Record Finder / 25-002498-TT
Michigan
Partridge Creek Senior Living LLC, Petitioner Vs. Township Of Clinton, Respondent
- Petitioner
- Partridge Creek Senior Living LLC
- Respondent
- Township Of Clinton
Case overview
- Docket number
- 25-002498-TT
- Status
- Abeyance
- CaseType
- ET Property
- Division
- ET
- County
- Macomb
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 11 | A response to motion was filed. | RESP | Not recorded | 05/20/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 10 | Motion to Amend Subsequent Year was received. | PET | Not recorded | 04/29/2026 | $300.00 | Download |
| 9 | Granted | PET | 7 | 10/22/2025 | Not recorded | Download |
| 8 | Order granting Motion. | Not recorded | 7 | 10/22/2025 | Not recorded | Download |
| 7 | Motion for Abeyance was received. | PET | Not recorded | 10/20/2025 | $50.00 | Download |
| 6 | Answer was received | Not recorded | Not recorded | 08/03/2025 | Not recorded | Download |
| 5 | ET Case Info Sheet | Not recorded | Not recorded | 08/03/2025 | Not recorded | Download |
| 4 | Notice of Docket Number ET | Not recorded | Not recorded | 07/10/2025 | Not recorded | Download |
| 3 | Proof of service of petition was received. | PET | Not recorded | 07/07/2025 | Not recorded | Download |
| 2 | A petition has been filed. | PET | Not recorded | 07/01/2025 | Not recorded | Download |
| 1 | Order Severing 2025 Tax Year from 24-001683 | Not recorded | Not recorded | 06/25/2025 | Not recorded | Download |
Documents
MTA 2026 Response_Partridge Creek_FINAL.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL PARTRIDGE CREEK SENIOR LIVING, LLC, Petitioner, v CLINTON CHARTER TOWNSHIP, Respondent. Docket No. 25-002498 Parcel No. 16-11-05-100-060 _____________________________________________________________________________/ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7420 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ RESPONDENT’S ANSWER TO PETITIONER’S MOTION TO AMEND PETITION TO CONTEST 2026 ASSESSED AND TAXABLE VALUES Respondent, Clinton Charter Township, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Motion to Amend as follows: 1. Respondent admits the allegations in Paragraph 1. 2. Respondent admits the allegations in Paragraph 2. 3. Respondent denies the allegations in Paragraph 3, including subparagraphs (a)-(c), 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
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2 principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 4. Respondent acknowledges the relief requested by Petitioner in the final paragraph of the Motion but denies that Petitioner is entitled to the requested relief due to the statements in the above Paragraphs. Respondent incorporates by reference the affirmative defenses set forth in its Answer to Petition herein. WHEREFORE, Respondent, Clinton Charter Township, requests the Tribunal enter an Order Denying Petitioner’s Motion to Amend and dismissing the appeal. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan______________ 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: May 20, 2026 (248) 731-3089
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3 PROOF OF SERVICE On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to Petitioner’s Motion to Amend to: Stewart L. Mandell Honigman LLP slmandell@honigman.com Daniel L. Stanley Honigman LLP dstanley@honigman.com I declare that the statement above is true to the best of my information, knowledge and belief. /s/Kelsea M. Melcher_____________ Dated: May 20, 2026 Kelsea M. Melcher
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MITAT_SubsequentFiling.pdfRead complete document text →
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1 of 1 Docket #: 25-002498 Party Filing Document Party Filing Document: Respondent Respondent If 'other', Identify: File Document Type: fuFile:
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25-002498.pdfRead complete document text →
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wl 6C RECEIVED APR 29 2026 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AMFA#IREN TAX TRIBUNAL MICHIGAN TAX TRIBUNAL Partridge Creek Senior Living, LLC, Petitioner, v MTT Docket No. 25-002498 Clinton Twp., Respondent. / Stewart L. Mandell (P33781) Laura M. Hallahan (P42101) Daniel L. Stanley (P57052) Seth A. O’Loughlin (P80257) Honigman LLP Kelsea M. Melcher (P85821) Attorneys for Petitioner Hallahan & Associates, P.C. 2290 First National Building Attorneys for Respondent 660 Woodward Avenue 1750 S. Telegraph Road, Suite 202 Detroit, MI 48226-3506 Bloomfield Hills, MI 48302 (313) 465-7420 (248) 731-3089 slmandell@honigman.com lhallahan@hallahanlaw.com dstanley@honigman.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com Motion to Amend Petition to Contest 2026 Assessed and Taxable Values Petitioner, Partridge Creek Senior Living, L.L.C., through its attorneys, Honigman LLP, moves to amend the Petition in this matter to include the following: l. The Petition in this case stated that the property involved has tax parcel
