Southeast Group LLC, Petitioner Vs. City Of Detroit, Respondent

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

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

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

STATE OF MICHIGAN 

IN THE COURT OF APPEALS 

 

 

Southeast Group LLC, 

Petitioner-Appellant, 

 

v 

 

 

 

 

 

 

Court of Appeals Docket No. 377647 

 

City of Detroit, 

Respondent-Appellee. 

 

Lower Court No. 25-002897 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CERTIFIED RECORD OF PROCEEDINGS 

 

 

BEFORE THE MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: February 27, 2026 

 

 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

 

 

P.O. Box 30232 

 

 

 

 

 

 

 

Lansing, MI 48909

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 

STATE OF MICHIGAN 

IN THE COURT OF APPEALS 

 

 

Southeast Group LLC, 

Petitioner-Appellant, 

 

v 

 

 

 

 

 

 

Court of Appeals Docket No. 377647 

 

City of Detroit, 

Respondent-Appellee. 

 

 

Lower Court No. 25-002897 

 

 

CERTIFIED RECORD OF PROCEEDINGS BEFORE THE MICHIGAN TAX TRIBUNAL 

 

Kate Campbell, Tribunal Secretary of the Michigan Tax Tribunal, certifies that the 

electronic file is a replica of the original record of the Michigan Tax Tribunal in the 

above-captioned matter, and that said record consists of those entries shown on the 

docket card. The documents are stored electronically and can be found on the 

Tribunal’s website at 

https://taxdocketlookup.apps.lara.state.mi.us/Details.aspx?PK=158586. Any 

confidential documents contained in this docket will be attached to the e-mail 

responding to the file request. 

 

 

Dated: February 27, 2026 

 

____________________________ 

Michigan Tax Tribunal Paralegal

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

1

Campbell, Kate (LARA)

From:

COA Detroit Records Clerk <COADetroitRecords@courts.mi.gov>

Sent:

Friday, February 27, 2026 8:35 AM

To:

Campbell, Kate (LARA)

Subject:

Record_Request for COA #377647 - Detroit Office

CAUTION: This is an External email. Please report suspicious emails via the "Report to Abuse" 

button in Outlook 

 

To: COURT CONTACT

 

RE:SOUTHEAST GROUP LLC V CITY OF DETROIT 

Court of Appeals No.:377647 

Tax Tribunal:25-002897 

Within 21 days of the date of this notice, please send the court record for this case to the Michigan 

Court of Appeals digitally, or to this location: Cadillac Place, 3020 West Grand Boulevard, Suite 14-300, 

Detroit, MI 48202-6020. See MCR 7.210(G). If you are unable to file the record within 21 days, please 

reply to this email explaining the delay and indicating when you expect the record to be available. 

 

If you have any questions, you may reply to this email. 

 

Thank you, 

Michigan Court of Appeals Clerk's Office

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Page 1

RECEIVED 

0cT 06 025 

rps, 

MICHIGAN TAX TR] 

STATE OF MICHIGAN 

BUNAL 

COURT OF APPEALS 

Southeast Group LLC, 

Petitioner-Appellant, 

v 

Court of Appeals Case No. 

City Of Detroit, 

Respondent-Appellee. 

MTT Docket No. 25-002897 

Stewart Mandell (P33781) 

Kevin C. Richard (P43417) 

Jackie J. Cook (P68781) 

City of Detroit Law Department 

Christina Grossi (P67482) 

Attorneys for Respondent-Appellee 

Honigman LLP 

Coleman A. Young Municipal Center 

Attorneys for Petitioner-Appellant 

2 Woodward Avenue, Suite 500 

39400 Woodward Avenue, Suite 101 

Detroit, M1 48226 

Bloomfield Hills, MI 48304-5151 

(313) 237-3061 

(313) 465-7420 

richkc@detroitmi.gov 

slmandell@honigman.com 

jcook@honigman.com 

cgrossi@honigman,com 

Notice of Filing Claim of Appeal 

TO: 

Chief Clerk 

Michigan Tax Tribunal 

611 W. Ottawa 

Lansing, MI148933 

PLEASE TAKE NOTICE that on October 6, 2025, the attached Claim of Appeal was filed 

electronically with the Court of Appeals.

Page 2

JIS Code: COA 

STATE OF MICHIGAN 

JUDICIAL DISTRICT 

JUDICIAL CIRCUIT 

COUNTY 

[/] IN THE COURT OF APPEALS 

CLAIM OF APPEAL 

CASE NO. 

