has failed to show that any factor other than fifty percent (50%) was applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the respective assessments appearing on the roll, and also fails to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper. 7. Petitioner asks the Tribunal to grant it preference by application of a self-chosen method of assessment contrary to the intent, purpose and law of this State. 8. Petitioner, in essence, asks the Tribunal to grant it an illegal preference by application of a method of assessment different from that employed in the assessment of other properties in Respondent’s taxing unit. 9. Petitioner, in essence, seeks by petition to challenge the process of county and state equalization as to which it has no legal standing and cannot maintain a cause of action. 10. Any decrease in the value of Petitioner’s property was a result of its own intentional acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 11. Respondent has properly and lawfully assessed Petitioner’s property and established its taxable value in accordance with statutory and constitutional requirements. 12. Petitioner has failed to pursue its appeal in a timely fashion. 13. Respondent reserves the right to raise additional affirmative defenses as the same may become known to it during the course of these proceedings. 4
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HALLAHAN & ASSOCIATES, P.C. /s/ Seth A.
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Entire Tribunal Case Information Sheet - Respondent MTT DOCKET NO. 26-002823 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Tecumseh (LENAWEE) First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) Section 2: Attorney/Authorized Representative’s Contact Information First Name M.I. Last Name Laura Hallahan Firm Name (if any) Hallahan & Associates PC Address (No., Street, P.O. Box or Rural Route) 1750 S. Telegraph Road, Suite 202 City or Town State ZIP Code Bloomfield Hills Michigan 48302 Telephone Number 248-731-3089 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: /s/Kelsea M. Melcher /s/
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27777 Franklin Road, Suite 2500 Southfield, MI 48034-8214 Tel: 248.351.3000 | Fax: 248.351.3082Taft/ taftlaw.com RECEIVED Trey Brice AUGS 2006 248.727.1407 tbrice@taftlaw.com MICHIGAN TAX TRIBUNAL July 28,2026 Michigan Tax Tribunal Ottawa Building, 2nd Floor 611 W. Ottawa Street P.O. Box 30232 Lansing, Michigan 48909-7732 Re: Newburg Meadows Partners v City of Tecumseh MTT Docket 26-002823 Dear Sir/Madam: For the above referenced matter, enclosed please find the Proof of Service for Petitioner’s Petition challenging the 2026 tax year showing service to the required taxing entities. Should there be any questions, please contact me immediately. Taft Stettinius & Hollister LLP TRB
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Newburg Meadows Partners LLC, Petitioner, MTT Docket No. 26- v. Parcel Nos. XT0-121-4600-00 City of Tecumseh, Respondent. PROOF OF SERVICE On the date below I sent a copy of the foregoing Petition by certified United States mail, return receipt requested, to: City Assessor City Clerk City of Tecumseh City of Tecumseh P.O. Box 396 P.O. Box 396 Tecumseh, MI 48286 Tecumseh, MI 48286 On the date below I sent a copy of the foregoing Petition by first-class United States mail to: County Clerk Director of Equalization Lenawee County Lenawee County 301 N Main Street 301 N Main Street 0ld Courthouse 2nd floor Old Courthouse 1st floor Adrian, MI 49221 Adrian, MI 49221 Secretary of School Board State of Michigan Tecumseh Public Schools State Treasurer 760 Brown Street 430 W. Allegan Tecumseh, MI 49286 Lansing, MI 48922 I declare that the statement above is true to the best of my information, knowledge
