Pure Tax And Immigration Services LLC, Petitioner Vs. City Of Dearborn, 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

Pure Tax and Immigration Services LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001880

City Of Dearborn,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

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

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: May 20, 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

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

Pure Tax and Immigration Services LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001880

City Of Dearborn,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

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

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: May 20, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

Pure Tax and Immigration Services LLC, 

Petitioner, 

 

v 

 

 

 

 

 

 

MOAHR Docket No. 25-001880 

City of Dearborn, 

Respondent. 

________________________________________________________________________/ 

 

Joshua T. Shillair, Esq., (P72674) 

Of Colliers International 

Attorney for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

 

 

 

 

Jeremy J. Romer 

Rosati, Schults, Joppich, Amtsbuechler 

Attorney for Respondent 

27555 Executive Drive, Suite 250 

Farmington Hills, MI 48331 

P 248.489.4100 | F 248.489.1726 

Email: jromer@rsjalaw.com

 _____________________________________________________________________/ 

STIPULATION TO WITHDRAW APPEAL 

 

Now comes Petitioner, Pure Tax and Immigration Services LLC, by and through their 

counsel, Joshua T. Shillair, Esq. of Colliers International and stipulates to withdraw its 

appeal. 

Signed: 

___/s/Joshua T. Shillair_____ Date:_5/19/2026_______ 

Joshua T. Shillair, Esq. (P72674), Attorney for Petitioner 

 

 

 

Now comes Respondent, City of Dearborn, by and through its counsel and concurs and 

stipulates to the withdrawal of this appeal. 

 

Signed: 

 

__/s/Jeremy J. Romer______ Date:_5/19/26________ 

Jeremy Romer, (P77287), Attorney for Respondent

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Page 1

1 of 1

Docket #: 25-001880

Party Filing Document

Party Filing Document: 

 Joint

 Joint

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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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

Pure Tax and Immigration Services 

LLC,

Petitioner,

v

 

 

City Of Dearborn,

Respondent.

 MTT Docket No. 25-001880

Please be advised that 25-001880 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.

Page 2

MTT Docket No. 25-001880

Page 2 of 3

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

website for more information.

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” 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 subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Page 3

MTT Docket No. 25-001880

Page 3 of 3

Entered: January 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

Page 4

STAT

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Page 1

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 25-001880 

 

Page 1 of 2 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Pure Tax and Immigration Services LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 25-001880 

 

City of Dearborn, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

City of Dearborn Assessing 

16901 Michigan Ave, Suite #5 

Dearborn, MI 48126 

(313) 943-2140 

 

 

 

_____________________________________________________________________________/ 

PROOF OF SERVICE 

 

STATE OF MICHIGAN 

) 

 

 

 

 

)ss 

COUNTY OF OAKLAND 

) 

 

Joshua T. Shillair, Esq. states that on 06/12/2025, in compliance with TTR 221, he did place in 

the US mail a copy of Petitioner’s 2025 Entire Tribunal Property Tax Petition with docket 

number and this Proof of Service of Petition for the above captioned appeal to the units of 

government listed on the second page of this Proof of Service of Petition and on 8/13/2025, 

submit electronically to the Michigan Tax Tribunal a copy of this Proof of Service of Petition at 

eFile through www.etaxappeal.lara.state.mi.us. 

 

 

 

 

 

 

 

 

/s/ Joshua T. Shillair 

 

 

 

 

 

 

Joshua T. Shillair

Page 2

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 25-001880 

 

Page | 2 

 

By Certified Mail 

 

Assessor’s Office 

City of Dearborn Assessing 

16901 Michigan Ave, Suite #5 

Dearborn, MI 48126 

 

Office of the City/Township Clerk 

City of Dearborn 

Clerk's Office 

16901 Michigan Ave. 

Dearborn, MI, 48126 

 

By First Class Mail 

 

Director of Equalization 

Wayne County 

Equalization Director 

2 Woodward Ave 

Detroit, MI 48226 

 

County Clerk’s Office 

Wayne County 

Clerk's Office 

2 Woodward Ave 

Detroit, MI 48226 

 

Secretary of the School Board 

Dearborn City School Dist 

18700 Audette St 

Dearborn, MI 48124 

 

Treasurer for the State of Michigan 

Michigan Department of Treasury 

Lansing, MI 48922

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

 

PURE TAX IMMIGRATION SERVICES LLC, 

 

Petitioner, 

 

 

MTT Docket No. 24-001880 

 

 

 

v 

 

 

CITY OF DEARBORN, 

 

Respondent. 

