Shree Hari Of Auburn Hills Inc Petitioner Vs. City Of Auburn Hills 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

NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Shree Hari Of Auburn Hills Inc,

Petitioner,

v

 

 

City Of Auburn Hills,

Respondent.

 MTT Docket No. 26-000515

Please be advised that 26-000515 has been placed on a two-week Prehearing General 

Call commencing August 02, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

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

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 26-000515

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by April 5, 2027. 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 April 5, 2027. 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 

April 5, 2027, 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 

August 2, 2027, 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

Entered: September 1, 2026

Page 3

MTT Docket No. 26-000515

Page 3 of 3

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 4

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 AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF

Page 5

MT

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 & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Shree Hari of Auburn Hills Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Auburn Hills, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000515 

 

______________________________________________________________________________ 

 

GREGORY A. NOWAK (P39240) 

MILLER, CANFIELD, PADDOCK AND 

STONE, P.L.C. 

Attorney for Petitioner 

150 W. Jefferson, Suite 2500 

Detroit, MI 48226 

(313) 963-6420 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_______________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Auburn Hills, by and through its attorneys, Hallahan & Associates, 

P.C., responds to the allegations made in Petitioner’s Petition as follows: 

 

Jurisdictional Allegations and Factual Averments 

1. 

Respondent lacks knowledge or information sufficient to respond to the truth of the 

allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

 

2. 

Respondent lacks knowledge or information sufficient to respond to the truth of the 

allegations set forth in Paragraph 2and, therefore, leaves Petitioner to its proofs. 

 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

2

 

The Subject Property 

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5. 

 

6. 

Respondent acknowledges Petitioner’s belief as to an issue with the 2026 tax year 

but denies any issue with the identified tax year. 

7. 

Respondent neither admits nor denies the allegations in Paragraph 7 as the date 

Petitioner filed its Petition speaks for itself. 

 

 

Count I – The Assessed Value and Equalized Assessments 

Are More than 50% of the True Cash Value 

 

8. 

Respondent incorporates by reference herein its answers to Paragraphs 1 -7 above. 

 

9. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but 

denies that those issues have merit and further denies that Petitioner is entitled to any relief. 

 

10. 

Respondent admits the allegations in Paragraph 10. 

 

11. 

Respondent denies the allegations in Paragraph 11, including subparagraphs (a)-

(c), for the reason that the same are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional. 

 

12. 

Respondent acknowledges Petitioner’s contention of value but denies that it reflects 

the property’s fair market value as of December 31, 2025. In further answer, the assessed, state 

equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of 

true cash value permitted by law, were correctly determined and are based upon correct application 

of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory 

and constitutional. 

 

13. 

Respondent acknowledges Petitioner’s belief as to a dispute in the subject 

property’s valuation but denies Petitioner’s contentions of value have merit and further denies 

Petitioner is entitled to relief. In further answer, the assessed, state equalized and/or taxable values 

do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by 

law, were correctly determined and are based upon correct application of proper principles, and 

the values and Respondent’s mode of assessment are non-discriminatory and constitutional.

Page 3

3

14. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to said relief for the reasons set forth above. 

 

 

WHEREFORE, Respondent, City of Auburn Hills, requests the Tribunal dismiss the 

Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, 

and award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 10, 2026 

 

 

 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Auburn Hills, asserts the following affirmative defenses: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

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

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

its agents.

Page 4

4

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

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

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

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

7. 

Petitioner asks

Page 5

5

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000515

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Respondent

Files

Document Type: Amended Answer

Attachment File Name: Answer to Petition and Affirmative Defenses

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

51054779.1/164414.00001 

STATE OF MICHIGAN

IN THE MICHIGAN TAX TRIBUNAL

SHREE HARI OF AUBURN HILLS INC, 

MTT Docket No. 26-000515 

Petitioner, 

v. 

Parcel No. 02-14-23-101-010 

CITY OF AUBURN HILLS, 

Respondent. 

