Pogue Properties LLC, Petitioner Vs. City Of Detroit, Respondent

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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

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

Pogue Properties LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001834 

 

City of Detroit, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

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

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

 

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

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

indicated. 

 

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

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

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

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

 

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

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

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

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

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

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

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

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

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

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

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

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

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

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after 

December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 

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

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001834 

Page 2 of 2 

 

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

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

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

8.66%, and (ix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 

 

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

 

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

 

 

 

 

 

 

 

 

 

By _____________________________ 

Entered: January 30, 2026 

sb 

 

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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Page 1

POGUE PROPERTIES, LLC, 

Petitioner, 

v. 

CITY OF DETROIT, 

Respondent. 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

MTT Docket No. 25-001834 

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

2. 

Property Parcel Nos: 08004470-1 and 08004371-83. 

3. 

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

Review are; 

Parcel Number 

Tax Year 

True Cash Value 

| Assessed Value 

Taxable Value 

08004470-1 

2025 

$169,200 

$84,600 

$84,600 

08004371-83 

2025 

$39,468 

$19,734 

$19,734 

4. 

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

purposes are: 

Parcel Number 

Tax Year 

True Cash Value 

| Assessed Value 

Taxable Value 

08004470-1 

2025 

$85,000 

$42,500 

$42,500 

08004371-83 

2025 

$15,000 

$7,500 

$7,500 

5. 

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

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

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

years: 

6. 

4938-6396-4299.1 

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

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

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

Page 2

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall 

be made payable jointly to Petitioner named herein and its 

counsel, 

Foley & Lardner LLP, and sent 

in care of such 

counsel. Calculations of the refund amount shall also be sent 

to Petitioner's counsel at the same address. 

IT IS FURTHER ORDERED AND ADJUDGED that all interest 

due hereunder is waived if, and only if, all refunds otherwise 

due are made within 90 days of the date of entry of the Consent 

Judgment. 

FOLEY & LARDNER LLP 

Attorneys Petitioner 

By:__/s/ Jason Conti 

Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7177 

Dated: January 26, 2026 

4938-6396-4299.1 

CITY OF DETROIT LAW 

Attorneys for Respondent 

Revi Richard 

Kevin Richard (P43417) 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3039 

Dated: January 26, 2026 

ail 

i 

v a 0), <tt> : A 

Alvin Horhn, Deputy CFO, Assessor 

CAYMC 

- 2 Woodward Avenue 

Suite 824 

Detroit, Michigan 48226 

(313) 224-3052 

Dated: D9 

dred 

2 26

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Page 1

POGUE PROPERTIES, LLC, 

Petitioner, 

v. 

CITY OF DETROIT, 

Respondent. 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

MTT Docket No. 25-001834 

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

2. 

Property Parcel Nos: 08004470-1 and 08004371-83. 

3. 

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

Review are; 

Parcel Number 

Tax Year 

True Cash Value 

| Assessed Value 

Taxable Value 

08004470-1 

2025 

$169,200 

$84,600 

$84,600 

08004371-83 

2025 

$39,468 

$19,734 

$19,734 

4. 

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

purposes are: 

Parcel Number 

Tax Year 

True Cash Value 

| Assessed Value 

Taxable Value 

08004470-1 

2025 

$85,000 

$42,500 

$42,500 

08004371-83 

2025 

$15,000 

$7,500 

$7,500 

5. 

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

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

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

years: 

6. 

4938-6396-4299.1 

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

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

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

Page 2

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall 

be made payable jointly to Petitioner named herein and its 

counsel, 

Foley & Lardner LLP, and sent 

in care of such 

counsel. Calculations of the refund amount shall also be sent 

to Petitioner's counsel at the same address. 

IT IS FURTHER ORDERED AND ADJUDGED that all interest 

due hereunder is waived if, and only if, all refunds otherwise 

due are made within 90 days of the date of entry of the Consent 

Judgment. 

FOLEY & LARDNER LLP 

Attorneys Petitioner 

By:__/s/ Jason Conti 

Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7177 

Dated: January 26, 2026 

4938-6396-4299.1 

CITY OF DETROIT LAW 

Attorneys for Respondent 

Revi Richard 

Kevin Richard (P43417) 

CAYMC - 2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3039 

Dated: January 26, 2026 

ail 

i 

v a 0), <tt> : A 

Alvin Horhn, Deputy CFO, Assessor 

CAYMC 

- 2 Woodward Avenue 

Suite 824 

Detroit, Michigan 48226 

(313) 224-3052 

Dated: D9 

dred 

2 26

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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

NOTICE OF DECEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

Pogue Properties LLC,

Petitioner,

v

 

 

City of Detroit,

Respondent.