CIRCUIT 

michigan 

Tax Tribunal 

DISTRICT 

5.002897 

PROBATE 

Court address 

Court telephone no. 

Plaintiff s/Petitioner’s name(s) and address(es) 

[4] Appellant 

Southeast Group LLC 

0 Appellee 

Defendant’s/Respondent’s name(s) and address(es) 

[J Appetiant 

City of Detroit 

appellee 

Plaintiff's attorney, bar no., address, and telephone no. 

Stewart L. Mandell {(P33781}, Jackie J. Cook {P68781), 

Christina Grossi (P67482), Honigman LLP, 39400 Woodward 

Avenue, Suite 101, Bloomfleid Hills, M1 48304, 

(313) 465-7420, (248) 566-8474 

Defendant's attorney, bar no., address, and telephone no. 

Kevin Richard (P43417}, City of Detroit Law Department, 

CAYMC - 2 Woodward Avenue, Suite S00, Detroit, Ml 48226, 

(313) 237-3061 

In the matter of 

Other interested parly(ies) of probate matter 

1. Southeast Group LLC 

Name 

September 25, 2025 

in the Michigan Tax Tribunal 

claims an appeal from a final judgment or final order entered on 

Court of the State of Michigan, 

Date 

Court name and number or county 

by 

[ldistrictjudge 

[circuit judge 

Presiding judge Patricia L. Halin 

[J probate judge 

[J district court magistrate 

Name of judge or district court magistrate 

2. Bond on appealis 

~~ [lfiled. 

 [Jattached. 

3. (Ja. The transcript has been ordered. 

[Ib. The transcript has been filed. 

¢. No record was made. 

[J waived. ____-— 

ar no. 

[I not required.

Page 3

Claim of Appeal 

(9/23) 

Page 2012 

Case No. 25-002897 

14, THIS CASE INVOLVES 

[Ja. ACONTEST AS TO THE CUSTODY OF A MINOR CHILD. 

[Ib. AN ADULT OR MINOR GUARDIANSHIP UNDER THE ESTATES AND PROTECTED INDIVIDUALS CODE OR 

UNDER THE MENTAL HEALTH CODE. 

Cle. AN INVOLUNTARY MENTAL HEALTH TREATMENT CASE UNDER THE MENTAL HEALTH CODE. 

ld. 

ARULING THAT A PROVISION OF THE MICHIGAN CONSTITUTION, A MICHIGAN STATUTE, A RULE OR 

REGULATION INCLUDED IN THE MICHIGAN ADMINISTRATIVE CODE, OR ANY OTHER ACTION OF THE 

LEGISLATIVE OR EXECUTIVE BRANCH OF STATE GOVERNMENT 1S INVALID, 

[Je. AN ADOPTION ORDER UNDER CHAPTER X OF THE PROBATE CODE, 

[Jf AFREEDOM OF INFORMATION ACT ISSUE. 

10/6/2025 

Stewart L. Mandell 

Date 

Appollant/Attomey signature 

PROOF OF SERVICE 

| certify that copies of this claim of appeal and bond (if required) were served on 

Kevin Richard 

on 10/6/2025 

by 

[lpersonal service. 

[first-class mail. 

Name 

Dale 

on 

by 

[personal service. 

[lfirst-class mal. 

Name 

Date 

on 

by 

[personal service. 

[first-class mail. 

Name 

Date 

10/6/2025 

/s/ Lisa Joseph 

Dale 

Signature

Page 4

Michigan Court of Appeals 

Lower Court/Tribunal: Michigan Tax Tribunal 

Jurisdictional Checklist 

25-002897 

Lower Court Case No.: 

case Name: SOUtheast Group LLC v City of Detroit 

INSTRUCTIONS: For a givil claim of appeal, please complete the following statements. 

[SELECT ONE] An appeal of right may be filed because the order is: 

MCR 7.203(A) 

1] 

A final order of the circuit court under MCR 7.202(6). Specify subsection: 

] 

A probate court order that falls within MCR 5.801(A). Specify subsection: 

MI Const. ant 6, sec 28; MCL 205.763(1); MCR 7.203(A)(2) 

Appealable as of right by law or court rule. Specify law or rule: 

[SELECT ONE] This claim of appeal is timely because it is being filed: 

MCR 7.204(A) 

Within 21 days from entry of the order appealed from (as identified above). 

