Nreg US Holdings Ltd Petitioner Vs. Township Of Pittsfield 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

NOTICE OF JULY 16- 30, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

NREG US Holdings LTD,

Petitioner,

v

 

 

Township Of Pittsfield,

Respondent.

 MTT Docket No. 26-000825

Please be advised that 26-000825 has been placed on a two-week Prehearing General 

Call commencing July 16, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

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MTT Docket No. 26-000825

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IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by March 19, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by March 19, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 19, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

July 16, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time

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MTT

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STATE

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M

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S E C R E S T W A R D L E 

 STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

 

NREG US HOLDINGS LTD, 

 

Petitioner, 

MTT Docket No. 26-000825 

-vs- 

 

PITTSFIELD CHARTER TOWNSHIP, 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

HALLAHAN & ASSOCIATES, P.C. 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

lhallahan@hallahanlaw.com 

SECREST WARDLE 

Alana E. Knox (P85859) 

Attorney for Respondent 

2600 Troy Center Drive 

P.O. Box 5025 

Troy, MI 48007-5025 

(248) 851-9500 

aknox@secrestwardle.com 

_________________________________________________________________________________/ 

 

RESPONDENT’S AMENDED ANSWER TO PETITIONER’S PETITION 

(Entire Tribunal, 2026 Tax Year) 

(Amended - Address Only) 

 

 

NOW COMES Respondent, PITTSFIELD CHARTER TOWNSHIP, by and through its 

attorneys, SECREST WARDLE, and for its Answer to Petitioner’s Petition (Entire Tribunal, 2026 

Tax Year), states as follows: 

1. 

Answering paragraph 1, Respondent admits that the subject property consists of one 

parcel of commercial property. Respondent denies the location as 42955 Carpenter. Respondent 

states the location as 4955 Carpenter. Respondent admits the location is in Pittsfield Charter 

Township, in the Ann Arbor School District and is also identified as tax identification number L-12-

13-302-001. Respondent neither admits nor denies the remainder of the allegations contained in 

paragraph 1 for lack of sufficient knowledge or information upon which to form a belief and leaves

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S E C R E S T W A R D L E 

Petitioner to its proofs. Except for the change in the Petitioner’s address at issue, Respondent 

reaffirms and incorporates all of the admission, denials and affirmative defenses set forth on the 

original Answer filed July 20, 2026. 

2. 

Answering paragraph 2, Respondent states that there is no information to admit or deny 

in paragraph 2. 

 

3. 

Answering paragraph 3, Respondent admits the same. 

4. 

Answering paragraph 4, Respondent admits that Petitioner NREG US Holdings LTD, 

is the owner of the subject property known as 42955 Carpenter. Respondent neither admits nor denies 

the allegations contained in paragraph 4 for lack of sufficient knowledge or information upon which to 

form a belief and leaves Petitioner to its proofs. 

5. 

Answering paragraph 5, Respondent neither admits nor denies the allegations 

contained in paragraph 5 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

6. 

Answering paragraph 6, Respondent neither admits nor denies the allegations 

contained in paragraph 6 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

7. 

Answering paragraph 7, Respondent admits that the tax year at issue is 2026. 

8. 

Answering paragraph 8, Respondent admits that the subject property’s 2026 true cash, 

state equalized value and taxable value on the Respondent’s assessment roll are as follows: 

PARCEL NUMBER

TRUE CASH VALUE

STATE EQUALIZED 

VALUE 

TAXABLE VALUE 

L-12-13-302-001 

$6,133,392 

 $3,066,696 

$3,066,696 

which assessed valued will result in a state equalized value in the same amount based upon the 

tentative equalization factor. Respondent neither admits nor denies the remainder of the allegations

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3

S E C R E S T W A R D L E 

contained in paragraph 8 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

9. 

Answering paragraph 9, Respondent denies that the subject property’s 2026 true cash, 

state equalized value and taxable value on the Respondent’s assessment roll should be: 

PARCEL NUMBER

TRUE CASH VALUE

STATE EQUALIZED 

VALUE 

TAXABLE VALUE 

L-12-13-302-001 

$4,000,000 

 $2,000,000 

$1,000,000 

 

10. 

Answering paragraph 10, Respondent neither admits nor denies the allegations 

 

contained in paragraph 10, for lack of sufficient knowledge or information upon which to form a 

 

belief and leaves Petitioner to its proofs. 

 

11. 

