Square Knot 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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002191

City of Detroit,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

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

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: September 15, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002191

City of Detroit,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

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

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: September 15, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

SQUARE KNOT, LLC, 

Petitioner, 

vs. 

CITY OF DETROIT, 

Respondent. 

 

Docket No. 25-002191 

 

 

Troy C. Otto (P67448) 

Fischer, Franklin & Ford 

24725 W. 12 Mile Road, Suite 230 

Southfield, Michigan 48034 

(313) 962-5210 

otto@fischerfranklin.com 

Kevin C. Richard (P43417) 

Mary Beth Cobbs (P40080) 

City of Detroit Law Department Coleman A. 

Young Municipal Center 

2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3061 

 

 

STIPULATION TO DISMISS 

 

Petitioner and Respondent hereby stipulate to the dismissal of Petitioner’s appeal with 

prejudice and without costs or attorney fees to either party. 

 

/s/ Troy C. Otto (w/permission) 

Troy C. Otto (P67448) 

FISCHER, FRANKLIN & FORD 

Attorneys for Petitioner 

 

Dated: September 11, 2026 

 

/s/ Kevin C. Richard 

KEVIN C. RICHARD (P43417) 

MARY BETH COBBS (P40080) 

Attorneys for Respondent 

 

Dated: September 9, 2026

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 25-002191

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

Party Filing Document 

Joint

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Square Knot LLC MTT# 25-002191 withdrawal

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

 

MTT Docket No. 25-002191 

City of Detroit,

Respondent.

ORDER GRANTING PETITIONER’S MOTION TO AMEND

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

has been filed requesting that the Tribunal permit Petitioner to amend the petition filed in 

this case to include the subsequent tax year. Respondent has not filed a response to the 

Motion to Amend. More importantly, the motion is timely under MCL 205.737 and 

205.735a and Petitioner has shown good cause to justify the granting of the motion. 

Therefore,

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED.

IT IS FURTHER ORDERED that this order only grants the relief indicated above and 

does not find as true any allegations of fact or provide any other relief requested by the 

motion.

By:___________________________________

Patricia L. Halm, Tribunal Chair

Entered: June 26, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

 

MTT Docket No. 25-002191 

City of Detroit,

Respondent.

ORDER GRANTING PETITIONER’S MOTION TO AMEND

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

has been filed requesting that the Tribunal permit Petitioner to amend the petition filed in 

this case to include the subsequent tax year. Respondent has not filed a response to the 

Motion to Amend. More importantly, the motion is timely under MCL 205.737 and 

205.735a and Petitioner has shown good cause to justify the granting of the motion. 

Therefore,

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED.

IT IS FURTHER ORDERED that this order only grants the relief indicated above and 

does not find as true any allegations of fact or provide any other relief requested by the 

motion.

By:___________________________________

Patricia L. Halm, Tribunal Chair

Entered: June 26, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Square Knot, LLC 

 

 

 

Petitioner, 

 

v 

 

 

 

 

 

 

 

MTT Docket No.: 25-002191 

 

City of Detroit, 

 

 

 

Respondent, 

 

 

 

 

 

 

______________________________________________________________________________ 

 

FISCHER, FRANKLIN & FORD 

 

 

CITY OF DETROIT LAW DEPARTMENT 

Troy C. Otto (P67448) 

 

 

 

Kevin C. Richard (P43417) 

Attorney for Petitioner 

 

 

 

Perry L.Yun (P39446) 

24725 W. 12 Mile Road, Suite 230 

 

Attorney for Respondent 

Southfield, MI 48034 

 

 

 

Coleman A. Young Municipal Center 

(313) 962-5210 

 

 

 

 

2 Woodward Avenue, Suite 500 

otto@fischerfranklin.com 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

 

313-237-3061 

 

 

 

 

 

 

 

richkc@detroitmi.gov 

______________________________________________________________________________ 

 

 

 

MOTION TO AMEND TO ADD SUBSEQUENT TAX YEAR 

Petitioner, by its attorneys, for its Motion states as follows: 

1. The case involves a commercial property commonly known as 4428 Second, located in 

the City of Detroit, County of Wayne, State of Michigan, Parcel Number 02002373. 