] 

Within 21 days of an order deciding a motion for new trial, rehearing, reconsideration, or other relief from 

the order appealed, and the postiudgment motion was filed within 21 days of the order appealed from. 

Other: 

INSTRUCTIONS: Please complete the checklist and file with your claim of appeal. 

Failure to file all required documents and requisite fees may result in rejection of 

MCR 7.201(8)(2) 

your claim of appeal. 

A signed claim of appeal. The caption must list all of the parties in each lower court 

MCR 7.204(B)(1) & (D) 

case appealed. 

A copy of the order you are appealing {as identified in Jurisdiction section). 

MCR 7.204(C)(1) 

An official current register of actions from the lower court or tribunal showing entry 

MCR 7.204(C)(5) 

of the order appealed. 

The filing fee or exception (example: motion to waive fees). 

MCR 7.202(3), 

MCR 7.204(B)(2) 

Evidence of the transcript (Select one): 

MCR 7.204(C)(2) 

M The complete transcript has been ordered. 

MCR 7.210(B)(1)a) 

No transcript will be filed. 

MCR 7.204(C)(2)

Page 5

Order Appealed

Page 6

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLCN 1. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Southeast Group LLC, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MTT Docket No. 25-002897 

City of Detroit, 

Presiding Judge 

Respondent. 

Patricia L. Halm 

ORDER OF DISMISSAL 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner's appeal. The pleadings indicate that Petitioner is appealing the true cash 

value, state equalized value, and taxable value (TV) for Parcel Nos. 01003901.002, 

01003901.003,

Page 7

MTT

Page 8

MTT

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Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

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

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

Southeast Group LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002897 

 

City of Detroit, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner’s appeal. The pleadings indicate that Petitioner is appealing the true cash 

value, state equalized value, and taxable value (TV) for Parcel Nos. 01003901.002, 

01003901.003, 01003913., 01003914., 01003915., and 01003916. for the 2025 tax 

year. The Tribunal has no authority over those parcels under MCL 205.735a(6), 

however, because these parcels of property are classified as commercial and the 

petition in this case was filed on July 28, 2025. As such, Petitioner failed to appeal the 

assessment to the Tribunal by the statutory deadline of June 2, 2025.1 

 

Petitioner’s failure to file the appeal by the statutory deadline is a failure to invoke the 

Tribunal’s statutory jurisdiction over this proceeding.2 In Sixarp, the Michigan Supreme 

Court reiterated previous appellate decisions in its reasoning that the Tribunal’s 

jurisdiction is statutory by nature. The Court stated: 

 

MCL 205.735a(3) “is not a notice statute, but is a jurisdictional statute that 

governs when and how a petitioner invokes the Tax Tribunal’s jurisdiction.” 

We therefore overrule Parkview3 to the extent that it incorrectly held that the 

protest requirement of . . . the precursor to MCL 205.735a . . . is a mere 

“procedural requirement for perfecting an appeal in the Tax Tribunal” and 

not an express limitation on the MTT’s jurisdiction. Instead, the protest 

requirement of MCL 205.735a(3) may only be waived by the court if 

necessary to remedy a constitutional due-process violation that deprived 

the taxpayer of their ability to invoke the right to protest.4 

 

The Tribunal finds that the same reasoning relied upon by the Sixarp court is applicable 

to MCL 205.735a(6) in this case. The Legislature created a statutory jurisdiction 

 

1 MCL 205.735a(6) states in pertinent part: “The jurisdiction of the tribunal in an assessment dispute as to 

property classified . . . as commercial real property . . . is invoked by a party in interest, as petitioner, filing 

a written petition on or before May 31 of the tax year involved.” Further, the deadline was extended to 

June 2, 2025 because May 31 fell on a Saturday. See MCL 205.735a(8). 

