Rac Ryan LLC, Petitioner Vs. City Of Warren, 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

RAC Ryan LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002385

City Of Warren,

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: February 25, 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

RAC Ryan LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002385

City Of Warren,

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: February 25, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

RAC RYAN LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF WARREN, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002385 

 

 

_____________________________________________________________________________/ 

 

JORDAN JONNA 

AF JONNA DEVELOPMENT 

Representative for Petitioner 

4036 Telegraph Rd., Suite 201 

Bloomfield Hills, MI 48302 

(248) 593-6200 

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 

_____________________________________________________________________________/ 

 

STIPULATION TO DISMISS 

Petitioner and Respondent hereby stipulate to the dismissal of this case with prejudice 

and without costs or attorney fees to either party. 

 

/s/ Jordan Jonna___________________ 

JORDAN JONNA 

AF JONNA DEVELOPMENT 

Representative for Petitioner 

 

 

 

Dated: February 25, 2026 

 

_/s/ Laura M. Hallahan_____________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

 

Dated: February 25, 2026

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Page 1

15

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RACRYAN LLC, 

Petitioner, 

MTT Docket No. 25-002385 

v 

CITY OF WARREN, 

Respondent. 

/ 

JORDAN JONNA 

LAURA M. HALLAHAN (P42101) 

AF JONA DEVELOPMENT 

SETH A. O'LOUGHLIN (P80257) 

Representative for Petitioner 

KELSEA M. MELCHER (P85821) 

4036 Telegraph Rd., Suite 201 

HALLAHAN & ASSOCIATES, P.C. 

Bloomfield Hills, MI 48302 

Attorneys for Respondent 

(248) 593-6200 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

RESPONDENT’S SUBSTITUTION OF AUTHORIZED REPRESENTATIVE 

Laura M. Hallahan of Hallahan & Associates, P.C. substitutes in place of Mary Michaels 

and Laura 

Sullivan, 

Attorneys 

for 

the 

City 

of Warren, 

as 

authorized representatives 

for 

Respondent City of Warren and requests that she be copied on all future matters in the above 

pal 

docket. 

J 

\ 

/ 

Pr 

(lle bY / / 

/s/ Laura M. Hallahan 

MARY MICHAELS (P44601) 

LAURA M. HALLAHAN (P42101) 

LAURA SULLIVAN (P42021) 

SETH A. O'LOUGHLIN (P80257)

Page 2

15

PROOF OF SERVICE 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Substitution of 

Authorized Representative to: 

Jordan Jonna 

fkuza@afjonna.com 

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

/s/ Holly McIntyre 

Dated: January 15,2026 

Holly McIntyre

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

ACTING 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 AUGUST 3 - 14, 2026 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

RAC Ryan LLC,

Petitioner,

v

 

 

City Of Warren,

Respondent.

 MTT Docket No. 25-002385

Please be advised that 25-002385 has been placed on a two-week Prehearing General 

Call commencing August 03, 2026. Parties will be notified at least one week before 

they are scheduled to appear.

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, as provided by TTR 237.

In accordance with MCR 1.109(D)(9), as of January 1, 2021, 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. Please refer to the 

Tribunal’s FAQs and Glossary of Terms pages on our 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 April 6, 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.

Page 2

MTT Docket No. 25-002385

Page 2 of 2

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

Statements by April 6, 2026. 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, as provided by 

TTR 237. 

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

April 6, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, 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 

August 3, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, 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

Entered: September 2, 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 provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

ACTING 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 AUGUST 3 - 14, 2026 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

RAC Ryan LLC,

Petitioner,

v

 

 

City Of Warren,

Respondent.

 MTT Docket No. 25-002385

Please be advised that 25-002385 has been placed on a two-week Prehearing General 

Call commencing August 03, 2026. Parties will be notified at least one week before 

they are scheduled to appear.

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, as provided by TTR 237.

In accordance with MCR 1.109(D)(9), as of January 1, 2021, the responsibility for 

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

or offered to the Tribunal rests solely

Page 4

MTT

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Page 1

RECEIVED 

JUL 112025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RAC Ryan LLC, 

Petitioner, 

Vs. 

MOAHR Docket No. 25-002385 

City of Warren, 

Respondent. 