2. This appeal is pending for the 2025 tax year and the Petitioner requests to include the 

subsequent tax year assessment for the 2026 tax year pursuant to MCL 205.737 and 

Mich. Admin. Code R. 792.10219. 

3. Counsel for the Respondent City of Detroit does not object to this proposed amendment. 

4. The values for the property identified above as established by Respondent for 2026 are: 

$421,200 (Assessed Value); $16,511 (Taxable Value) and $842,400 (True Cash Value).

Page 2

5. Petitioner contends that the values for the property above are: $150,000 (Assessed 

Value); $16,511 (Taxable Value) and $300,000 (True Cash Value). 

WHEREFORE, Petitioner requests that the Entire Tribunal Property Tax Petition be amended to 

include the 2026 tax year. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: ____________________ 

 

 

 

 

 

 

 

 

 

Troy C. Otto 

 

 

 

 

 

 

 

 

FISCHER, FRANKLIN & FORD 

 

 

 

 

 

 

 

 

24725 W. 12 Mile Road, Suite 230 

 

 

 

 

 

 

 

 

Southfield, MI 48034 

 

 

 

 

 

 

 

 

(313) 962-5210 

 

 

 

 

 

 

 

 

otto@fischerfranklin.com

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

BEFORE THE MICHIGAN TAX TRIBUNAL 

 

 

Square Knot, LLC 

 

 

Petitioner, 

 

v. 

 

 

 

 

 

 

 

MTT Docket No.: 25-002191 

 

City of Detroit, 

 

 

Respondent, 

 

 

 

 

 

 

__________________________________________) 

 

PROOF OF SERVICE 

 

 

It is hereby certified that on May 29, 2026 the Motion To Amend To Add Subsequent Tax 

Year, were served on the City of Detroit Law Department, by mailing a copy of the same via first-

class certified mail to the following: 

 

City of Detroit Law Department 

Kevin C. Richard 

Coleman A. Young Municipal Center 

2 Woodward Ave, Suite 500 

Detroit, MI 48226 

 

 

I declare under penalties of perjury that this Proof of Service has been examined by me and that 

its contents are true to the best of my information, knowledge, and belief. 

 

 

 

______________________________ 

 

 

 

 

 

 

 

 

 

Troy C. Otto

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Page 1

1 of 1

Docket #: 25-002191

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF JANUARY 19 - 29, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Square Knot LLC,

Petitioner,

v

 

 

City of Detroit,

Respondent.

 MTT Docket No. 25-002191

Please be advised that 25-002191 has been placed on a two-week Prehearing General 

Call commencing January 19, 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. 25-002191

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 September 22, 2026. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a

Page 3

MT

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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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002191

City of Detroit,

Respondent.

ORDER SETTING ASIDE DEFAULT

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

Respondent was held in default on August 21, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 9, 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

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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002191

City of Detroit,

Respondent.

ORDER SETTING ASIDE DEFAULT

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

Respondent was held in default on August 21, 2025, and the default has been timely 

cured. The documents curing the default can be reviewed through the docket search 

function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket 

number and clicking on the document link next to the line item entry for the documents. 

Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By_________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 9, 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

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SQUARE KNOT, LLC, 

 

Petitioner, 

v. 

Docket No. 25-002191 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

ANSWER 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

 

2. Respondent admits. 

 

3. No response necessary. 

 

4. No response necessary. 

 

5. No response necessary. 

 

6. Respondent denies as untrue. The subject property is classified as residential. 

 

7. Upon information and belief, Petitioner did not file an appeal to the Board of Review as 

required by MCL 205.735a(3) 

8. Respondent asserts that this Honorable Tribunal does not have jurisdiction over this 

matter as Petitioner failed to file an appeal to the Board of Review as required by MCL 

205.735a(3). 