Answering paragraph 11, including subparagraphs a. through d., Respondent denies the 

allegations contained therein for the reason that the same are untrue. 

 

 

 

WHEREFORE, Respondent, PITTSFIELD CHARTER TOWNSHIP, denies that Petitioner is 

entitled to the relief it seeks and respectfully requests that the Respondent’s assessments and taxable 

values of the subject property be affirmed or increased, that Petitioner’s Petition (Entire Tribunal, 

2026 Tax Year) be dismissed with prejudice and that Respondent be granted costs and attorney fees so 

wrongfully incurred in the defense of this matter. 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

 

BY: 

/s/ Alana E. Knox 

 

 

 

ALANA E. KNOX (P85859) 

 Attorney for Respondent 

 

 

 

 

 

 

 

2600 Troy Center Dr., P.O. Box 5025 

 

 

 

 

 

 

 

Troy, MI 48007-5025

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S E

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000825

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Pittsfield (WASHTENAW)

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

Alana

M.I.

E.

Last Name

Knox

Firm Name (if any)

Secrest Wardle

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

2600 Troy Center Drive

City or Town

Troy

State

 Michigan

ZIP Code

48007

Telephone Number

2488519500

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

aknox@secrestwardle.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Alana E. Knox

/s/

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S E C R E S T W A R D L E 

 STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

 

NREG US HOLDINGS LTD, 

 

Petitioner, 

MTT Docket No. 26-000825 

-vs- 

 

PITTSFIELD CHARTER TOWNSHIP, 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

HALLAHAN & ASSOCIATES, P.C. 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

lhallahan@hallahanlaw.com 

SECREST WARDLE 

Alana E. Knox (P85859) 

Attorney for Respondent 

2600 Troy Center Drive 

P.O. Box 5025 

Troy, MI 48007-5025 

(248) 851-9500 

aknox@secrestwardle.com 

_________________________________________________________________________________/ 

 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

 

NOW COMES Respondent, PITTSFIELD CHARTER TOWNSHIP, by and through its 

attorneys, SECREST WARDLE, and for its Answer to Petitioner’s Petition (Entire Tribunal, 2026 

Tax Year), states as follows: 

1. 

Answering paragraph 1, Respondent admits that the subject property consists of one 

parcel of commercial property located at 42955 Carpenter, Pittsfield Charter Township, in the Ann 

Arbor School District and is also identified as tax identification number L-12-13-302-001. 

Respondent neither admits nor denies the remainder of the allegations contained in paragraph 1 for 

lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its 

proofs. 

2. 

Answering paragraph 2, Respondent states that there is no information to admit or deny

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2

S E C R E S T W A R D L E 

in paragraph 2. 

 

3. 

Answering paragraph 3, Respondent admits the same. 

4. 

Answering paragraph 4, Respondent admits that Petitioner NREG US Holdings LTD, 

is the owner of the subject property known as 42955 Carpenter. Respondent neither admits nor denies 

the allegations contained in paragraph 4 for lack of sufficient knowledge or information upon which to 

form a belief and leaves Petitioner to its proofs. 

5. 

Answering paragraph 5, Respondent neither admits nor denies the allegations 

contained in paragraph 5 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

6. 

Answering paragraph 6, Respondent neither admits nor denies the allegations 

contained in paragraph 6 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

7. 

Answering paragraph 7, Respondent admits that the tax year at issue is 2026. 

8. 

Answering paragraph 8, Respondent admits that the subject property’s 2026 true cash, 

state equalized value and taxable value on the Respondent’s assessment roll are as follows: 

PARCEL NUMBER

TRUE CASH VALUE

STATE EQUALIZED 

VALUE 

TAXABLE VALUE 

L-12-13-302-001 

$6,133,392 

 $3,066,696 

$3,066,696 

which assessed valued will result in a state equalized value in the same amount based upon the 

tentative equalization factor. Respondent neither admits nor denies the remainder of the allegations 

contained in paragraph 8 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

9. 

Answering paragraph 9, Respondent denies that the subject property’s 2026 true cash, 

state equalized value and taxable value on the Respondent’s assessment roll should be:

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3

S E C R E S T W A R D L E 

PARCEL NUMBER

TRUE CASH VALUE

STATE EQUALIZED 

VALUE 

TAXABLE VALUE 

L-12-13-302-001 

$4,000,000 

 $2,000,000 

$1,000,000 

 

10. 

