Romulus Development LLC, Petitioner Vs. City Of Sterling Heights, 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 

Romulus Development LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 24-004182 

 

City of Sterling Heights, 

 

Presiding Judge 

Respondent. 

 

Joshua M. Wease 

 

 

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, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 24-004182 

Page 2 of 2 

 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

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

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

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

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

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

rate of 9.47%. 

 

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: April 3, 2025 

jc 

 

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 TAX TRIBUNAL 

 

 

ROMULUS DEVELOPMENT, LLC, 

 

 

 

Petitioner, 

 

vs. 

 

CITY OF STERLING HEIGHTS, 

 

 

 

Respondent. 

 

 

 

 

MTT Docket No. 24-004182 

_____________________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

MARC D. KASZUBSKI (P60333) 

O’REILLY RANCILIO P.C. 

Attorney for Respondent 

12900 Hall Road, Suite 350 

Sterling Heights, MI 48313-1151 

(586) 726-1000 

_____________________________________________________________________________/ 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

 

1. 

The case is pending in the __X__ Entire Tribunal ___ Small Claims Division. 

 

2. 

Property Parcel No: 10-10-26-477-041 

 

3. 

The property is located at: 13255 15 Mile Road, Sterling Heights, Macomb County, MI 

48312. 

 

4. 

The 2024 values for the property identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Year 

Original TCV 

Original AV 

Original TV 

2024 

$4,720,000 

$2,360,000 

 

$2,360,000* 

*The 2024 taxable value is being rolled back to the 2023 taxable value as it was 

improperly uncapped in 2024. 

 

5. 

The 2024 values for the property identified above as stipulated by the parties for 

settlement purposes are:

Page 2

MTT Docket No. 24-004182 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Year 

 Revised TCV 

Revised SEV 

Revised TV 

2024 

$4,720,000 

$2,360,000 

$1,110,822 

 

6. 

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 (attach additional page if necessary): 

____________________________________________________ 

 

7. 

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. (attach additional page if necessary): 

 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

 

Refunds shall be made payable to Petitioner and Petitioner’s counsel Hallahan & 

Associates, P.C. and sent in care of Petitioner’s counsel Hallahan & Associates, P.C., 

to: 1750 Telegraph Road, Suite 202, Bloomfield Hills, Michigan 48302-2082. 

 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

 //s// Laura M. Hallahan 

 

 

 

 

 

 

 

 

 

 

Laura M. Hallahan 

 

Signature of Respondent’s authorized representative: 

 //s// Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 

 

Marc D. Kaszubski

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

ROMULUS DEVELOPMENT, LLC, 

 

 

 

Petitioner, 

 

vs. 

 

CITY OF STERLING HEIGHTS, 

 

 

 

Respondent. 

 

 

 

 

MTT Docket No. 24-004182 

_____________________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

MARC D. KASZUBSKI (P60333) 

O’REILLY RANCILIO P.C. 

Attorney for Respondent 

12900 Hall Road, Suite 350 

Sterling Heights, MI 48313-1151 

(586) 726-1000 

_____________________________________________________________________________/ 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

 

1. 

The case is pending in the __X__ Entire Tribunal ___ Small Claims Division. 

 

2. 

Property Parcel No: 10-10-26-477-041 

 

3. 

The property is located at: 13255 15 Mile Road, Sterling Heights, Macomb County, MI 

48312. 

 

4. 

The 2024 values for the property identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Year 

Original TCV 

Original AV 

Original TV 

2024 

$4,720,000 

$2,360,000 

 

$2,360,000* 

*The 2024 taxable value is being rolled back to the 2023 taxable value as it was 

improperly uncapped in 2024. 

 

5. 

The 2024 values for the property identified above as stipulated by the parties for 

settlement purposes are:

Page 2

MTT Docket No. 24-004182 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Year 

 Revised TCV 

Revised SEV 

Revised TV 

2024 

$4,720,000 

$2,360,000 

$1,110,822 

 

6. 

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 (attach additional page if necessary): 

____________________________________________________ 

 

7. 

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. (attach additional page if necessary): 

 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

 

Refunds shall be made payable to Petitioner and Petitioner’s counsel Hallahan & 

Associates, P.C. and sent in care of Petitioner’s counsel Hallahan & Associates, P.C., 

to: 1750 Telegraph Road, Suite 202, Bloomfield Hills, Michigan 48302-2082. 