_____________________________________________________________________/ 

 

JOSHUA T. SHILLAIR (P72674) 

COLLIERS INTERNATIONAL 

Attorney for Petitioner 

400 W. 4th Street, Ste. 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

 

 

 

JEREMY J. ROMER (P77287) 

GOPI P. PATEL (P77727) 

CITY OF DEARBORN 

Attorneys for Respondent 

16901 Michigan Ave., Ste. 14 

Dearborn, MI 48126 

(313) 943-2035 

(313) 943-2469 fax 

jromer@dearborn.gov 

gpatel@dearborn.gov 

_____________________________________________________________________/ 

 

RESPONDENT'S ANSWER TO PETITION 

AND AFFIRMATIVE DEFENSES 

 

 

NOW COMES Respondent, City of Dearborn, by and through its attorneys, JEREMY J. 

ROMER and GOPI P. PATEL, and for its Answer to Petition states as follows: 

ANSWER TO THE PETITION 

 

1. 

As to the allegations contained in Paragraph 1, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to his proofs. 

 

2. 

As to the allegations contained in Paragraph 2, this Respondent admits the 

allegations contained therein.

Page 2

2 

3. 

As to the allegations contained in Paragraph 3, this Respondent admits the 

allegations contained therein. 

 

4. 

As to the allegations contained in Paragraph 4, this Respondent admits only that the 

subject property is classified as Commercial. As to the remaining allegations stated therein, this 

Respondent is without sufficient information or knowledge to form a belief as to its truth and 

leaves Petitioner to his proofs. 

 

5. 

As to the allegations contained in Paragraph 5, this Respondent admits only that no 

Board of Review protest is required for a parcel classified as Commercial Real. 

 

6. 

As to the allegations contained in Paragraph 6, this Respondent admits the 

allegations contained therein. 

 

7. 

As to the allegations contained in Paragraph 7, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to his proofs. 

 

8. 

As to the allegations contained in Paragraph 8, this Respondent admits the 

allegations contained therein. 

 

9. 

As to the allegations contained in Paragraph 9, this Respondent admits the 

allegations contained therein. 

 

10. 

As to the allegations contained in Paragraph 10, this Respondent denies each and 

every allegation contained therein for the reason that they are untrue. 

 

11. 

As to the allegations contained in Paragraph 11, this Respondent is without 

sufficient information or knowledge to form a belief as to the truth of the allegation stated therein 

and leaves Petitioner to his proofs.

Page 3

3 

 

12. 

As to the allegations contained in Paragraph 12, this Respondent is without 

sufficient information or knowledge to form a belief as to the truth of the allegation stated therein 

and leaves Petitioner to his proofs. 

 

13. 

As to the allegations contained in Paragraph 13, this Respondent is without 

sufficient information or knowledge to form a belief as to the truth of the allegation stated therein 

and leaves Petitioner to his proofs. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss this 

Petition with prejudice, deny the legal and/or equitable relief requested, and order Petitioner to pay 

Respondent the costs and attorney fees so wrongfully sustained by the necessity of the defense. 

 

Respectfully submitted, 

 

 

Jeremy J. Romer 

 

________________________ 

 

JEREMY J. ROMER 

 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

 

16901 Michigan Ave., Ste. 14 

 

 

 

 

 

 

 

Dearborn, MI 48126 

 

 

 

 

 

 

 

(313) 943-2035 

 

 

 

 

 

 

 

(313) 943-2069 fax 

 

 

 

 

 

 

 

jromer@dearborn.gov 

 

 

Dated: August 1, 2025

Page 4

4 

AFFIRMATIVE DEFENSES 

 

 

For its further answer to Petition, and by way of its affirmative defenses, Respondent 

respectfully represents to this Honorable Tribunal as follows: 

1. 

Petitioner lacks standing to bring this matter before the Michigan Tax Tribunal. 

2. 

Petitioner has failed to allege specific and sufficient acts to set forth a cause of action 

against Respondent. 

3. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error of 

law, discrimination, and application of wrong principles or illegality on the part of Respondent. 

4. 

Petitioner has failed to allege that the mode and method of appraising its property failed 

to conform to the mode and method applied in the case of all other properties in the Respondent 

taxing unit. 

5. 

Petitioner has failed to allege specific and sufficient facts to establish the true cash 

value of its property. 

6. 

Petitioner has failed to file a petition which conforms to the requirements of TTR 240 

and its subsections sufficient to apprise Respondent of the grounds of its Petition. 

7. 