9. No response necessary. 

 

10. Respondent admits.

Page 2

2 

 

11. Respondent admits. 

 

12. Respondent admits. 

 

13. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

relating to true cash and taxable values, however, Respondent denies that any such 

allegation has merit. 

14. Respondent admits. 

 

15. No response necessary. 

 

16. Respondent admits. 

 

17. Respondent neither admits nor denies the allegation, there being an insufficient basis at 

this time upon which to form a belief as to the truth of the allegation. 

18. Based solely upon Petitioner’s unsubstantiated value contentions Respondent admits. 

19. Prayer for relief, no response necessary. 

20. Respondent denies as untrue. 

 

 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

 

1. Petitioner’s claims are barred by the applicable statute of limitations. 

2. Petitioner has failed to state a claim for which relief may be granted. 

 

3. Petitioner lacks standing. 

 

4. This Honorable Tribunal lacks jurisdiction over this matter.

Page 3

3 

 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

Respectfully Submitted, 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Mary Beth Cobbs (P40080) 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3061 

Dated: September 4, 2025

Page 4

4 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SQUARE KNOT, LLC, 

 

Petitioner, 

v. 

Docket No. 25-002191 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

PROOF OF SERVICE 

 

On September 4, 2025, I mailed by first class mail a copy of Respondent’s Answer w/Affirmative 

Defenses in the instant matter to: 

 

Troy C. Otto 

Fischer, Franklin & Ford 

24725 W. 12 Mile Road, Suite 230 

Southfield, Michigan 48034 

 

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

 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Senior Assistant Corporation Counsel 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Dated: September 4, 2025 

Detroit, Michigan 48226

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002191

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City of Detroit (Wayne)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Kevin

M.I.

C

Last Name

Richard

Firm Name (if any)

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

2 Woodward Avenue, Suite 500

City of Detroit Law Department

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-237-3061

Fax Number

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

richkc@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kevin C Richard

/s/

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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

Square Knot LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002191

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: August 21, 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. 25-002191

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

Square Knot LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 25-002191

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

Page 4

MTT

Page 5

ST

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER 

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

ORLENE HAWKS 

DIRECTOR

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

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 

Petitioner, 

v 

MOAHR Docket No. ___________ 

______________________, 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is ___real ___personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes ___No. (If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as _________________________ 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent’s ___ March ___ July ___December Board of Review. 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

SQUARE KNOT, LLC

CITY OF DETROIT 

02002373

XXX

N/A

COMMERCIAL

Page 2

MOAHR Docket No. _________________ 

Page 2 of 4 

9. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

12. 

Petitioner’s legal residence or principal office address is: 

13. 

This appeal involves issues relating to the (check all that are applicable): 

________the property or properties’ true cash and taxable values 

________the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

 under MCL ______ 

14. 

The tax year(s) at issue are: _______________________________________ 

N/A

N/A

WAYNE

4428 SECOND AVE. 

DETROIT, MI 48201

CITY OF DETROIT

4428 SECOND AVE.

Page 3

MO

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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

Square Knot LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002191

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 15, 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 

BEFORE THE MICHIGAN TAX TRIBUNAL 

 

 

Square Knot, LLC, 

 

Petitioner, 

 

V 

 

 

 

 

 

 

 

MOAHR Docket No.: 25-002191 

 

City of Detroit, 

 

Respondent, 

 

 

 

 

 

 

__________________________________________) 

 

PROOF OF SERVICE 

 

 

It is hereby certified that on June 5, 2025, the Notice of Docket Number and Entire Tribunal 

Property Tax Petition were served on the City of Detroit Assessors Office and Detroit City Clerks 

Office by mailing a copy of the same via first-class certified mail to the following: 

 

City of Detroit – Assessors Office 

 

 

 

City of Detroit Clerk’s Office 

2 Woodward Ave, Suite 130 

 

 

 

2 Woodward Ave, Suite 200 

Detroit, MI 48226 

 

 

 

 

 

Detroit, MI 48226 

 

 

I declare under penalties of perjury that this Proof of Service has been examined by me and that 

its contents are true to the best of my information, knowledge, and belief. 