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2. In 2026, Respondent determined the taxable value of Petitioner's Property to be $13,224,100 and Respondent assessed Petitioner’s Property at $13,224,100, which will result in a state equalized value of the same amount, based upon the tentative equalization factor. 3. The 2026 taxable value imposed on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and unlawful for the reasons that: (a) The 2026 taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 2026 taxable value discriminates against Petitioner and denies Petitioner its constitutional rights to equal protection and due process of law; and (c) The 2026 taxable value is based upon the application of wrong principles. WHEREFORE, Petitioner asks that this Motion be granted, and Petitioner requests that the Tribunal enter an Order: (i) reducing the 2026 taxable value from $13,224,100 to $11,663,089; (ii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is entitled. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner Stewart L. Mandell (P33781) Daniel L. Stanley (P57052) 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Partridge Creek Senior Living, LLC, Petitioner, v Clinton Twp., MTT Docket No. 25-002498 Respondent. / Stewart L. Mandell (P33781) Laura M. Hallahan (P42101) Daniel L. Stanley (P57052) Seth A. O’Loughlin (P80257) Honigman LLP Kelsea M. Melcher (P85821) Attorneys for Petitioner Hallahan & Associates, P.C. 2290 First National Building Attorneys for Respondent 660 Woodward Avenue 1750 S. Telegraph Road, Suite 202 Detroit, MI 48226-3506 Bloomfield Hills, MI 48302 (313) 465-7420 (248) 731-3089 slmandell@honigman.com lhallahan@hallahanlaw.com dstanley@honigman.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com / Proof of Service Lisa Joseph affirms that on April 29, 2026 she served a copy of Petitioner's Motion to Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service in connection with the above-entitled cause upon the following: Laura M. Hallahan (P42101) Seth A. O'Loughlin (P80257) Kelsea M. Melcher (P85821) Hallahan & Associates, P.C. Attorneys for Respondent lhallahan@hallahanlaw.com
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Honaman LLP COSTS ADVANCED ACCOUNT 0 4 0 7 an Invoice Date Invoice Number Invoice Narrative Payment Amount 4/29/26 040700 262006/395453/DLS #E$$300,00%%% Motion to Amend Filing Fee 210746781
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Joint Motion for Abeyance - Partridge Senior Clinton (25-002498).pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL PARTRIDGE CREEK SENIOR LIVING, LLC, Petitioner, v CLINTON CHARTER TOWNSHIP Respondent. Docket No. 25-002498 _____________________________________________________________________________/ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-001683 The parties, by and through their respective counsel, state the following in support of the above captioned Joint Motion: 1. The above captioned appeal concerns the 2025 valuation of Parcel No. 16-11-05- 100-060 (the “Property”), located in Macomb County. This 2025 appeal has not yet been placed on a Prehearing General Call and Order of Procedure. 2. In MTT Docket No. 24-001683 (the “2024 Case”), the valuation of the Property is also at issue and valuation disclosures are currently due on November 17, 2025. With the
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62482872.1 2 exception of the tax year at issue, based on the pleadings filed to date, the parties, the Property, and issues raised in the 2024 Case and this case are substantially the same, if not identical. 3. The prosecution of this case will require the Parties and the Tribunal to expend substantial resources. Yet, it is quite likely that the resolution of the 2024 Case would have an important impact on this 2025 appeal. Therefore, not putting this case in abeyance could result in a tremendous waste of time and resources for the Parties and the Tribunal. 4. Given the foregoing, to proceed with this case before the resolution of the 2024 Case would not constitute an efficient administration of justice. 5. Placing this Case in abeyance at this juncture before substantial time and resources have been spent – including, but not limited to, the completion of appraisals – is in the interest of efficiency and judicial economy for the Tribunal and the Parties. 6. Granting this joint motion is proper under Tax Tribunal Act, MCL 205.732(c), which provides in pertinent part: "The tribunal's powers include, but are not limited to, all of the following: ... (c) Granting other relief or issuing writs, orders, or directives that it deems necessary or appropriate in the process of disposition of a matter over which it may acquire jurisdiction.” 7. Granting this Joint Motion will serve the interests of justice. 8. Indeed, in many similarly situated cases the Tribunal has granted the relief requested herein. 9. All of the foregoing establish that there is good cause for the Tribunal to grant this Joint Motion. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding this case in abeyance pending the resolution of MTT Docket No. 24-001683.