PROOF OF SERVICE 

(Property Tax Petition) 

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

City Assessor 

City Clerk 

City of Warren 

City of Warren 

One City Square 

One City Square, Suite 205 

Warren, MI 48093 

Warren, MI 48093 

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

Equalization Director 

County Clerk 

Macomb County 

Macomb County 

1 S. Main, 6th Floor 

120 N. Main 

Mount Clemens, MI 48043 

Mount Clemens, MI 48043 

Secretary, Board of Education 

State Treasurer 

Warren Consolidated Schools 

Department of Treasury 

31300 Anita Drive 

430 W. Allegan Street 

Warren, MI 48093 

Lansing, MI 48922 

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

/s/ Jordan Jonna

Page 2

RECEIVED 

RECEIVED 

JUN 02 205 

MAY 2 9 2025 

MICs. 

STATE OF MICHIGAN 

N TAX TRIBUNAL s1GAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

RAC Ryan LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 

25-_ 002385 

City of Warren, 

Parcel No. 

12-13-06-228-026 

Respondent. 

/ 

Trininfodh0s 

 2R019834-1 

05/30/75 

PROPERTY TAX PETITION hid: 

[5% 

wt: $00.00 

(Entire Tribunal, 2025 Tax Year)ll: 

RC RYAN LLC 

Petitioner, by and through its attorney, Jordan Jonna, contends: 

1. 

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

Parcel Number 

| 12-13-06-228-026 

Address 

32983 Ryan 

Classification 

201 Comm Imp 

[ Use 

Retail 

County 

Macomb 

| Sch Dist | Warren Consolidated Schools 

2. 

N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[J March, 

[1 July, 

0 December 

Board of Review. 

3. 

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

4. 

Petitioner is 

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

property. 

5. 

The Petitioner’s principal office/legal residence address is: 

4036 Telegraph Road, Suite 

201, Bloomfield Hills, MI 48302. 

6. 

This appeal involves issues related to: 

X 

the subject property’s true cash and taxable values 

0 

the subject property’s taxable value only

Page 3

Petition 

10. 

11. 

The values! established by Respondent's Board of Review for the subject property are: 

Parcel Number 

TCV 

SEV 

™vV 

12-13-06-228-026 

1,610,980 

805,490 

577,177 

Petitioner contends that the values! for the subject property are: 

Parcel Number 

TCV 

SEV 

TV 

12-13-06-228-026 

555,100 

277,550 

271,550 

The values! in dispute are. 

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

1,055,880 

527,940 

299,627 

Petitioner relies upon the following to support the relief requested: 

The 2025 values imposed on Petitioner's property, and the taxes to be levied and collected 

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

that: 

(a) 

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

by the Michigan Constitution and applicable statutes; 

(b) 

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

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

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

determination of the true cash value of that portion of Petitioners property that is 

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

and 

(d) 

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

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2025 values from those established 

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

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

Page 4

Petition 

y 

Jordan Jonna 

/ 

4036 Telegraph Road, Suite 201 

Bloomfield Hills, MI 48302 

248 593-6200 

Dated: May 28, 2025 

FRuza@AFJonna.com 

Filing Fee: $600

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RAC RYAN LLC 

MTT Docket No. 25-002385 

Petitioner, 

Parcel ID No. 12-13-06-228-026 

V. 

CITY OF WARREN, 

Respondent. 

JORDAN JONNA 

AF JONNA DEVELOPMENT 

Representative for Petitioner 

4036 Telegraph Road, Suite 201 

Bloomfield Hills, Michigan 48302 

(248) 593-6200 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Ste. 400 

Warren, MI 48093 

(586) 574-4671 

/ 

RESPONSE TO PETITION 

Respondent, City of Warren, 

by and through 

its attorneys, MARY MICHAELS, Acting 

City Attorney and LAURA SULLIVAN, Assistant City Attorney, in response to the Petition states 

as follows: 

1. 

Paragraph 

1 

is not contested. 

2. 

Paragraph 2 is not contested. 

3. 

Paragraph 3 is not contested. 

4, 

Paragraph 4 is not contested.

Page 2

7. 

Paragraph 7 is not contested. 

8. 

Paragraph 

8 

is not contested except that the True Cash Value on the Subject 

Property Tax Record is $1,610,986.00. 

9. 

In 

response 

to 

Paragraph 

9, 

Respondent 

lacks 

sufficient 

knowledge 

or 

information to form a belief as to the truth of the allegations and therefore leaves Petitioner to its 

proofs. 

10. 

In 

response 

to 

Paragraph 

10, 

Respondent 

lacks 

sufficient 

knowledge 

or 

information to form a belief as to the truth of the allegations and therefore leaves Petitioner to its 

proofs. 

11. 

In response to Paragraph 11, (a)-(d) is denied. 

THEREFORE, Respondent City of Warren requests this Tribunal deny the requested 

relief, dismiss the Petition with prejudice, and award Respondent costs it incurred in the defense 

of this appeal. 