 

 

______________________________ 

 

 

 

 

 

 

 

 

 

Troy C. Otto

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Page 1

STATE OF MICHIGAN 

BEFORE THE MICHIGAN TAX TRIBUNAL 

 

 

 

Square Knot, LLC 

 

Petitioner, 

 

V 

 

 

 

 

 

 

 

MOAHR Docket No.: 25-002191 

 

City of Detroit, 

 

Respondent, 

 

 

 

 

 

 

__________________________________________) 

 

PROOF OF SERVICE 

 

 

It is hereby certified that on June 5, 2025 the Notice of Docket Number and Entire Tribunal 

Property Tax Petition were served on the County Equalization Director for Wayne County, Wayne 

County Clerk, Secretary of Detroit School Board and Treasurer of State of Michigan by mailing a 

copy of the same via first-class mail to the following: 

 

County Equalization Director for Wayne County 

 

Wayne County Clerks Office 

500 Griswold, 21st Fl 

 

 

 

 

Coleman A. Young Municipal Center 

Detroit, MI 48226-2831 

 

 

 

 

2 Woodward Ave #201 & #207 

 

 

 

 

 

 

 

 

Detroit, MI 48226 

 

Vania Moore 

 

 

 

 

 

State of Michigan Treasurer 

Secretary to the Board of Education 

 

 

New Center One 

Fisher Building 

 

 

 

 

 

3060 E. Grand Blvd 

3011 W. Grand Blvd, 12th Floor 

 

 

 

Detroit, MI 48202 

Detroit, MI 48202 

 

State of Michigan Treasurer 

430 W. Allegan St. 

Lansing, MI 48933 

 

I declare under penalties of perjury that this Proof of Service has been examined by me and that 

its contents are true to the best of my information, knowledge, and belief. 

 

 

 

______________________________ 

 

 

 

 

 

 

 

 

 

Troy C. Otto

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER 

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

ORLENE HAWKS 

DIRECTOR

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

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 

Petitioner, 

v 

MOAHR Docket No. ___________ 

______________________, 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is ___real ___personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes ___No. (If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as _________________________ 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent’s ___ March ___ July ___December Board of Review. 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

SQUARE KNOT, LLC

CITY OF DETROIT 

02002373

XXX

N/A

COMMERCIAL

Page 2

MOAHR Docket No. _________________ 

Page 2 of 4 

9. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

12. 

Petitioner’s legal residence or principal office address is: 

13. 

This appeal involves issues relating to the (check all that are applicable): 

________the property or properties’ true cash and taxable values 

________the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

 under MCL ______ 

14. 

The tax year(s) at issue are: _______________________________________ 

N/A

N/A

WAYNE

4428 SECOND AVE. 

DETROIT, MI 48201

CITY OF DETROIT

4428 SECOND AVE.

Page 3

MO

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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

SQUARE KNOT, LLC

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

4470 Second Ave.

City or Town

Detroit

State

Michigan

ZIP Code

48201

Telephone Number

(313) 610-8086

Fax Number

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

scott@traffic-jam.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Troy

M.I.

C

Last Name

Otto

Firm Name (if any)

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

24725 W 12 Mile Rd Suite 230

City or Town

Southfield

State

Michigan

ZIP Code

48034

Telephone Number

313-962-5210

Fax Number

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

otto@fischerfranklin.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]

4428 SECOND AVE.

DETROIT

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? 

(*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:

02002373

Classification of Property: Real 

Commercial

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

392500

Current Taxable Value as established by the Board of Review:

16077

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

300000

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

150000

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

16077

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

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