2 See Sixarp, LLC v Byron Twp, __Mich __; __ NW3d __ (2025) (Docket No 166190) at 8. 

3 Parkview Memorial Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (Parkview) (1990). 

4 See Sixarp at 8 (citations omitted).

Page 2

MTT Docket No. 25-002897 

Page 2 of 3 

 

requirement that a commercial property valuation appeal be filed with the Tribunal by 

May 31 of the tax year under appeal. This statutory subsection, like MCL 205.735a(3), 

controls the Tribunal’s jurisdiction over an appeal. The Tribunal has no equitable power 

to disregard a statutory filing deadline.5 “[S]imply because the plaintiffs' underlying 

claim has a constitutional dimension, and may even be meritorious, does not excuse the 

plaintiffs' failure to assert their claim within the applicable statutory period of limitation.”6 

 

The Tribunal notes that the petition in this case contends that Petitioner filed a property 

transfer affidavit in 20247 and that Petitioner did not receive the notice of assessment 

until “[a]fter July 1, 2025.”8 Petitioner also pleads that there is a dispute as to loss,9 and 

the Tribunal notes that any potential contention affecting TV requires a “mandatory and 

automatic” review to properly consider the determination of TV.10 Notwithstanding, 

these contentions of improper notice, if actionable, would require a determination by an 

applicable authority that the purported error resulted in a due-process violation. As 

explained above, the Tribunal lacks any equitable authority to consider a potential due-

process violation. The Tribunal’s jurisdiction as a result of a failure of a unit of 

government to comply with a statutory obligation, if there was any, may be vested upon 

the Tribunal by a judicial body only as a matter of equity.11 Lacking jurisdiction, the only 

appropriate action is dismissal. Therefore, 

 

IT IS ORDERED that the case is DISMISSED. 

 

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

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

 

5 The Tribunal’s powers are limited to those authorized by statute and do not include powers of equity. 

See Federal-Mogul Corp v Dep’t of Treasury, 161 Mich App 346 (1987), Elec Data Sys Corp v Flint Twp, 

253 Mich App 538 (2002), and VanderWerp v Plainfield Twp, 278 Mich App 624 (2008). 

6 See Szymanski v City of Westland, 420 Mich 301, 303; 362 NW2d 224, 225 (1984). 

7 Petition at paragraph 12. 

8 Id. at paragraph 13-14. 

9 Id. at paragraph 10. 

10 See Michigan Properties, LLC v Meridian Twp, 491 Mich 518, 531; 817 NW2d 548 (2012). 

11 See Sixarp at 4, 8. The

Page 3

MTT

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Southeast Group LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002897

City of Detroit,

Respondent.

ORDER OF DEFAULT

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

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

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

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

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

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

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

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

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

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

By:_______________________________

Entered: September 18, 2025

Patricia L. Halm, Tribunal Chair

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

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

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

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

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

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

Page 2

MTT Docket No. 25-002897

Page 2 of 6

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

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

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

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

act, MCL 205.735a.” TTR 225(5)

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Southeast Group LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002897

City of Detroit,

Respondent.

ORDER OF DEFAULT

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

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

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

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

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

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

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

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

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

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

By:_______________________________

Entered: September 18, 2025

Patricia L. Halm, Tribunal Chair

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

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

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

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

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

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

Page 4

MTT Docket No. 25-002897

Page 4 of 6

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

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

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

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

act, MCL 205.735a.” TTR 225(5)

Page 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

Southeast Group LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002897

City of Detroit,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the

Page 6

MTT Docket

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Page 1

25-0053

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Southeast Group LLC,

Petitioner,

v.

City of Detroit,

Respondent,

MTT Docket No. ________

Parcel Nos. 01003901.002,

01003901.003, 01003913.,

01003914., 01003915., and

01003916.

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

jcook@honigman.com

Petition

Southeast Group LLC (“Petitioner”), through its attorneys, Honigman LLP, says:

1.

Petitioner's principal office is 630 Woodward Avenue, Detroit, MI 48226.

2.

Petitioner is a party in interest with respect to property taxes on tax parcel numbers

01003901.002, 01003901.003, 01003913., 01003914., 01003915., and 01003916. (collectively,

"Petitioner's Property"), with addresses that include 333 E. Jefferson Ave. and 460 Randolph,

Detroit, located in Wayne County, Michigan.

3.

Petitioner’s Property is commonly known as being part of the Millender Center,

including the Millender Center parking deck. The tax parcels comprising Petitioner’s Property are

contiguous. Petitioner’s Property includes over 1,700 parking spots.

Page 2

2

61478223.5

4.

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's

Property.

5.

The values in the chart below show the 2025 assessed value, state equalized value

and taxable value of Petitioner’s Property, which values are the result of Respondent’s actions.

Also included in the chart are Petitioner’s contended and requested values for 2025.

6.

Petitioner’s Property is classified as commercial real.

7.

Petitioner’s Property is presently used or available for use for commercial purposes.

8.