____________________________________________/ 

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Gregory A. Nowak (P39240) 

Attorney for Petitioner 

150 W. Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

313-963-6420 / Email: nowak@millercanfield.com

____________________________________________/ 

CERTIFICATE OF SERVICE 

The undersigned states that the Petition with Exhibits relative to the above-referenced matter 

were served with sufficient postage fully prepaid thereon upon the following persons as follows: 

Laura M. Pierce, Clerk 

City of Auburn Hills 

1827 N. Squirrel Road 

Auburn Hills, Michigan 48326 

(served 6/16/2026) 

Maria Collias, Assessor 

City of Auburn Hills 

1827 N. Squirrel Road 

Auburn Hills, Michigan 48326 

(served on 6/15/2026)

Page 2

51054779.1/164414.00001 

Lisa Brown, Clerk 

Oakland County 

1200 N Telegraph Building 12E 

Pontiac, MI 48341

(served 6/17/2026)

Eveonne Roberts, Secretary 

Board of Education 

Avondale School District 

2940 Waukegan Street 

Auburn Hills, MI 48326 

(served on 6/15/2026)

David Coulter, Director 

Oakland County Equalization 

250 Elizabeth Lake Rd, Suite 1000 W 

Pontiac, MI 48341 

(served 6/16/2026) 

Rachel Eubanks, State Treasurer 

Michigan Department of Treasury 

430 W. Allegan St. 

Lansing, MI 48933 

(served 6/16/2026)

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

Dated: July 2, 2026 

Respectfully submitted, 

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Attorneys for Petitioner 

/ s / Gregory A. Nowak 

Gregory A. Nowak (P39240) 

150 West Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 

Email: nowakmillercanfield.com

Page 3

SENDER: COMPLETE THIS SECTION 

® Complete items 1, 2, and 3. 

® Print your name and address on the reverse 

so that we can return the card to you. 

® Attach this card to the back of the mailpiece, 

or an the front if spare narmite 

1. Ar 

Laura M. Pierce, Clerk 

City of Auburn Hills 

1827 N. Squirrel Road 

Auburn Hills, Michigan 48326 

MR 

9590 9402 7703 2122 2890 25 

. COMPLETE THIS SECTION. ON DELIVERY. 

AJ 

Agent 

X 

[1 Addressee 

B. Received Ei fPrintey Name) 

. Date of Delivery 

D Zed 

<1 

D. Is delivery address different from item 1? 

OI Yes 

If YES, enter delivery address below: 

[1 No 

3. Service Type 

DO Adult Signature 

0 Adult Signature Restricted Delivery 

J Priority Mail Express® 

£1 Registered Mail™ 

O Registered Mail Restricted 

3. 

Artin Nine Tonmafne fone nin TabAn 

Certified Mail® 

ertified Mail Restricted Delivery 

2 Collect on Delivery 

[1 Collect on Delivery Restricted Delivery 

Delivery 

0 Signature Confirmation™ 

0] Signature Confirmation 

Restricted Delivery 

g585 

p710 

5270 

3452 

3L2h 

50 

jcteaveivey 

Bee 

J 

1.1.32: 

OO. 

. PS Form 3811, July 2020 PSN 7530-02-000-8053 

Domestic Return Receipt

Page 4

SENDER: COMPLETE THIS SECTION 

® Complete items 1, 2, and 3. 

B Print your name and address on the reverse 

so that we can return the card to you. 

B Attach this card to the back of the mailpiece, 

or on the front if space permits. 

COMPLETE THIS SECTION ON DELIVERY 

%: 

3: 

5 

/ 

( Agent 

i} Addressee 

B. hy oy ee re 

GC, 

Date of Delivery 

| 

[A 

1. Article Addrosnnd sae 

Maria Collias, Assessor 

City of Auburn Hills 

1827 N. Squirrel Road 

Auburn Hills, Michigan 48326 

DT AAT 

9590 9402 7703 2122 2890 01 

ult Signature Restricted Delivery 

LF 

Certified Mail® 

“5. Article Number (Transfer from service label) 

9589 0710 5270 3452 312k 74 

D. 

Is delivery address different from item 2/0 Yes 

If YES, enter delivery address below: 

3. Service Type 

0 Priority Mall Express® 

O Adult Signature 

[I Registered Mail™ 

DO Registered Mail Restricted. 

Delivery 

: 

0 Signature Confirmation™ 

[I Signature Confirmation 

ertified Mall Restricted Delivery 

0 Collect on Delivery 

t on Delivery Restricted Delivery 

A 

A Mail 

Restricted Delivery 

Ltricted Delivery 

, PS Form 3811, July 2020 PSN 7530-02-000-9053 

Domestic Return Receipt

Page 5

SENDER: COMPLETE THIS SECTION 

=® Complete items 1, 2, and 3. 