Answering paragraph 10, Respondent neither admits nor denies the allegations 

 

contained in paragraph 10, for lack of sufficient knowledge or information upon which to form a 

 

belief and leaves Petitioner to its proofs. 

 

11. 

Answering paragraph 11, including subparagraphs a. through d., Respondent denies the 

allegations contained therein for the reason that the same are untrue. 

 

 

 

WHEREFORE, Respondent, PITTSFIELD CHARTER TOWNSHIP, denies that Petitioner is 

entitled to the relief it seeks and respectfully requests that the Respondent’s assessments and taxable 

values of the subject property be affirmed or increased, that Petitioner’s Petition (Entire Tribunal, 

2026 Tax Year) be dismissed with prejudice and that Respondent be granted costs and attorney fees so 

wrongfully incurred in the defense of this matter. 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

 

BY: 

/s/ Alana E. Knox 

 

 

 

ALANA E. KNOX (P85859) 

 Attorney for Respondent 

 

 

 

 

 

 

 

2600 Troy Center Dr., P.O. Box 5025 

 

 

 

 

 

 

 

Troy, MI 48007-5025 

 

 

 

 

 

 

 

(248) 851-9500 

Dated: July 20, 2026 

 

 

 

aknox@secrestwardle.com 

 

 

 

 

AFFIRMATIVE DEFENSES 

 

 

For its further Answer to Petitioner’s Petition (Entire Tribunal, 2026 Tax Year) and by way of 

its Affirmative Defenses, Respondent respectfully requests unto this Honorable Tribunal as follows:

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S E C R E S T W A R D L E 

 

1. 

Petitioner

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5

S

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000825

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Pittsfield (WASHTENAW)

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

Alana

M.I.

E.

Last Name

Knox

Firm Name (if any)

Secrest Wardle

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

2600 Troy Center Drive

City or Town

Troy

State

 Michigan

ZIP Code

48007

Telephone Number

2488519500

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

aknox@secrestwardle.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Alana E. Knox

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NREG US Holdings Ltd, 

Petitioner, 

vs. 

Pittsfield Township, 

Respondent.

MTT Docket No. 26-000825 

_____________________________________________________________________________/ 

PROOF OF SERVICE 

(Property Tax Petition) 

On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: 

Township Assessor 

Pittsfield Township 

6201 W Michigan Ave 

Ann Arbor, MI 48108 

Township Supervisor 

Pittsfield Township 

6201 W Michigan Ave 

Ann Arbor, MI 48108 

On the date below I sent by first class mail a copy of the Petition to: 

Equalization Director 

Washtenaw County 

200 N Main St, Suite 210 

PO Box 8645 

Ann Arbor, MI 48107-8645 

County Clerk 

Washtenaw County 

200 N Main St 

Ann Arbor, MI 48104 

Secretary, Board of Education 

Ann Arbor Public Schools 

2555 S State St 

Ann Arbor, MI 48104

State Treasurer 

Department of Treasury 

430 W Allegan Street 

Lansing, MI 48922

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

/s/ Laura M. Hallahan 

Dated: July 15, 2025

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

NREG US HOLDINGS LTD, 

Petitioner, 

v 

PITTSIFIELD CHARTER TOWNSHIP, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-000825______ 

Parcel No. L-12-13-302-001 

_____________________________________________________________________________/ 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1.

☒ The property that is the subject of this appeal is one real property parcel:

Parcel Number 

L-12-13-302-001

Address 

42955 Carpenter 

Classification 

201-Commercial

Use 

Storage 

County 

Washtenaw 

Sch Dist Ann Arbor Public Schools 

2.

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s:

☐March, ☐ July, ☐ December Board of Review.

3.

Respondent, identified above, assesses and collects taxes on the subject property.

4.

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject

property.

5.

The Petitioner’s principal office/legal residence address is: Hugo Noort, Unit 101-403 6TH

Street, New Westminster, BC V3L 3B1.

6.

This appeal involves issues related to:

☒

the subject property’s true cash and taxable values

☐

the subject property’s taxable value only

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No

☐

uniformity of the subject property’s assessment

☐

the subject property’s exemption from ad valorem taxation under MCL ______

7.

The tax year at issue is 2026.

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Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

6,133,392 

3,066,696 

3,066,696 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

4,000,000 

2,000,000 

2,000,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

2,133,392 

1,066,696 

1,066,696 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioner’s property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

and 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 4

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 9, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $600

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000825

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Petition - POs

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

NREG US HOLDINGS LTD, 

 

Petitioner, 

 

v 

 

PITTSIFIELD CHARTER TOWNSHIP, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-_____________ 

Parcel No. L-12-13-302-001 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. 