 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

 //s// Laura M. Hallahan 

 

 

 

 

 

 

 

 

 

 

Laura M. Hallahan 

 

Signature of Respondent’s authorized representative: 

 //s// Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 

 

Marc D. Kaszubski

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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

Romulus Development LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 24-004182

City Of Sterling Heights,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on March 24, 2025, 

and finds that the parties have stipulated to a taxable value(s) which does not appear to 

be in compliance with MCL 211.27a and the parties have failed to provide any 

justification for the proposed value(s). Specifically, the stipulated taxable value 

decreased below the state equalized value without legal justification. Therefore,

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall remain on the previously-scheduled 

Prehearing General Call and a Prehearing Conference will be scheduled accordingly.

IT IS FURTHER ORDERED that because this Stipulation for Entry of Consent 

Judgment is no longer pending before the Tribunal, a new stipulation is required for any 

future settlement. However, if the new stipulation is filed within 14 days of the issuance 

of this Order, no additional filing fee is required.

By _____________________________

 Joshua M. Wease, Tribunal Member 

Entered: March 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 provide by those parties, attorneys, or authorized 

representatives.

Page 2

MTT Docket No. 24-004182

Page 2 of 6

By: Tribunal Clerk

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

Romulus Development LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 24-004182

City Of Sterling Heights,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on March 24, 2025, 

and finds that the parties have stipulated to a taxable value(s) which does not appear to 

be in compliance with MCL 211.27a and the parties have failed to provide any 

justification for the proposed value(s). Specifically, the stipulated taxable value 

decreased below the state equalized value without legal justification. Therefore,

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall remain on the previously-scheduled 

Prehearing General Call and a Prehearing Conference will be scheduled accordingly.

IT IS FURTHER ORDERED that because this Stipulation for Entry of Consent 

Judgment is no longer pending before the Tribunal, a new stipulation is required for any 

future settlement. However, if the new stipulation is filed within 14 days of the issuance 

of this Order, no additional filing fee is required.

By _____________________________

 Joshua M. Wease, Tribunal Member 

Entered: March 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 provide by those parties, attorneys, or authorized 

representatives.

Page 4

MTT Docket No. 24-004182

Page 4 of 6

By: Tribunal Clerk

Page 5

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

Romulus Development LLC, 

Petitioner,

MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

MTT Docket No. 24-004182

City Of Sterling Heights,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on March 24, 2025, 

and finds that the parties have stipulated to a taxable value(s) which does not appear to 

be in compliance with MCL 211.27a and the parties have

Page 6

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

ROMULUS DEVELOPMENT, LLC, 

 

 

 

Petitioner, 

 

vs. 

 

CITY OF STERLING HEIGHTS, 

 

 

 

Respondent. 

 

 

 

 

MTT Docket No. 24-004182 

_____________________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

MARC D. KASZUBSKI (P60333) 

O’REILLY RANCILIO P.C. 

Attorney for Respondent 

12900 Hall Road, Suite 350 

Sterling Heights, MI 48313-1151 

(586) 726-1000 

_____________________________________________________________________________/ 

 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

1. 

The case is pending in the __X__ Entire Tribunal ___ Small Claims Division. 

 

2. 

Property Parcel No: 10-10-26-477-041 

 

3. 

The property is located at: 13255 15 Mile Road, Sterling Heights, Macomb County, MI 

48312. 

 

4. 

The 2024 values for the property identified above as established by Respondent’s Board 

of Review are: 

(TCV=true cash value, AV=assessed value, TV=taxable value) 

Year 

Original TCV 

Original AV 

Original TV 

2024 

$4,720,000 

$2,360,000 

 

$2,360,000 

 

5. 

The 2024 values for the property identified above as stipulated by the parties for 

settlement purposes are: 

(TCV=true cash value, SEV=state equalized value, TV=taxable value) 

Year 

 Revised TCV 

Revised SEV 

Revised TV 

2024 

$4,720,000 

$2,360,000 

$1,110,822

Page 2

MTT Docket No. 24-004182 

Stipulation for Entry of Consent Judgment, Page 2 of 2 

 

6. 