Petitioner believes that Petitioner’s Property was originally designed to be used for

commercial purposes.

9.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable

value, (d) due process and equal protection under the Constitutions of the United States and the

State of Michigan, (e) the assessment notice requirements of the General Property Tax Act, and

(f) uniformity.

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute

relative to the value of a loss.

11.

No board of review protest was required for Petitioner’s Property.

Page 3

3

61478223.5

12.

During 2024, Petitioner, i) acquired Petitioner’s Property, and ii) Petitioner filed

a property transfer affidavit, which advised Respondent of the transfer, the property’s

purchase price of approximately $32,901,540, and Petitioner’s address.

13.

Petitioner has never received any notices of assessment for Petitioner’s Property.

14.

After July 1, 2025, was the first time that Petitioner became aware of the 2025

assessments for Petitioner’s Property.

15.

Throughout this year, and even after July 1, 2025, Respondent’s records for

Petitioner’s Property had an incorrect address for mailing notices to Petitioner.

16.

Petitioner was not sent and did not receive lawful notice of the 2025 assessments

for Petitioner’s Property. Therefore, in this case Petitioner is entitled to a determination of the

lawful values of Petitioner’s Property, and the Tribunal has jurisdiction to decide this case.

17.

Each 2025 assessment, including state equalized value and taxable value, imposed

on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and unlawful

for the reasons that:

(a)

Each 2025 assessment, including state equalized value and/or taxable value,

exceeds the amount permitted by the Michigan Constitution and applicable statutes;

(b)

Each 2025 assessment, including state equalized value and/or taxable value,

is at a higher percentage of true cash value than permissible under the Michigan Constitution and

applicable statutes;

(c)

Each 2025 assessment, including taxable value and/or state equalized value,

is based upon an erroneous determination of the true cash value of that portion of Petitioner’s

Property that is taxable under Michigan law, and is based upon the application of wrong principles;

and,

Page 4

4

61478223.5

(d)

Each 2025 assessment, including state equalized value and/or taxable value,

and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny

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

WHEREFORE,

Petitioner

requests

that

the

Tax

Tribunal

enter

an

Order:

(i) reducing each 2025 assessed value, state equalized value, and taxable value of Petitioner’s

Property as shown in the table in paragraph five above; (ii) requiring payment to Petitioner of the

refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any

other relief to which it is entitled.

Dated: July 28, 2025

Respectfully submitted,

HONIGMAN LLP

Attorneys for Petitioner

By:

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

jcook@honigman.com

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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

Southeast Group LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002897

City of Detroit, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: August 20, 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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Southeast Group LLC, 

Petitioner, 

v. 

MTT Docket 

No. od 

> =O ( 2K 9 4 

[Parcel No(s). 01003913.(see additional parcels 

on attached list)] 

Detroit, 

Respondent. 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, 

and that on 

70 s/ A s she did serve 

a copy of Petitioner's Petition, with docket 

number, upon the parties named on the attached list. 

V7» 

Lisa Joseph 

(Ei 

A

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

ASSESSOR 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WAYNE COUNTY 

CAYMC, 2 WOODWARD AVENUE #211 

DETROIT, MI 48226 

DIRECTOR OF EQUALIZATION 

WAYNE COUNTY 

500 GRISWOLD ST. 21ST FLOOR 

DETROIT, MI 48226 

SECRETARY OF SCHOOL BOARD 

DETROIT PUBLIC SCHOOLS 

7321 2ND AVENUE, 14TH FLOOR 

DETROIT, MI 48202-4050 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0088

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Page 1

25-0053

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Southeast Group LLC,

Petitioner,

v.

City of Detroit,

Respondent,

MTT Docket No. ________

Parcel Nos. 01003901.002,

01003901.003, 01003913.,

01003914., 01003915., and

01003916.

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

jcook@honigman.com

Petition

Southeast Group LLC (“Petitioner”), through its attorneys, Honigman LLP, says:

1.

Petitioner's principal office is 630 Woodward Avenue, Detroit, MI 48226.

2.

Petitioner is a party in interest with respect to property taxes on tax parcel numbers

01003901.002, 01003901.003, 01003913., 01003914., 01003915., and 01003916. (collectively,

"Petitioner's Property"), with addresses that include 333 E. Jefferson Ave. and 460 Randolph,

Detroit, located in Wayne County, Michigan.

3.