= Print your name and address on the reverse 

so that we can return the card to you. 

Wm Attach this card to the back of the mailpiece, 

or on the front if space permits. 

David Coulter, Director 

Oakland County Equalization 

-950 Elizabeth Lake Rd, Suite 1000 W 

Pontiac, MI 48341 

[J Agent. 

1 Addressee 

| 

17+ 

‘address different from item 1? 

J Yes 

|f YES, enter delivery address below: 

OO No 

C. Date of Delivery 

! 

9590 9402 7703 2122 2889 67 

3. Service Type 

0 Adult Signature 

J 

Adult Signature Restricted Delivery 

ertified Mail® 

ified Mail Restricted Delivery 

0 Collect on Delivery 

2. 

Article Number (Transfer from service label) 

OJ Priority Mail Express® 

[I Registered Mall™ 

O Registered Mail Restricted 

Delivery 

| 

| 

| 

| 

| 

| 

| 

| 

0 Signature Confirmation™ 

i 

0 Signature Confirmation 

O Collect on Delivery Restricted Delivery 

Restricted Delivery 

9589 

0710 

5270 

3452 312k 

BL 

ResvictedDefvery 

| 

; PS Form 3811, July 2020 PSN 7530-02-000-9053 

Domestic Return Receipt 

| 

| | 

] 

J

Page 6

NDER: COMPLETE THIS SECTION 

B® Complete items 1, 2, and 3. 

B® Print your name and address on the reverse 

so that we can return the card to you. 

| Attach this card to the back of the mailpiece, 

or on the front if space permits. 

A. Signature 

X 

IN DELIVER 

0 Agent 

[J] Addressee 

B. Received by (Printed Name) 

C. Date of Delivery 

ETE 

EE — 

Rachel Eubanks, State Treasurer 

Michigan Department of Treasury 

430 W. Allegan St. 

Lansing, MI 48933 

9590 9402 7703 2122 2889 43 

D. 

Is delivery address 

diff 

a 

TERN 

TMS 

frenfitem 1? 

[J Yes 

If YES, enter deliféry’ SpapEspeow: 

OO No 

petted 

J 

Lo of Michv jal 

3. Service TypAgent Ra 

O Adult Signature 

O,Adult Signature Restricted Delivery 

Sette Mail® 

ertified Mail Restricted Delivery 

O Collect 

on

Page 7

451

Page 8

6/3

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000515

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Certificate of Service - Petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

50509941.2/164414.00001 

STATE OF MICHIGAN

IN THE MICHIGAN TAX TRIBUNAL

SHREE HARI OF AUBURN HILLS INC, 

MTT Docket No. _______ 

Petitioner, 

v. 

Parcel No. 02-14-23-101-010 

CITY OF AUBURN HILLS, 

Respondent. 

____________________________________________/ 

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Gregory A. Nowak (P39240) 

Attorney for Petitioner 

150 W. Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

313-963-6420 / Email: nowak@millercanfield.com

____________________________________________/ 

ENTIRE TRIBUNAL PROPERTY TAX PETITION

NOW COMES PETITIONER, SHREE HARI OF AUBURN HILLS INC, by its attorneys, Miller, 

Canfield, Paddock and Stone, PLC, and for its Petition, represents unto the Honorable Tax Tribunal as 

follows: 

JURISDICTIONAL ALLEGATIONS AND FACTUAL AVERMENTS 

1.

Petitioner, Shree Hari of Auburn Hills Inc (hereinafter “Petitioner” or “SHAHI”) is a Michigan 

corporation with its registered office located at 1730 S CENTERVILLE RD, STURGIS, MI 49091. 

2.

Petitioner is a party in interest and/or an entity responsible for the payment of the ad 

valorem property taxes assessed on the Subject Property and/or an entity with an ownership interest in the 

Subject Property. 

3.

Respondent, City of Auburn Hills, is a municipality, existing under the laws of the State of 

Michigan, and is responsible for the real and/or personal property tax assessments levied against the 

Subject Property.

Page 2

50509941.2/164414.00001 

-2-

4.

The real property at issue herein is identified as 1461 N. Opdyke Road, Auburn Hills, MI 

48326, Parcel No. 02-14-23-101-010 (herein referred to as the “Subject Property”). 