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62482872.1 3 Respectfully submitted, HONIGMAN LLP /s/ Stewart L. Mandell________________ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 Dated: October 20, 2025 HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan______________ 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 (248) 731-3089 Dated: October 20, 2025
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25-002498 Abeyance Grant.pdfRead complete document text →
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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 Partridge Creek Senior Living LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-002498 Clinton Township, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE On October 20, 2025, the parties filed a joint motion requesting that the Tribunal hold this case in abeyance pending resolution of MTT Docket No. 24-001683, which is currently pending before the Tribunal. In the motion, the parties state that the above- mentioned case pertains to the same parties, property, and claims as the subject appeal, and its resolution could impact the proceedings in this matter. MTT Docket No. 24-001683 currently has valuation disclosures and prehearing statements due on November 17, 2025, however, this case has not been placed on a Prehearing General Call and Order of Procedure. Proceeding with this matter could waste time and resources for both the parties and the Tribunal while MTT Docket No. 24-001683 remains pending. The Tribunal has considered the motion and the case file and finds that placing this case in abeyance pending resolution of MTT Docket No. 24-001683 will facilitate the efficient administration of justice, as that resolution may have a direct bearing on the outcome of the instant appeal. Therefore, IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 days of the resolution of MTT Docket No. 24-001683 as to the need for further proceedings in this matter. Entered: October 22, 2025 By _____________________________ cs PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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Joint Motion for Abeyance - Partridge Senior Clinton (25-002498).pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL PARTRIDGE CREEK SENIOR LIVING, LLC, Petitioner, v CLINTON CHARTER TOWNSHIP Respondent. Docket No. 25-002498 _____________________________________________________________________________/ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-001683 The parties, by and through their respective counsel, state the following in support of the above captioned Joint Motion: 1. The above captioned appeal concerns the 2025 valuation of Parcel No. 16-11-05- 100-060 (the “Property”), located in Macomb County. This 2025 appeal has not yet been placed on a Prehearing General Call and Order of Procedure. 2. In MTT Docket No. 24-001683 (the “2024 Case”), the valuation of the Property is also at issue and valuation disclosures are currently due on November 17, 2025. With the
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62482872.1 2 exception of the tax year at issue, based on the pleadings filed to date, the parties, the Property, and issues raised in the 2024 Case and this case are substantially the same, if not identical. 3. The prosecution of this case will require the Parties and the Tribunal to expend substantial resources. Yet, it is quite likely that the resolution of the 2024 Case would have an important impact on this 2025 appeal. Therefore, not putting this case in abeyance could result in a tremendous waste of time and resources for the Parties and the Tribunal. 4. Given the foregoing, to proceed with this case before the resolution of the 2024 Case would not constitute an efficient administration of justice. 5. Placing this Case in abeyance at this juncture before substantial time and resources have been spent – including, but not limited to, the completion of appraisals – is in the interest of efficiency and judicial economy for the Tribunal and the Parties. 6. Granting this joint motion is proper under Tax Tribunal Act, MCL 205.732(c), which provides in pertinent part: "The tribunal's powers include, but are not limited to, all of the following: ... (c) Granting other relief or issuing writs, orders, or directives that it deems necessary or appropriate in the process of disposition of a matter over which it may acquire jurisdiction.” 7. Granting this Joint Motion will serve the interests of justice. 8. Indeed, in many similarly situated cases the Tribunal has granted the relief requested herein. 9. All of the foregoing establish that there is good cause for the Tribunal to grant this Joint Motion. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding this case in abeyance pending the resolution of MTT Docket No. 24-001683.