Petitioner’s Property is commonly known as being part of the Millender Center,

including the Millender Center parking deck. The tax parcels comprising Petitioner’s Property are

contiguous. Petitioner’s Property includes over 1,700 parking spots.

Page 2

2

61478223.5

4.

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's

Property.

5.

The values in the chart below show the 2025 assessed value, state equalized value

and taxable value of Petitioner’s Property, which values are the result of Respondent’s actions.

Also included in the chart are Petitioner’s contended and requested values for 2025.

6.

Petitioner’s Property is classified as commercial real.

7.

Petitioner’s Property is presently used or available for use for commercial purposes.

8.

Petitioner believes that Petitioner’s Property was originally designed to be used for

commercial purposes.

9.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable

value, (d) due process and equal protection under the Constitutions of the United States and the

State of Michigan, (e) the assessment notice requirements of the General Property Tax Act, and

(f) uniformity.

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute

relative to the value of a loss.

11.

No board of review protest was required for Petitioner’s Property.

Page 3

3

61478223.5

12.

During 2024, Petitioner, i) acquired Petitioner’s Property, and ii) Petitioner filed

a property transfer affidavit, which advised Respondent of the transfer, the property’s

purchase price of approximately $32,901,540, and Petitioner’s address.

13.

Petitioner has never received any notices of assessment for Petitioner’s Property.

14.

After July 1, 2025, was the first time that Petitioner became aware of the 2025

assessments for Petitioner’s Property.

15.

Throughout this year, and even after July 1, 2025, Respondent’s records for

Petitioner’s Property had an incorrect address for mailing notices to Petitioner.

16.

Petitioner was not sent and did not receive lawful notice of the 2025 assessments

for Petitioner’s Property. Therefore, in this case Petitioner is entitled to a determination of the

lawful values of Petitioner’s Property, and the Tribunal has jurisdiction to decide this case.

17.

Each 2025 assessment, including state equalized value and taxable value, imposed

on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and unlawful

for the reasons that:

(a)

Each 2025 assessment, including state equalized value and/or taxable value,

exceeds the amount permitted by the Michigan Constitution and applicable statutes;

(b)

Each 2025 assessment, including state equalized value and/or taxable value,

is at a higher percentage of true cash value than permissible under the Michigan Constitution and

applicable statutes;

(c)

Each 2025 assessment, including taxable value and/or state equalized value,

is based upon an erroneous determination of the true cash value of that portion of Petitioner’s

Property that is taxable under Michigan law, and is based upon the application of wrong principles;

and,

Page 4

4

61478223.5

(d)

Each 2025 assessment, including state equalized value and/or taxable value,

and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny

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

WHEREFORE,

Petitioner

requests

that

the

Tax

Tribunal

enter

an

Order:

(i) reducing each 2025 assessed value, state equalized value, and taxable value of Petitioner’s

Property as shown in the table in paragraph five above; (ii) requiring payment to Petitioner of the

refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any

other relief to which it is entitled.

Dated: July 28, 2025

Respectfully submitted,

HONIGMAN LLP

Attorneys for Petitioner

By:

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

jcook@honigman.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

Southeast Group LLC

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

630 Woodward Avenue

39400 Woodward

Suite 101

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3134657420

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

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

slmandell@honigman.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?6

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

Michigan

Taxing Authority (City or Township)

City of Detroit (Wayne)

County

Wayne

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

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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

01003901.002

Classification of Property: Real 

Commercial

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

4353900

Current Taxable Value as established by the Board of Review:

2507078

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

3939400

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

1969700

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

Parcel Number:

01003901.003

Classification of Property: Real 

Commercial

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

2119800

Current Taxable Value as established by the Board of Review:

395851

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

1841000

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

920500

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

Parcel Number:

01003913.

Classification of Property: Real 

Commercial

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

30553200

Current Taxable Value as established by the Board of Review:

30443200

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

26534800

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

13267400

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

Parcel Number:

01003914.

Classification of Property: Real 

Commercial

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

330100

Current Taxable Value as established by the Board of Review:

126529

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

286600

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

143300

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

Parcel Number:

01003915.

Classification of Property: Real 

Commercial

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

51200

Current Taxable Value as established by the Board of Review:

23898

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

44400

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

22200

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

Parcel Number:

01003916.

Classification of Property: Real 

Commercial

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

293900

Current Taxable Value as established by the Board of Review:

18110

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

255200

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

127600

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

Page 5

STATE

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