5.

The Subject Property is classified as 201 Commercial located in City of Auburn Hills, 

County of Oakland and within the Pontiac City School District. 

6.

The tax year at issue is 2026. 

7.

This appeal is being submitted on or before the May 31st commercial property appeal 

deadline. 

COUNT I – THE ASSESSED VALUE AND 

EQUALIZED ASSESSMENTS ARE MORE THAN 50% OF THE TRUE CASH VALUE 

8.

Petitioner restates and incorporates herein paragraphs 1-7, above. 

9.

This property tax appeal involves issues relating to valuation, assessment, taxable value 

and uniformity of assessment. 

10.

For tax year 2026, Respondent determined true cash value (TCV), assessed value/state 

equalized value (AV) and taxable value (TV) for the Subject Property as follows: 

PARCEL 

TCV 

AV 

TV

02-14-23-101-010 

$4,519,860 

$2,259,930 

$1,965,080 

11.

The 2026 assessment imposed on the Subject Property and the taxes to be levied and 

collected thereon are invalid because: 

a.

The assessed value and equalized assessment imposed on the Subject Property are 

more than 50% of its true cash value in violation of the applicable statutory and 

constitutional limitations; 

b.

The taxable value is in excess of the applicable statutory and constitutional limitations;

Page 3

50509941.2/164414.00001 

-3-

and 

c.

The Subject Property is assessed in a discriminatory manner in that the assessment is 

at a higher level of the cash value than the average level of assessment for 

commercial properties within the assessment district. 

12.

Petitioner contends that the TCV, the AV/SEV and the TV for the Subject Property are as 

follows: 

PARCEL 

TCV 

AV 

TV

02-14-23-101-010 

$3,000,000 

$1,500,000 

$1,500,000 

13.

The values in dispute for the Subject Property for 2026 are: 

PARCEL 

TCV 

AV 

TV

02-14-23-101-010 

$1,519,860 

$759,930 

$465,080 

WHEREFORE, Petitioner respectfully requests that this Honorable Tax Tribunal enter an Order: (1) 

Reducing the 2026 assessed value on the Subject Property from $2,259,930 to $1,500,000; (2) Reducing 

the 2026 taxable value on the Subject Property from $1,965,080 to $1,500,000; (3) Directing Respondent to 

pay to Petitioner the refund attributable to such a reduction in the Subject Property’s assessed value and 

taxable value, plus interest and costs as provided by the Tax Tribunal Act; and (4) Granting Petitioner such 

other and further relief as is appropriate under the circumstances. 

(Signature on following page)

Page 4

50509941.2/164414.00001 

-4-

Dated: April 7, 2026 

Respectfully submitted,

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Attorneys for Petitioner 

By: / s / Gregory A. Nowak 

Gregory A. Nowak (P39240) 

150 West Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 / Email: nowak@millercanfield.com

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

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

Shree Hari Of Auburn Hills Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000515

City Of Auburn Hills, 

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: May 27, 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

50509941.2/164414.00001 

STATE OF MICHIGAN

IN THE MICHIGAN TAX TRIBUNAL

SHREE HARI OF AUBURN HILLS INC, 

MTT Docket No. _______ 

Petitioner, 

v. 

Parcel No. 02-14-23-101-010 

CITY OF AUBURN HILLS, 

Respondent. 

____________________________________________/ 

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Gregory A. Nowak (P39240) 

Attorney for Petitioner 

150 W. Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

313-963-6420 / Email: nowak@millercanfield.com

____________________________________________/ 

ENTIRE TRIBUNAL PROPERTY TAX PETITION

NOW COMES PETITIONER, SHREE HARI OF AUBURN HILLS INC, by its attorneys, Miller, 

Canfield, Paddock and Stone, PLC, and for its Petition, represents unto the Honorable Tax Tribunal as 

follows: 

JURISDICTIONAL ALLEGATIONS AND FACTUAL AVERMENTS 

1.

Petitioner, Shree Hari of Auburn Hills Inc (hereinafter “Petitioner” or “SHAHI”) is a Michigan 

corporation with its registered office located at 1730 S CENTERVILLE RD, STURGIS, MI 49091. 

2.