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 (attach additional page if necessary): 

____________________________________________________ 

 

7. 

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. (attach additional page if necessary): 

 

The parties agree that the stipulation regarding the subject property’s assessed and 

taxable values is strictly for settlement purposes only, and only for the years involved, 

and for no other purpose whatsoever. 

 

Refunds shall be made payable to Petitioner and Petitioner’s counsel Hallahan & 

Associates, P.C. and sent in care of Petitioner’s counsel Hallahan & Associates, P.C., 

to: 1750 Telegraph Road, Suite 202, Bloomfield Hills, Michigan 48302-2082. 

 

Petitioner hereby waives interest attributable to the reduction for all taxing authorities. 

 

Signature of Petitioner’s Authorized Representative or, if none, Petitioner: 

 //s// Laura M. Hallahan 

 

 

 

 

 

 

 

 

 

 

Laura M. Hallahan 

 

Signature of Respondent’s authorized representative: 

 //s// Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 

 

Marc D. Kaszubski

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

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 JANUARY 16 - 30, 2026 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Romulus Development LLC,

Petitioner,

v

 

 

City Of Sterling Heights,

Respondent.

 MTT Docket No. 24-004182

Please be advised that 24-004182 has been placed on a two-week Prehearing General 

Call commencing January 16, 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 September 19, 2025. 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. 24-004182

Page 2 of 2

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

Statements by September 19, 2025. 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 

September 19, 2025, 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 

January 16, 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: February 18, 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

Page 3

STATE OF

Page 4

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

ROMULUS DEVELOPMENT, LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

Docket No. 24-004182 

 

 

 

 

 

 

 

Parcel No. 10-10-17-476-029 

CITY OF STERLING HEIGHTS, 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

LAURA M. HALLAHAN (P42101) 

Hallahan & Associates. P.C. 

Attorney for Petitioner 

1750 S. Telegraph Rd., Ste. 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

lhallahan@hallahanlaw.com 

 

MARC D. KASZUBSKI (P60333) 

O’Reilly Rancilio P.C. 

Attorney for Respondent 

12900 Hall Road, Suite 350 

Sterling Heights, MI 48313-1151 

(586) 726-1000 

mkaszubski@orlaw.com 

 

 

ANSWER TO PETITION 

 

Respondent, CITY OF STERLING HEIGHTS (“Respondent”), submits the following as 

its Answer to the Petition in this matter: 

1. 

Admit. 

2. 

No response required. 

3. 

Admit. 

4. 

Neither admit nor deny as Respondent is without sufficient information upon 

which to form a belief as to the truth of the matter asserted. 

5. 

Neither admit nor deny as Respondent is without sufficient information upon 

which to form a belief as to the truth of the matter asserted.

Page 2

2 

 

6. 

Neither admit nor deny as Respondent is without sufficient information upon 

which to form a belief as to the truth of the matter asserted. 

7. 

Admit. 

8. 

Admit. 

9. 

Denied as untrue. 

10. 

Denied as untrue. 

11. 

a.-e. 

Denied as untrue. 

WHEREFORE, Respondent respectfully requests this Honorable Tribunal dismiss the 

Petition with prejudice and on the merits and further award Respondent any and all other relief in 

its favor as is deemed just and appropriate under the circumstances. 

 

 

 

 

 

O’REILLY RANCILIO P.C. 

 

 

 

 

 

 

 

By: /s/ Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 

Marc D. Kaszubski (P60333) 

 

 

 

 

 

 

 

Attorney for Respondent 

Dated: January 16, 2025 

 

 

RESPONDENT’S AFFIRMATIVE DEFENSES 

 

 

NOW COMES, Respondent, CITY OF STERLING HEIGHTS, by and through its 

attorneys, O’REILLY RANCILIO P.C. and states for its Affirmative Defenses as follows: 

1. 

Petitioner lacks an interest in the property or standing to bring this action. 

2. 

The Petition is improper because of untimely filing and statute of limitations. 

3. 

Lack of jurisdiction. 

4. 

Res Judicata and Collateral Estoppel. 

5. 

Petitioner fails to allege specific and sufficient facts to support a cause of action 

against Respondent.

Page 3

3 

 

6. 

The Petition is improper because it asks this Tribunal to grant a preference by 

application of a self-chosen method of assessment contrary to the laws of the 

State of Michigan. 