Respectfully submitted, 

By: 

[s/Laura Sullivan 

LAURA SULLIVAN (P42021) 

Assistant City Attorney 

Attorneys for Respondent 

Dated: 

July 14, 2025 

LS/vIt Response to Petition, Affirmative Defenses and POS — RAC Ryan LLC ID 113654

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RAC RYAN LLC 

MTT Docket No. 25-002385 

Petitioner, 

Parcel ID No. 12-13-06-228-026 

V. 

CITY OF WARREN, 

Respondent. 

JORDAN JONNA 

AF JONNA DEVELOPMENT 

Representative for Petitioner 

4036 Telegraph Road, Suite 201 

Bloomfield Hills, Michigan 48302 

(248) 593-6200 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Ste. 400 

Warren, MI 48093 

(586) 574-4671 

/ 

AFFIRMATIVE DEFENSES 

Respondent, 

City of Warren, 

by and through 

its attorneys, MARY MICHAELS, Acting 

City Attorney and LAURA SULLIVAN, Assistant City Attorney, 

in response 

to the Petition, 

submit the following Affirmative Defenses: 

1. 

Petitioner failed 

to allege specific and sufficient facts to set forth 

a cause 

of 

action. 

2. 

Petitioner failed to allege specific and sufficient facts to establish illegality on part 

of Respondent, or its agent.

Page 4

5. 

Petitioner 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 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 failed 

to allege specific and sufficient facts to 

support its allegations that the property’s taxable value is improper. 

7. 

Petitioner failed to submit any evidence warranting relief from the assessments to 

the Board of Review. 

8. 

Petitioner, 

in essence, seeks by petition to challenge the process of county and 

state equalization as to which it has no legal standing and cannot maintain a cause of action. 

9. 

Respondent reserves 

the 

right 

to 

raise 

additional defenses 

as may become 

known to 

it during the course of these proceedings. 

Respectfully submitted, 

By: 

/s/Laura Sullivan 

LAURA SULLIVAN (P42021) 

Assistant City Attorney 

Attorneys for Respondent 

Dated: 

July 14, 2025 

LS/vIt Response to Petition, Affirmative Defenses and POS — RAC Ryan ID 113654

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RAC RYAN LLC 

MTT Docket No. 25-002385 

Petitioner, 

Parcel ID No. 12-13-06-228-026 

V. 

CITY OF WARREN, 

Respondent. 

JORDAN JONNA 

AF JONNA DEVELOPMENT 

Representative for Petitioner 

4036 Telegraph Road, Suite 201 

Bloomfield Hills, Michigan 48302 

(248) 593-6200 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Ste. 400 

Warren, MI 48093 

(586) 574-4671 

/ 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) SS. 

COUNTY OF MACOMB 

) 

On the date below, 

| sent via email 

to fkuza@afjonna.com 

a copy 

of Respondent City of 

Warren's Response to Petition, Affirmative Defenses and Proof of Service. 

| declare that the statements above are true to the best of my information, knowledge, and 

belief. 

[s/Valerie Tack 

Valerie Tack 

Dated: 

July 14, 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 - Respondent

MOAHR DOCKET NO. 25-002385

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Warren (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.

Last Name

Sullivan

Firm Name (if any)

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

One City Square

Suite 400

City or Town

Warren

State

Michigan

ZIP Code

48093

Telephone Number

586-574-4671

Fax Number

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

lsullivan@cityofwarren.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Laura Sullivan

/s/

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Page 1

RECEIVED 

RECEIVED 

JUN 02 925 

MAY 2 9 2025 

MICs. _ 

STATE OF MICHIGAN 

"N TAX TRIBUNAL 1GAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

RAC Ryan LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 

25- 

City of Warren, 

Parcel No. 

12-13-06-228-026 

Respondent. 

/ 

Traninfo:4606 

 2601983¢-1 

05/30/25 

PROPERTY TAX PETITION 

Chkfi: 

1534 

Ant: $600.00 

(Entire Tribunal, 2025 Tax Year)ID: 

RAD RYAN LLC 

Petitioner, by and through its attorney, Jordan Jonna, contends: 

1. 

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

Parcel Number 

| 12-13-06-228-026 

Address 

32983 Ryan 

Classification 

201 Comm Imp 

[ Use 

Retail 

County 

Macomb 

| Sch Dist 

| Warren Consolidated Schools 

2. 

XI N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[OO March, 

July, 

[J December 

Board of Review. 

3. 

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

4. 

Petitioner is 

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

property. 