Petitioner is a party in interest and/or an entity responsible for the payment of the ad 

valorem property taxes assessed on the Subject Property and/or an entity with an ownership interest in the 

Subject Property. 

3.

Respondent, City of Auburn Hills, is a municipality, existing under the laws of the State of 

Michigan, and is responsible for the real and/or personal property tax assessments levied against the 

Subject Property.

Page 2

50509941.2/164414.00001 

-2-

4.

The real property at issue herein is identified as 1461 N. Opdyke Road, Auburn Hills, MI 

48326, Parcel No. 02-14-23-101-010 (herein referred to as the “Subject Property”). 

5.

The Subject Property is classified as 201 Commercial located in City of Auburn Hills, 

County of Oakland and within the Pontiac City School District. 

6.

The tax year at issue is 2026. 

7.

This appeal is being submitted on or before the May 31st commercial property appeal 

deadline. 

COUNT I – THE ASSESSED VALUE AND 

EQUALIZED ASSESSMENTS ARE MORE THAN 50% OF THE TRUE CASH VALUE 

8.

Petitioner restates and incorporates herein paragraphs 1-7, above. 

9.

This property tax appeal involves issues relating to valuation, assessment, taxable value 

and uniformity of assessment. 

10.

For tax year 2026, Respondent determined true cash value (TCV), assessed value/state 

equalized value (AV) and taxable value (TV) for the Subject Property as follows: 

PARCEL 

TCV 

AV 

TV

02-14-23-101-010 

$4,519,860 

$2,259,930 

$1,965,080 

11.

The 2026 assessment imposed on the Subject Property and the taxes to be levied and 

collected thereon are invalid because: 

a.

The assessed value and equalized assessment imposed on the Subject Property are 

more than 50% of its true cash value in violation of the applicable statutory and 

constitutional limitations; 

b.

The taxable value is in excess of the applicable statutory and constitutional limitations;

Page 3

50509941.2/164414.00001 

-3-

and 

c.

The Subject Property is assessed in a discriminatory manner in that the assessment is 

at a higher level of the cash value than the average level of assessment for 

commercial properties within the assessment district. 

12.

Petitioner contends that the TCV, the AV/SEV and the TV for the Subject Property are as 

follows: 

PARCEL 

TCV 

AV 

TV

02-14-23-101-010 

$3,000,000 

$1,500,000 

$1,500,000 

13.

The values in dispute for the Subject Property for 2026 are: 

PARCEL 

TCV 

AV 

TV

02-14-23-101-010 

$1,519,860 

$759,930 

$465,080 

WHEREFORE, Petitioner respectfully requests that this Honorable Tax Tribunal enter an Order: (1) 

Reducing the 2026 assessed value on the Subject Property from $2,259,930 to $1,500,000; (2) Reducing 

the 2026 taxable value on the Subject Property from $1,965,080 to $1,500,000; (3) Directing Respondent to 

pay to Petitioner the refund attributable to such a reduction in the Subject Property’s assessed value and 

taxable value, plus interest and costs as provided by the Tax Tribunal Act; and (4) Granting Petitioner such 

other and further relief as is appropriate under the circumstances. 

(Signature on following page)

Page 4

50509941.2/164414.00001 

-4-

Dated: April 7, 2026 

Respectfully submitted,

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Attorneys for Petitioner 

By: / s / Gregory A. Nowak 

Gregory A. Nowak (P39240) 

150 West Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 / Email: nowak@millercanfield.com

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

SHREE HARI OF AUBURN HILLS INC

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

1730 S Centerville Road

City or Town

Sturgis

State

Michigan

ZIP Code

49091

Telephone Number

419-315-0659

Fax Number

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

sunilkumar.patel@stayatchoice.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Gregory

M.I.

A

Last Name

Nowak

Firm Name (if any)

Miller Canfield Paddock and Stone PLC

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

150 W. Jefferson

Suite 2500

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-496-7963

Fax Number

313-496-8454

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

nowak@millercanfield.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]

1461 N Opdyke Road

Auburn Hills

Michigan

48326

Taxing Authority (City or Township)

City Of Auburn Hills (OAKLAND)

County

Oakland

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:

02-14-23-101-010

Classification of Property: Real 

Commercial

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

2259930

Current Taxable Value as established by the Board of Review:

1965080

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

3000000

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

1500000

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/ Gregory A. Nowak

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.