7. 

The Petition is improper because its effect would be to shift the burden of the city, 

school and county taxes to other property owners within the City of Sterling 

Heights. 

8. 

Petitioner has failed to join any and all claims arising out of the same transaction 

or occurrence subject to this action. 

9. 

Respondent reserves the right to raise any additional affirmative defenses as they 

arise during the pendency of this matter. 

 

WHEREFORE, Respondent respectfully requests this Honorable Tribunal dismiss the 

Petition with prejudice and on the merits and further award Respondent any and all other relief in 

its favor as is deemed just and appropriate under the circumstances. 

 

 

 

 

 

 

O’REILLY RANCILIO P.C. 

 

 

 

 

 

 

 

By: /s/ Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 

Marc D. Kaszubski (P60333) 

 

 

 

 

 

 

 

Attorney for Respondent 

Dated: January 16, 2025

Page 4

4 

 

PROOF OF SERVICE 

 

I served Respondent’s Answer to Petition and Affirmative 

Defenses upon the attorneys of record and/or parties in this case on 

January 16, 2025. I declare the foregoing statement to be true to 

the best of my information, knowledge and belief. 





 U.S. Mail 

 

 Fax 



 Hand Delivered 

 

 Messenger 



 Express Mail Private 

 Other: 

 

 

/s/ Teresa A. Walsh 

 

 

Teresa A. Walsh

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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. 24-004182

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Sterling Heights (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

Marc

M.I.

D

Last Name

Kaszubski

Firm Name (if any)

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

12900 Hall Rd, Ste 350

City or Town

Sterling Heights

State

Michigan

ZIP Code

48313

Telephone Number

586-726-1000

Fax Number

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

mkaszubski@orlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Marc D. Kaszubski

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

IN THE MICHIGAN TAX TRIBUNAL 

 

Romulus Development, LLC, 

 

Petitioner, 

 

v 

 

City of Sterling Heights, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 24-004182 

Parcel No. 10-10-26-477-041 

_____________________________________________________________________________/ 

 

 

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 of Sterling Heights 

40555 Utica Rd 

Sterling Heights, MI 48313 

 

City Clerk 

City of Sterling Heights 

40555 Utica Rd 

Sterling Heights, MI 48313 

 

 

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

 

Equalization Director 

Macomb County 

1 S. Main, 6th Floor 

Mount Clemens, MI 48043 

 

County Clerk 

Macomb County 

120 N. Main 

Mount Clemens, MI 48043 

 

Secretary, Board of Education 

Utica Community Schools 

11303 Greendale 

Sterling Heights, MI 48312 

 

State Treasurer 

Department of Treasury 

430 W. Allegan Street 

Lansing, MI 48922 

 

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

 

 

 

/s/ Laura M. Hallahan 

 

Dated: December 26, 2024

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

IN THE MICHIGAN TAX TRIBUNAL 

 

Romulus Development, LLC, 

 

Petitioner, 

 

v 

 

City of Sterling Heights, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 24-_____________ 

Parcel No. 10-10-26-477-041 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2024 Tax Year) 

 

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

1. 

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

Parcel Number 

10-10-26-477-041 

Address 

13255 15 Mile Road 

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: 

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

3. 

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

4. 

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

property. 

5. 

The Petitioner’s principal office/legal residence address is: 7486 Lakeport Street, West 

Bloomfield, MI 48323 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

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

☐ 

uniformity of the subject property’s assessment 

☐ 

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

Page 2

Petition 

2 

☒ 

Unlawful uncapping of Petitioner’s property. Respondent unlawfully uncapped 

the property at the December 2024 Board of Review and this Petition is timely filed 

within 35 days of that decision. See Board of Review decision attached. 

7. 

The tax year at issue is 2024. 

8. 

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

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

4,720,000 

2,360,000 

2,360,000 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

3,150,000 

1,575,000 

1,110,822 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

1,570,000 

785,000 

1,249,178 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2024 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; 

(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; and/or 

(e) 

The property transferred ownership on January 5, 2024 and, therefore Respondent 

unlawfully uncapped the property. 