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62482872.1 3 Respectfully submitted, HONIGMAN LLP /s/ Stewart L. Mandell________________ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 Dated: October 20, 2025 HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan______________ 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 (248) 731-3089 Dated: October 20, 2025
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Answer 25-002498.pdfRead complete document text →
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL PARTRIDGE CREEK SENIOR LIVING, LLC, Petitioner, v CLINTON CHARTER TOWNSHIP Respondent. Docket No. 25-002498 Parcel No. 16-11-05-100-060 _____________________________________________________________________________/ STEWART L. MANDELL (P33781) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ ANSWER TO SEVERED PETITION AND AFFIRMATIVE DEFENSES ANSWER Respondent, Clinton Charter Township, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent admits the allegations in Paragraph 1 as to the relevant tax year, the parcel number, and the location of said parcel. Respondent lacks the knowledge and information necessary to respond to the remainder of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs.
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2. Respondent admits the allegations in Paragraph 2 insofar as it is the entity that assesses and collects property taxes with relation to the parcel identified in the Petition. 3. Respondent admits the allegations in Paragraph 3 as to the stated values. With respect to the remaining allegations in Paragraph 3, Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained therein and leaves Petitioner to its proofs. 4. Respondent admits that subject property is classified as commercial real. With respect to the remaining allegations in Paragraph 4, Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained therein and leaves Petitioner to its proofs. 5. Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies that Petitioner’s claims have merit and denies that Petitioner is entitled to any relief. 6. Respondent acknowledges Petitioner’s belief relative to the value of a loss but denies any such loss has occurred. 7. Respondent admits the allegations in Paragraph 7. 8. Respondent denies the allegations in Paragraph 8, including subparagraphs (a)-(d), 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.
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9. 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. WHEREFORE, Respondent, Clinton Charter Township, 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 3, 2025 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent, Clinton Charter Township, 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.
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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
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H
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10._Entire_Tribunal_Case_Information_Sheet_Must_Upload_Answer_.a68eecb6-98a4-48e3-ba58-72704f9e1459.pdfRead complete document text →
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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. 25-002498 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Township Of Clinton (MACOMB) 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 Laura M.I. M Last Name Hallahan Firm Name (if any) 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 Telephone Number 248-731-3087 Fax Number 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: Seth A. O'Loughlin /s/
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ET_Notice_of_Docket_Number.2025-07-10_13-27-52.0000.pdfRead complete document text →
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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 Partridge Creek Senior Living LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002498 Township Of Clinton, 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 10, 2025 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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Proof of Service.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Partridge Creek Senior Living, L.L.C., Petitioner, Vv. MTT Docket No. 25-002498 Clinton Twp., Parcel No. 16-11-05-100-060 Respondent. Stewart L. Mandell (P33781) Laura M. Hallahan (P42101) Honigman LLP Seth A. O’Loughlin (P80257) Attorneys for Petitioner Kelsea M. Melcher (P85821) 39400 Woodward Avenue, Suite 101 Hallahan & Associates, P.C. Bloomfield Hills, MI 48304-5151 Attorneys for Respondent (313) 465-7420 1750 S. Telegraph Rd., Suite 202 slmandell@honigman.com Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com r@hallahanlaw.com Proof of Service Lisa Joseph states that on 7 ii Zz / 25 . she did serve a copy of the Petition, with docket number, upon the parties named on the attached list. Dated: // wi / 2 Ss Lisa Joseph 61094611.2
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BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK CLINTON TWP. - MACOMB 40700 ROMEO PLANK ROAD CLINTON TWP., MI 48038-2917 ASSESSOR CLINTON TWP. - MACOMB 40700 ROMEO PLANK ROAD CLINTON TWP., MI 48038-2917 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK MACOMB COUNTY ATTN: F. KRYCIA ADM BLDG. 1 S. MAIN ST., 8TH FLOOR MT. CLEMENS, MI 48043 DIRECTOR OF EQUALIZATION MACOMB COUNTY ATTN: F. KRYCIA ADM BLDG. 1 S. MAIN ST., 8TH FLOOR MT. CLEMENS, MI 48043 SECRETARY OF SCHOOL BOARD CHIPPEWA VALLEY SCHOOLS 19120 CASS AVENUE CLINTON TWP., MI 48038-2900 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 25-0089 61094611.2
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Petition 2025 (per Sever Order) Partridge Creek Clinton Twp. (25-002498).pdfRead complete document text →
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
Partridge Creek Senior Living, L.L.C.,
Petitioner,
v.
Clinton Twp.,
Respondent.