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Newburg Meadows Partners LLC, Petitioner, MTT Docket No. 26- Vv. Parcel Nos. XT0-121-4600-00 City of Tecumseh, Respondent. PROOF OF SERVICE On the date below I sent a copy of the foregoing Petition by certified United States mail, return receipt requested, to: City Assessor City Clerk City of Tecumseh City of Tecumseh P.O. Box 396 P.O. Box 396 Tecumseh, MI 48286 Tecumseh, MI 48286 On the date below I sent a copy of the foregoing Petition by first-class United States mail to: County Clerk Director of Equalization Lenawee County Lenawee County 301 N Main Street 301 N Main Street Old Courthouse 2nd floor Old Courthouse 1st floor Adrian, MI 49221 Adrian, MI 49221 Secretary of School Board State of Michigan Tecumseh Public Schools State Treasurer 760 Brown Street 430 W. Allegan Tecumseh, MI 49286 Lansing, MI 48922 I declare that the statement above is true to the best of my information, knowledge
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= 320¢ v0 ony PN DeAsney I Taft/ BRICE/shand 27777 Franklin Road, Suite 2500 Southfield, MI 48034-8214 Michigan Tax Tribunal Ottawa Building, 2" Floor 611 W. Cttawa Street P.0. 20232 Lansing, MI 48909-7732
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RECEIVED 27777 Franklin Road, Suite 2500 MAY 27 2006 ad Southfield, Michigan 48034-8214 ) Tel: 248.351.3000 | Fax: 248.351. 3082MI Chi Ga TAX TRIBUNAL Trey Brice Traninfo:db06 261239541 05/26/26 248.727.1407 Chit: 58606 Amt: $400.00 torice@taftlaw.com ID: TAFT STETINIUS AND HOLLISTER LLF May 21, 2026 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED Michigan Tax Tribunal P.O. Box 30232 Lansing, Michigan 48909-7732 Re: Newburg Meadows Partners LLC v City of Tecumseh Parcel Nos. XT0-121-4600-00 Dear Clerk: Enclosed for filing are an original and a copy of the Petition in the captioned matter and the $600.00 filing fee. Please return a time-stamped copy to me in the enclosed self-addressed stamped envelope. Pursuant to the Tax Tribunal Rules, Petitioner will serve the Petition on Respondent and other governmental entities after receiving notice of the docket number for this appeal. If you have any questions regarding the enclosed, please contact me. Sincerely, Taft Stettinius & Hollister LLP TRB/TRB
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Newburg Meadows Partners LLC, Petitioner, MTT Docket No. 26- Ve Parcel Nos. XT0-121-4600-00 City of Tecumseh, Respondent. Taft Stettinius & Hollister LLP L. Rider Brice, III (P60741) Attorneys for Petitioner 27777 Franklin Road, Suite 2500 Southfield, MI 48034 (248) 351-3000 tbrice@taftlaw.com PETITION Petitioner, Newburg Meadows LLC, through its attorneys, Taft Stettinius & Hollister LLP, petitions the Michigan Tax Tribunal as follows: 1 Petitioner is a Michigan limited liability company whose legal address is 600 W 22" Street, Suite 101, Oak Brook, IL 60523. 2. Petitioner is the party of interest with respect to the property identified as tax parcel no. XT0-121-4600-00 (“subject property”), located in Lenawee County at 9000 N Union Street BLK, Tecumseh, Michigan.
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5. The subject property was not required to be protested before the March Board of Review. 6. Respondent, City of Tecumseh levies and collects the property taxes on the subject property. 7. In 2026, Respondent’s Board of Review established the following values for the subject property: True Cash Value Assessed Value Taxable Value 5,300,400 2,650,200 2,638,746 8. Petitioner contends the following are the proper values for the subject property: True Cash Value State Equalized Value Taxable Value 3,000,000 1,500,000 1,500,000 9. The values in dispute for the subject property are: True Cash Value State Equalized Value Taxable Value 2,300,400 1,150,200 1,138,746 10. This matter involves issues relating to: (a) true cash value, (b) taxable value, and (c) uniformity. 11. The assessment, including state equalized taxable values, imposed on the subject property and the taxes levied are unlawful and operate as a fraud upon Petitioners for the reasons that: a. The assessed, state equalized and taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes.