Petitioner has failed to show that any rate other than 50%, after equalization, was 

applied to the true cash value of Petitioner’s property as well as to the properties of all others to 

arrive at the respective equalized assessments appearing on Respondent’s assessment roll. 

8. 

Petitioner failed in its appearance, if

Page 5

5

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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. 25-001880

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Dearborn (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

Jeremy

M.I.

J.

Last Name

Romer

Firm Name (if any)

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

16901 Michigan Ave Ste 14

City or Town

Dearborn

State

Michigan

ZIP Code

48126

Telephone Number

313-943-3086

Fax Number

313-943-2469

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

jromer@ci.dearborn.mi.us

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

Respondent or Authorized Attorney/Representative’s Signature: 

Jeremy Romer

/s/

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Page 1

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Pure Tax and Immigration Services LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

City of Dearborn, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

City of Dearborn Assessing 

16901 Michigan Ave, Suite #5 

Dearborn, MI 48126 

(313) 943-2140 

 

 

 

_____________________________________________________________________________/ 

 

2025 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, Pure Tax and Immigration Services LLC, has the legal 

residence or principal office address of 15300 N Commerce Dr,Dearborn, MI 48120-

1264. Petitioner is a party in interest with respect to property taxes on property parcel 

no(s). (hereinafter referenced as the Subject Property) 82-10-191-04-004. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous. 

2. The Subject Property is located in Wayne County.

Page 2

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, City of Dearborn Assessing of Wayne County, assesses and collects 

property taxes on the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. 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. Protest to the 2025 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

15350 N Commerce Dr, Dearborn, MI 48120 

7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

8. The tax year(s) at issue are: 2025 

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2025 

82-10-191-04-

004 

$917,400.00 

$458,700.00 

$458,700.00 

 

10. The 2025 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of 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, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable 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, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

82-10-191-04-

004 

$600,000.00 

$300,000.00 

$300,000.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2025 

82-10-191-04-004 

$158,700.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 4 of 5 

 

WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an 

Order reducing the 2025 assessed value, state equalized value and taxable value for the Subject 

Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

Respectfully Submitted,

Page 5

2

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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

Pure Tax and Immigration Services LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001880

City Of Dearborn, 

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 28, 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

2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Pure Tax and Immigration Services LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

City of Dearborn, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

City of Dearborn Assessing 

16901 Michigan Ave, Suite #5 

Dearborn, MI 48126 

(313) 943-2140 

 

 

 

_____________________________________________________________________________/ 

 

2025 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, Pure Tax and Immigration Services LLC, has the legal 

residence or principal office address of 15300 N Commerce Dr,Dearborn, MI 48120-

1264. Petitioner is a party in interest with respect to property taxes on property parcel 

no(s). (hereinafter referenced as the Subject Property) 82-10-191-04-004. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous. 

2. The Subject Property is located in Wayne County.

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2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, City of Dearborn Assessing of Wayne County, assesses and collects 

property taxes on the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. 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. Protest to the 2025 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

15350 N Commerce Dr, Dearborn, MI 48120 

7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

8. The tax year(s) at issue are: 2025 

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2025 

82-10-191-04-

004 

$917,400.00 

$458,700.00 

$458,700.00 

 

10. The 2025 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of 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, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

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2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable 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, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

82-10-191-04-

004 

$600,000.00 

$300,000.00 

$300,000.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2025 

82-10-191-04-004 

$158,700.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

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2025 Entire Tribunal Property Tax Petition & Proof of Service 

Pure Tax and Immigration Services LLC v City of Dearborn 

Parcel Number: 82-10-191-04-004 

MTT Docket No.: 

 

Page 4 of 5 

 

WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an 

Order reducing the 2025 assessed value, state equalized value and taxable value for the Subject 

Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

Respectfully Submitted,

Page 5

2

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

First Name/Company Name

M.I.

Last Name

Pure Tax and Immigration Services LLC

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

15300 N Commerce Dr

City or Town

Dearborn

State

Michigan

ZIP Code

48120

Telephone Number

248-226-1632

Fax Number

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

aminali@puretaxone.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

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

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

Fax Number

248-226-1633

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

tax.efile@colliers.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?1

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

15350 Commerce

Michigan

Taxing Authority (City or Township)

City Of Dearborn (WAYNE)

County

Wayne

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.)

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:

82-10-191-04-004

Classification of Property: Real 

Commercial

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

458700.00

Current Taxable Value as established by the Board of Review:

458700.00

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

600000.00

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

300000.00

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:

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?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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 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/ Joshua Shillair

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.