MTT Docket No. 25-002498
Parcel No. 16-11-05-100-060
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
Laura M. Hallahan (P42101)
Seth A. O’Loughlin (P80257)
Kelsea M. Melcher (P85821)
Hallahan & Associates, P.C.
Attorneys for Respondent
1750 S. Telegraph Rd., Suite 202
Bloomfield Hills, MI 48302
(248) 731-3089
lhallahan@hallahanlaw.com
soloughlin@hallahanlaw.com
kmelcher@hallahanlaw.com
Petition
Partridge Creek Senior Living, L.L.C. (“Petitioner”), through its attorneys, HONIGMAN
LLP, says:
1.
Petitioner is filing this Petition for the 2025 tax year, pursuant to the Tribunal’s
June 25, 2025 Order entered in MTT Docket No. 24-001683. Petitioner's principal office address
is 38525 Woodward Avenue, Bloomfield Hills, MI 48304. Petitioner is a party in interest with
respect to property taxes on tax parcel number 16-11-05-100-060 ("Petitioner's Property"), also
known as Partridge Creek Senior Living at 44003 Partridge Creek Blvd. located in Macomb
County, Michigan.Page 2
61094611.2 2. Respondent, Clinton Twp., assesses and collects property taxes on Petitioner's Property. 3. In 2025, Respondent determined the taxable value of Petitioner's Property to be $13,224,100 and assessed Petitioner's Property at $13,224,100, which has resulted in a state equalized value in the same amount based upon the tentative equalization factor. 4. Petitioner's Property is classified as commercial real. 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, (c) taxable value and (d) uniformity. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. No March Board of Review protest was required for Petitioner’s Property. 8. The 2025 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, is at a higher percentage of true cash value than permissible under the Michigan Constitution and applicable statutes;
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61094611.2 (c) The assessment, including taxable value and/or state equalized value, is based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and is based upon the application of wrong principles; and, (d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 2025 assessed value, state equalized value and taxable value of Petitioner's Property from $13,224,100 to $9,500,000; (ii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is entitled. Dated: July 1, 2025 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioners By: Stewart L. Mandell (P33781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7420 slmandell@honigman.com
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24-001683 MTA grant and Sever.pdfRead complete document text →
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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 Partridge Creek Senior Living LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 24-001683 & 25-002498 Clinton Township, Presiding Judge Respondent. Jason C. Grinnell ORDER GRANTING PETITIONER’S MOTION TO AMEND ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT DOCKET NUMBER 25-002498 On May 30, 2025, Petitioner filed a motion requesting that the Tribunal permit them to amend the petition filed in this case to include the 2025 tax year. On June 20, 2025, Respondent filed a response to the motion. In the response, Respondent states that valuation disclosures and prehearing statements are scheduled to be exchanged on November 17, 2025, and “[t]here is not sufficient time for Respondent to conduct discovery or prepare a valuation disclosure relevant to the 2025 tax year.” Additionally, Respondent requests that the 2025 tax year be severed and assigned a new docket number. The Tribunal has considered the motion, the response, and case file and finds that Petitioner timely filed its Motion to Amend, included the necessary information and filing fee, and otherwise met all requirements, as set forth in MCL 205.737 and MCL 205.735a. Due to the stage in which this case is at, however, and in the interest of judicial efficiency, the 2025 tax year shall be severed from this case and assigned to a new docket number. Therefore, IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. IT IS FURTHER ORDERED that Petitioner’s assessment appeal for the 2025 tax year is SEVERED and ASSIGNED to Docket No. 25-002498. IT IS FURTHER ORDERED that Petitioner shall file a petition pertaining to the 2025 tax year within 21 days of the entry of this order.1 The petition shall note the docket number 1 See TTR 233.
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MTT Docket No. 24-001683 & 25-002498 Page 2 of 2 assigned by the Tribunal for the 2025 tax year and if filed utilizing the Tribunal’s e-filing system, must be filed on the assigned 2025 docket number as a “Severed Petition.”2 IT IS FURTHER ORDERED that the Tribunal shall issue a Notice of Docket after receipt of the petition for the 2025 tax year. Failure to comply with this order may result in dismissal of the appeal for the 2025 tax year.3 Entered: June 25, 2025 By _______________________________ kac/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 2 Alternatively, the petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933. 3 See TTR 237.
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