☒ The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

L-12-13-302-001 

Address 

42955 Carpenter 

Classification 

201-Commercial 

Use 

Storage 

County 

Washtenaw 

Sch Dist Ann Arbor Public Schools 

 

2. 

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: Hugo Noort, Unit 101-403 6TH 

Street, New Westminster, BC V3L 3B1. 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ 

uniformity of the subject property’s assessment 

☐ 

the subject property’s exemption from ad valorem taxation under MCL ______ 

7. 

The tax year at issue is 2026.

Page 2

Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

6,133,392 

3,066,696 

3,066,696 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

4,000,000 

2,000,000 

2,000,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

2,133,392 

1,066,696 

1,066,696 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioner’s property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

and 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 9, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $600

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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Hallahan & Associates PC

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302-2073

Telephone Number

2487018529

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

lhallahan@hallahanlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Halahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

22

ZIP Code

48302-2073

Telephone Number

2487313090

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

lhallahan@hallahanlaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

42955 Carpenter

Pittsfield Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

48108-9721

Taxing Authority (City or Township)

Township Of Pittsfield (WASHTENAW) 

County

Washtenaw

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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

L-12-13-302-001

Classification of Property: Real (check one)

Commercial (check one)

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

3066696

Current Taxable Value as established by the Board of Review:

3066696

What do you believe is the fair market value (also known as True Cash Value)?

4000000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

2000000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

2000000

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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/ Laura M. Hallahan

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26050984706269

Supporting Waiver Documents:

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

NREG US Holdings LTD, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000825

Township Of Pittsfield, 

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: June 16, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 

NREG US HOLDINGS LTD, 

 

Petitioner, 

 

v 

 

PITTSIFIELD CHARTER TOWNSHIP, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 26-_____________ 

Parcel No. L-12-13-302-001 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2026 Tax Year) 

 

Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 

1. 

☒ The property that is the subject of this appeal is one real property parcel: 

Parcel Number 

L-12-13-302-001 

Address 

42955 Carpenter 

Classification 

201-Commercial 

Use 

Storage 

County 

Washtenaw 

Sch Dist Ann Arbor Public Schools 

 

2. 

☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: 

☐ March, ☐ July, ☐ December Board of Review. 

3. 

Respondent, identified above, assesses and collects taxes on the subject property. 

4. 

Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

5. 

The Petitioner’s principal office/legal residence address is: Hugo Noort, Unit 101-403 6TH 

Street, New Westminster, BC V3L 3B1. 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ 

uniformity of the subject property’s assessment 

☐ 

the subject property’s exemption from ad valorem taxation under MCL ______ 

7. 

The tax year at issue is 2026.

Page 2

Petition 

2 

8. 

The values1 established by Respondent’s Board of Review for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

6,133,392 

3,066,696 

3,066,696 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

4,000,000 

2,000,000 

2,000,000 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

L-12-13-302-001 

2,133,392 

1,066,696 

1,066,696 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons 

that: 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts permitted 

by the Michigan Constitution and applicable statutes; 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages of true 

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

The assessed, state equalized and/or taxable values are based upon an erroneous 

determination of the true cash value of that portion of Petitioner’s property that is 

taxable under Michigan law and are based upon the application of wrong principles; 

and 

(d) 

The assessed, state equalized and/or taxable values, and the mode of assessment 

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established 

by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable 

to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

1TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 3

Petition 

3 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: May 9, 2026 

lhallahan@hallahanlaw.com 

 

Filing Fee: $600

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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Hallahan & Associates PC

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302-2073

Telephone Number

2487018529

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

lhallahan@hallahanlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Halahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

22

ZIP Code

48302-2073

Telephone Number

2487313090

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

lhallahan@hallahanlaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

42955 Carpenter

Pittsfield Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

48108-9721

Taxing Authority (City or Township)

Township Of Pittsfield (WASHTENAW) 

County

Washtenaw

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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

L-12-13-302-001

Classification of Property: Real (check one)

Commercial (check one)

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

3066696

Current Taxable Value as established by the Board of Review:

3066696

What do you believe is the fair market value (also known as True Cash Value)?

4000000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

2000000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

2000000

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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/ Laura M. Hallahan

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26050984706269

Supporting Waiver Documents:

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.