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d. The assessed, state equalized and taxable values are based on an erroneous determination of the true cash value of the subject property, and are based upon the application of wrong principles. Wherefore, Petitioner request that the Tax Tribunal enter an order reducing the true cash, assessed, state equalized, and taxable values of the subject property as Petitioner contends above, and order a refund with interest as provided by the Tax Tribunal Act. Taft Stettinius & Hollister LLP Mia izis L. Rider Brice, II 41) Dated: May 21, 2026 Attorneys for Petitioner
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Taft/ BRICE/shand 27777 Franklin Road, Suite 2500 Southfield, MI 48034-8214 Michigan Tax Tribunal p.0. Box 30232 Lansing, M! 48909"
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Newburg Meadows Partners LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002823 City Of Tecumseh, 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 27, 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 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
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Newburg Meadows Partners LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002823 City Of Tecumseh, 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 27, 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 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
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Newburg Meadows Partners LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002823 City Of Tecumseh, 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
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RECEIVED 27777 Franklin Road, Suite 2500 MAY 27 2006 ad Southfield, Michigan 48034-8214 ) Tel: 248.351.3000 | Fax: 248.351. 3082MI Chi Ga TAX TRIBUNAL Trey Brice Traninfo:db06 261239541 05/26/26 248.727.1407 Chit: 58606 Amt: $400.00 torice@taftlaw.com ID: TAFT STETINIUS AND HOLLISTER LLF May 21, 2026 VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED Michigan Tax Tribunal P.O. Box 30232 Lansing, Michigan 48909-7732 Re: Newburg Meadows Partners LLC v City of Tecumseh Parcel Nos. XT0-121-4600-00 Dear Clerk: Enclosed for filing are an original and a copy of the Petition in the captioned matter and the $600.00 filing fee. Please return a time-stamped copy to me in the enclosed self-addressed stamped envelope. Pursuant to the Tax Tribunal Rules, Petitioner will serve the Petition on Respondent and other governmental entities after receiving notice of the docket number for this appeal. If you have any questions regarding the enclosed, please contact me. Sincerely, Taft Stettinius & Hollister LLP TRB/TRB
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Newburg Meadows Partners LLC, Petitioner, MTT Docket No. 26- Ve Parcel Nos. XT0-121-4600-00 City of Tecumseh, Respondent. Taft Stettinius & Hollister LLP L. Rider Brice, III (P60741) Attorneys for Petitioner 27777 Franklin Road, Suite 2500 Southfield, MI 48034 (248) 351-3000 tbrice@taftlaw.com PETITION Petitioner, Newburg Meadows LLC, through its attorneys, Taft Stettinius & Hollister LLP, petitions the Michigan Tax Tribunal as follows: 1 Petitioner is a Michigan limited liability company whose legal address is 600 W 22" Street, Suite 101, Oak Brook, IL 60523. 2. Petitioner is the party of interest with respect to the property identified as tax parcel no. XT0-121-4600-00 (“subject property”), located in Lenawee County at 9000 N Union Street BLK, Tecumseh, Michigan.
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5. The subject property was not required to be protested before the March Board of Review. 6. Respondent, City of Tecumseh levies and collects the property taxes on the subject property. 7. In 2026, Respondent’s Board of Review established the following values for the subject property: True Cash Value Assessed Value Taxable Value 5,300,400 2,650,200 2,638,746 8. Petitioner contends the following are the proper values for the subject property: True Cash Value State Equalized Value Taxable Value 3,000,000 1,500,000 1,500,000 9. The values in dispute for the subject property are: True Cash Value State Equalized Value Taxable Value 2,300,400 1,150,200 1,138,746 10. This matter involves issues relating to: (a) true cash value, (b) taxable value, and (c) uniformity. 11. The assessment, including state equalized taxable values, imposed on the subject property and the taxes levied are unlawful and operate as a fraud upon Petitioners for the reasons that: a. The assessed, state equalized and taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes.
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d. The assessed, state equalized and taxable values are based on an erroneous determination of the true cash value of the subject property, and are based upon the application of wrong principles. Wherefore, Petitioner request that the Tax Tribunal enter an order reducing the true cash, assessed, state equalized, and taxable values of the subject property as Petitioner contends above, and order a refund with interest as provided by the Tax Tribunal Act. Taft Stettinius & Hollister LLP Mia izis L. Rider Brice, II 41) Dated: May 21, 2026 Attorneys for Petitioner
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Taft/ BRICE/shand 27777 Franklin Road, Suite 2500 Southfield, MI 48034-8214 Michigan Tax Tribunal p.0. Box 30232 Lansing, M! 48909"
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