 MTT Docket No. 25-001834

Please be advised that 25-001834 has been placed on a two-week Prehearing General 

Call commencing December 16, 2026. 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.

Page 2

MTT Docket No. 25-001834

Page 2 of 3

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 August 19, 2026. 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 August 19, 2026. 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 

August 19, 2026, 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 

December 16, 2026, 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”

Page 3

MTT

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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

Pogue Properties LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001834

City of Detroit,

Respondent.

ORDER SETTING ASIDE DEFAULT

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

Respondent was held in default on October 9, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: November 6, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Pogue Properties LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001834

City of Detroit,

Respondent.

ORDER SETTING ASIDE DEFAULT

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

Respondent was held in default on October 9, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: November 6, 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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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

POGUE PROPERTIES, LLC, 

 

Petitioner, 

v. 

Docket No. 25-001834 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

ANSWER 

 

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

states as follows: 

1. Respondent admits. 

 

2. Respondent admits. 

 

3. Respondent admits as to Parcel# 08004470-1, however denies as untrue as to Parcel# 

08004371-83 which has assessed and taxable values of $15,900. 

4. Respondent admits. 

 

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

involving valuation, assessment, taxable value and uniformity, however, Respondent 

denies that any such allegations have merit. 

6. Respondent neither admits nor denies the allegations, there being an insufficient basis 

at this time upon which to form a belief as to the truth of the allegation. 

7. Respondent admits. 

 

8. Respondent denies as untrue.

Page 2

2 

 

AFFIRMATIVE DEFENSES 

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

 

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

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

 

3. Petitioner lacks standing. 

 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

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

Respectfully Submitted, 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Mary Beth Cobbs (P40080) 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3061 

Dated: October 15, 2025

Page 3

3 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

POGUE PROPERTIES, LLC, 

 

Petitioner, 

v. 

Docket No. 25-001834 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

PROOF OF SERVICE 

 

On October 15, 2025, I mailed by first class mail a copy of Respondent’s Answer with Affirmative 

Defenses in the instant matter to: 

 

Jason Conti 

Foley & Lardner LLP 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

 

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

 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Senior Assistant Corporation Counsel 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Dated: October 15, 2025 

Detroit, Michigan 48226

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001834

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City of Detroit (Wayne)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Kevin

M.I.

C

Last Name

Richard

Firm Name (if any)

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

2 Woodward Avenue, Suite 500

City of Detroit Law Department

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-237-3061

Fax Number

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

richkc@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kevin C Richard

/s/

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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

Pogue Properties LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001834

City of Detroit,

Respondent.

ORDER OF DEFAULT

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

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.i 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: October 9, 2025

Patricia L. Halm, Tribunal Chair

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

i “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received.

Page 2

MTT Docket No. 25-001834

Page 2 of 6

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5)

Page 3

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

Pogue Properties LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-001834

City of Detroit,

Respondent.

ORDER OF DEFAULT

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

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.ii 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By:_______________________________

Entered: October 9, 2025

Patricia L. Halm, Tribunal Chair

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

ii “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is

Page 4

MTT

Page 5

STA

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Page 1

4910-7329-0580.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

POGUE PROPERTIES, LLC, 

 

 

 

MTT Docket No. 25-001834 

 

 

 

 

 

 

 

 

 

Parcel Nos. 08004470-1 

 

 

Petitioner, 

 

 

 

 

 08004371-83 

 

v 

 

CITY OF DETROIT, 

 

 

 

Respondent. 

 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

_____________________________________________/ 

 

PROOF OF SERVICE 

 

On August 26, 2025, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for the 2025 Tax Year, Notice of Docket Number, and this Proof of Service on: 

Wayne County Clerk 

Two Woodward Avenue 

Detroit, Michigan 48226 

 

 via U.S. mail 

Wayne County Equalization 

Director 

500 Griswold 

Detroit, Michigan 48226 

 

via U.S. mail

Detroit School Board 

Secretary 

3011 W. Grand Boulevard 

Detroit, Michigan 48202 

 

via U.S. mail

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

 

 via U.S. mail 

 

 

 

City Clerk 

CAYMC 

Two Woodward Avenue 

Suite 120 

Detroit, Michigan 48226 

 

 via Certified Mail 

 

City of Detroit Assessor 

CAYMC 

Two Woodward Avenue 

Suite 120 

Detroit, Michigan 48226 

 

 via Certified Mail

Page 2

2 

4910-7329-0580.1 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: /s/ Jason Conti (P55617) 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

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Page 1

1 

4937-2086-2535.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

POGUE PROPERTIES, LLC, 

 

 

 

MTT Docket No. _____________ 

 

 

 

 

 

 

 

Parcel Nos. 08004470-1 

Petitioner, 

 

 

 

 

 08004371-83 

 

 

 

v 

 

CITY OF DETROIT, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2025 TAX YEAR 

 

 

POGUE PROPERTIES, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, states: 

 

1. 

Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, 

Michigan 48075. Petitioner is a party in interest with respect to property taxes on contiguous real property 

tax parcel nos. 08004470-1 and 08004371-83 (collectively, the “Subject Property”), also known as 2251 W 

Davison, Detroit, Michigan. 

 

2. 

Respondent City of Detroit (“Respondent”) assesses and collects property taxes on the 

Subject Property. 

 

3. 

In 2025, Respondent determined the taxable and assessed values of the Subject Property 

to be as follows (which will result in a state equalized value in the same amount based upon the tentative 

equalization factor): 

Parcel No. 

AV 

TV 

08004470-1 

$84,600 

$84,600 

08004371-83 

$19,734 

$19,734

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2 

4937-2086-2535.1 

. 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject 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. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March, 2025. 

 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed on the 

Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as 

a fraud upon the taxpayer 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, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and applicable 

statutes; 

 

 

(c) 

The assessment, including taxable value and/or state equalized value, are based 

upon an erroneous determination of the true cash value of that portion of the Subject Property that is 

taxable under Michigan law, and are 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.

Page 3

3 

4937-2086-2535.1 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2024 taxable 

values and state equalized values of the Subject Property as follows: 

Parcel No. 

AV 

TV 

08004470-1 

$10,000 

$10,000 

08004371-83 

$2,000 

$2,000 

 

and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and 

costs. 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 30, 2025

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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

Pogue Properties LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001834

City of Detroit, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: July 24, 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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Page 1

1 

4937-2086-2535.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

POGUE PROPERTIES, LLC, 

 

 

 

MTT Docket No. _____________ 

 

 

 

 

 

 

 

Parcel Nos. 08004470-1 

Petitioner, 

 

 

 

 

 08004371-83 

 

 

 

v 

 

CITY OF DETROIT, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2025 TAX YEAR 

 

 

POGUE PROPERTIES, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, states: 

 

1. 

Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, 

Michigan 48075. Petitioner is a party in interest with respect to property taxes on contiguous real property 

tax parcel nos. 08004470-1 and 08004371-83 (collectively, the “Subject Property”), also known as 2251 W 

Davison, Detroit, Michigan. 

 

2. 

Respondent City of Detroit (“Respondent”) assesses and collects property taxes on the 

Subject Property. 

 

3. 

In 2025, Respondent determined the taxable and assessed values of the Subject Property 

to be as follows (which will result in a state equalized value in the same amount based upon the tentative 

equalization factor): 

Parcel No. 

AV 

TV 

08004470-1 

$84,600 

$84,600 

08004371-83 

$19,734 

$19,734

Page 2

2 

4937-2086-2535.1 

. 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject 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. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March, 2025. 

 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed on the 

Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as 

a fraud upon the taxpayer 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, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and applicable 

statutes; 

 

 

(c) 

The assessment, including taxable value and/or state equalized value, are based 

upon an erroneous determination of the true cash value of that portion of the Subject Property that is 

taxable under Michigan law, and are 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.

Page 3

3 

4937-2086-2535.1 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2024 taxable 

values and state equalized values of the Subject Property as follows: 

Parcel No. 

AV 

TV 

08004470-1 

$10,000 

$10,000 

08004371-83 

$2,000 

$2,000 

 

and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and 

costs. 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 30, 2025

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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

First Name/Company Name

M.I.

Last Name

Pogue Properties, LLC

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

24500 Northwestern Hwy.

Suite 100

City or Town

Southfield

State

Michigan

ZIP Code

48075

Telephone Number

3132347177

Fax Number

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

jconti@foley.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

Last Name

Conti

Firm Name (if any)

Foley & Lardner LLP

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

500 Woodward Ave, Ste 2700

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-234-7177

Fax Number

313-234-2800

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

jconti@foley.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?2

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

2251 W. Davison

Detroit

Michigan

Taxing Authority (City or Township)

City of Detroit (Wayne)

County

Wayne

If you are appealing more than one parcel, are they contiguous or adjoining? Yes

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

08004470-1

Classification of Property: Real 

Commercial

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

84600

Current Taxable Value as established by the Board of Review:

84600

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

20000

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

10000

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

Parcel Number:

08004371-83

Classification of Property: Real 

Commercial

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

19734

Current Taxable Value as established by the Board of Review:

19734

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

4000

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

2000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification? 

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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.

A fee of $250.00 is required for the filing of a Special Assessment

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