5 

The Petitioners principal office/legal residence address is: 

4036 Telegraph Road, Suite 

201, Bloomfield Hills, MI 48302. 

6. 

This appeal involves issues related to: 

X 

the subject property’s true cash and taxable values

Page 2

Petition 

8. 

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

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

1,610,980 

805,490 

571,177 

9. 

Petitioner contends that the values! for the subject property are: 

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

555,100 

277,550 

271,550 

10. 

The values' in dispute are. 

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

1,055,880 

527,940 

299,627 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2025 values imposed on Petitioner’s property, and the taxes to be levied and collected 

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

that: 

(a) 

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

by the Michigan Constitution and applicable statutes; 

(b) 

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

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

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

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

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

and 

(d) 

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

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2025 values from those established 

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

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

Page 3

Petition 

A 

Jordan Jonna 

/ 

4036 Telegraph Road, Suite 201 

Bloomfield Hills, MI 48302 

248 593-6200 

Dated: May 28, 2025 

FKuza@AFJonna.com 

Filing Fee: $600

Page 4

Invoice 

CoDate 

BONim 

© 

fl 

Reference 

Amount "I 

Discount 

| 

Net 

RYA ~ APPEAL 

5/27/2025 

12-13-06-228-026 

600.00 

0.00 

600.00 

Payor: 

RAC Ryan, LLC 

Date 

Check No. 

Check Amount 

Payee: 

State of Michigan 

5/27/2025 

— 

600.00 

Retain this statement for your records

Page 5

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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

RAC Ryan LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002385

City Of Warren, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this Notice evidencing the service of the petition. 

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

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

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

the Notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: June 12, 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

RECEIVED 

RECEIVED 

JUN 02 925 

MAY 2 9 2025 

MICs. _ 

STATE OF MICHIGAN 

"N TAX TRIBUNAL 1GAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

RAC Ryan LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

Docket No. 

25- 

City of Warren, 

Parcel No. 

12-13-06-228-026 

Respondent. 

/ 

Traninfo:4606 

 2601983¢-1 

05/30/25 

PROPERTY TAX PETITION 

Chkfi: 

1534 

Ant: $600.00 

(Entire Tribunal, 2025 Tax Year)ID: 

RAD RYAN LLC 

Petitioner, by and through its attorney, Jordan Jonna, contends: 

1. 

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

Parcel Number 

| 12-13-06-228-026 

Address 

32983 Ryan 

Classification 

201 Comm Imp 

[ Use 

Retail 

County 

Macomb 

| Sch Dist 

| Warren Consolidated Schools 

2. 

XI N/A. 

If the assessment at issue was protested, the protest was made to Respondent’s: 

[OO March, 

July, 

[J December 

Board of Review. 

3. 

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

4. 

Petitioner is 

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

property. 

5 

The Petitioners principal office/legal residence address is: 

4036 Telegraph Road, Suite 

201, Bloomfield Hills, MI 48302. 

6. 

This appeal involves issues related to: 

X 

the subject property’s true cash and taxable values

Page 2

Petition 

8. 

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

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

1,610,980 

805,490 

571,177 

9. 

Petitioner contends that the values! for the subject property are: 

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

555,100 

277,550 

271,550 

10. 

The values' in dispute are. 

Parcel Number 

TCV 

SEV 

Tv 

12-13-06-228-026 

1,055,880 

527,940 

299,627 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2025 values imposed on Petitioner’s property, and the taxes to be levied and collected 

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

that: 

(a) 

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

by the Michigan Constitution and applicable statutes; 

(b) 

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

cash value than permissible under the Michigan Constitution and applicable 

statutes; 

(c) 

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

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

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

and 

(d) 

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

adopted by Respondent, discriminate against Petitioner and deny Petitioner its 

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

Petitioner requests that the Tribunal enter an order reducing the 2025 values from those established 

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

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

Page 3

Petition 

A 

Jordan Jonna 

/ 

4036 Telegraph Road, Suite 201 

Bloomfield Hills, MI 48302 

248 593-6200 

Dated: May 28, 2025 

FKuza@AFJonna.com 

Filing Fee: $600

Page 4

Invoice 

CoDate 

BONim 

© 

fl 

Reference 

Amount "I 

Discount 

| 

Net 

RYA ~ APPEAL 

5/27/2025 

12-13-06-228-026 

600.00 

0.00 

600.00 

Payor: 

RAC Ryan, LLC 

Date 

Check No. 

Check Amount 

Payee: 

State of Michigan 

5/27/2025 

— 

600.00 

Retain this statement for your records

Page 5

Envelc 

Recycle

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.