 

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

Page 3

Petition 

3 

Petitioner requests that the Tribunal enter an order reducing the 2024 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. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: December 18, 2024 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

Filing Fee: $600

Page 4

2024 DECEMBER BOARD OF REVIEW 

Change Notice 

12/13/2024 

ROMULUS DEVELOPMENT LLC 

7486 LAKEPORT ST 

WEST BLOOMFIELD MI 48323 

Regarding Address: 13255 15 MILE RD 

Parcel Number: 10-10-26-477-041 

Dear Property Owner: 

On Dec 09, 2024 

, the December Board of Review made the following correction to the assessed value, capped 

value, taxable value and/or to the Principal Residence Exemption for the above referenced parcel. 

Original 

Corrected 

Year 

Assessed 

Capped 

Taxable 

Year

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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

Romulus Development LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 24-004182

City Of Sterling Heights, 

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 221 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 229(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: December 26, 2024

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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

IN THE MICHIGAN TAX TRIBUNAL 

 

Romulus Development, LLC, 

 

Petitioner, 

 

v 

 

City of Sterling Heights, 

 

Respondent. 

MICHIGAN TAX TRIBUNAL 

Docket No. 24-_____________ 

Parcel No. 10-10-26-477-041 

_____________________________________________________________________________/ 

 

 

PROPERTY TAX PETITION 

(Entire Tribunal, 2024 Tax Year) 

 

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

1. 

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

Parcel Number 

10-10-26-477-041 

Address 

13255 15 Mile Road 

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: 

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

3. 

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

4. 

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

property. 

5. 

The Petitioner’s principal office/legal residence address is: 7486 Lakeport Street, West 

Bloomfield, MI 48323 

6. 

This appeal involves issues related to: 

☒ 

the subject property’s true cash and taxable values 

☐ 

the subject property’s taxable value only 

 

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

☐ 

uniformity of the subject property’s assessment 

☐ 

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

Page 2

Petition 

2 

☒ 

Unlawful uncapping of Petitioner’s property. Respondent unlawfully uncapped 

the property at the December 2024 Board of Review and this Petition is timely filed 

within 35 days of that decision. See Board of Review decision attached. 

7. 

The tax year at issue is 2024. 

8. 

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

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

4,720,000 

2,360,000 

2,360,000 

9. 

Petitioner contends that the values1 for the subject property are: 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

3,150,000 

1,575,000 

1,110,822 

10. 

The values1 in dispute are. 

 

 

Parcel Number 

TCV 

SEV 

TV 

 

10-10-26-477-041 

1,570,000 

785,000 

1,249,178 

11. 

Petitioner relies upon the following to support the relief requested: 

The 2024 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; 

(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; and/or 

(e) 

The property transferred ownership on January 5, 2024 and, therefore Respondent 

unlawfully uncapped the property. 

 

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

Page 3

Petition 

3 

Petitioner requests that the Tribunal enter an order reducing the 2024 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. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan 

 

Laura M. Hallahan (P42101) 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

Dated: December 18, 2024 

lhallahan@hallahanlaw.com, (248) 731-3090 

 

Filing Fee: $600

Page 4

2024 DECEMBER BOARD OF REVIEW 

Change Notice 

12/13/2024 

ROMULUS DEVELOPMENT LLC 

7486 LAKEPORT ST 

WEST BLOOMFIELD MI 48323 

Regarding Address: 13255 15 MILE RD 

Parcel Number: 10-10-26-477-041 

Dear Property Owner: 

On Dec 09, 2024 

, the December Board of Review made the following correction to the assessed value, capped 

value, taxable value and/or to the Principal Residence Exemption for the above referenced parcel. 

Original 

Corrected 

Year 

Assessed 

Capped 

Taxable 

Year

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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

Romulus Development LLC

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

7486 Lakeport Street

City or Town

West Bloomfield

State

Michigan

ZIP Code

48323

Telephone Number

2487018529

Fax Number

248 731 3090

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

lhallahan@hallahanlaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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]

13255 15 Mile Road

Michigan

Taxing Authority (City or Township)

City Of Sterling Heights (MACOMB)

County

Macomb

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, Uncapping of Taxable Value

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

10-10-26-477-041

Classification of Property: Real 

Commercial

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

2360000

Current Taxable Value as established by the Board of Review:

2360000

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

3150000

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

1575000

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

1110822

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/ Laura M Hallahan

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