Record Finder / 25-002276-TT
Michigan
Target Corporation, Petitioner Vs. Township Of Clinton, Respondent
- Petitioner
- Target Corporation
- Respondent
- Township Of Clinton
Case overview
- Docket number
- 25-002276-TT
- Status
- Abeyance
- CaseType
- ET Property
- Division
- ET
- County
- Macomb
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 12 | A response to motion was filed. | Not recorded | Not recorded | 06/04/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 11 | Motion to Amend Subsequent Year was received. | PET | Not recorded | 05/14/2026 | $300.00 | Download |
| 10 | Granted | Not recorded | 8 | 10/22/2025 | Not recorded | Download |
| 9 | Order granting Motion. | Not recorded | 8 | 10/22/2025 | Not recorded | Download |
| 8 | Motion for Abeyance was received. | Not recorded | Not recorded | 10/20/2025 | $50.00 | Download |
| 7 | Order Setting Aside R Default | Not recorded | Not recorded | 08/29/2025 | Not recorded | Download |
| 6 | Response to Order - Answer | RESP | 5 | 08/13/2025 | Not recorded | Download |
| 5 | Order Holding Party in Default | Not recorded | Not recorded | 08/07/2025 | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 06/11/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 06/16/2025 | Not recorded | Download |
| 2 | A petition has been filed. | PET | Not recorded | 06/11/2025 | Not recorded | Download |
| 1 | Order Severing from 24-003079 | Not recorded | Not recorded | 06/05/2025 | Not recorded | Download |
Documents
MTA 2026 Response_Target Clinton_FINAL.pdfRead complete document text →
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Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, v CLINTON TOWNSHIP, Respondent. Docket No. 25-002276 Parcel No. 16-11-34-328-004 _____________________________________________________________________________/ DANIEL L. STANLEY (P57052) JACKIE J. COOK (P68781) HONIGMAN LLP Attorneys for Petitioner 222 N. Washington Square, Suite 400 Lansing, MI 48933 (517) 377-0714 (313) 465-7270 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA A. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ RESPONDENT’S RESPONSE TO PETITIONER’S MOTION TO AMEND PETITION TO CONTEST 2026 ASSESSED AND TAXABLE VALUES Respondent, Clinton Township, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Motion to Amend as follows: 1. Respondent admits the allegations in Paragraph 1. 2. Respondent denies the allegations in Paragraph 2, including subparagraphs (a)-(d), 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
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2 principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 3. Respondent acknowledges the relief requested by Petitioner in the final paragraph of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in the above Paragraphs. Respondent incorporates by reference the affirmative defenses set forth in its Answer to Petition herein. WHEREFORE, Respondent, Clinton Township, requests the Tribunal enter an Order denying Petitioner’s Motion to Amend and dismissing the appeal. 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: June 4, 2026 (248) 731-3089
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3 PROOF OF MAILING On the date below I sent by electronic mail a copy of the foregoing Respondent’s Response to Petitioner’s Motion to Amend to: Daniel L. Stanley Honigman LLP dstanley@honigman.com Jackie J. Cook Honigman LLP jcook@honigman.com I declare that the statement above is true to the best of my information, knowledge and belief. /s/Kelsea M. Melcher____________ Dated: June 4, 2026 Kelsea M. Melcher
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MITAT_SubsequentFiling.pdfRead complete document text →
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1 of 1 Docket #: 25-002276 Party Filing Document Party Filing Document: Respondent Respondent If 'other', Identify: File Document Type: fuFile:
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25-002276.pdfRead complete document text →
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RECEIVED MAY 142026 x: Wo STATE OF MICHIGAN MICHIGAN Tax TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Target Corporation, Petitioner, V. MTT Docket No. 25-002276 Clinton Twp. - Macomb, Respondent. / Daniel L. Stanley (P57052) Laura M. Hallahan (P42101) Jackie J. Cook (P68781) Seth A. O’Loughlin (P80257) Honigman LLP Hallahan & Associates, P.C. Attorneys for Petitioner Attorneys for Respondent 222 N. Washington Square 1750 S. Telegraph Rd., Suite 202 Suite 400 Bloomfield Hills, MI 48302 Lansing, MI 48933 (248) 731-3089 (517) 377-0714 lhallahan@hallahanlaw.com (313) 465-7270 soloughlin@hallahanlaw.com dstanley@honigman.com jcook@honigman.com Motion to Amend Petition to Contest 2026 Assessed and Taxable Values Petitioner, Target Corporation, through its attorneys, Honigman LLP, moves to amend the Petition in this matter to include the following: I. In 2026, Respondent determined the taxable value of Petitioner’s Property to be $3,372,628 and Respondent assessed Petitioner’s Property at $5,545,100,which will result in a state equalized value of the same amount, based upon the tentative equalization factor. 2. The 2026 assessment, including state equalized value and taxable value,
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(a) The assessment, including state equalized value and/or taxable value, exceeds the amounts permitted by the Michigan Constitution and applicable statutes; (b) The 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) The 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 (d) The 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 moves that this Motion be granted, and Petitioner requests that the Tribunal enter an Order: (i) reducing the 2026 assessed and state equalized value from $5,545,100 to $2,127,000; (ii) reducing the 2026 taxable value from $3,372,628 to $2,127,000; (iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iv) awarding Petitioner any other relief to which it is entitled.
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Dated: 5/14/26 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: /s/ Daniel L. Stanley Daniel L. Stanley (P57052) Attorneys for Petitioner 222 N. Washington Square Suite 400 Lansing, MI 48933 (517) 377-0714 (313) 465-7270 dstanley@honigman.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, Vv. MTT Docket No. 25-002276 CLINTON TWP. - MACOMB, Respondent. / Proof of Service Lisa Joseph affirms that on 5/14/26 she served a copy of Petitioner's Motion to Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service in connection with the above-entitled cause upon the following: Laura Hallahan Attorneys for Respondent lhallahan@hallahanlaw.com via electronic mail. Dated: 5/14/26 /s/ Lisa Joseph Lisa Joseph
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Honigman LLP COSTS ADVANCED ACCOUNT Nn A A748 RECFTVED MAY 14 026 Re 0 Ye MICHIGAN TAX TRIBUNAL Invoice Date Invoice Number Invoice Narrative Payment Amount 5/14/26 040716 DLS/203729/43036 300.00 Motion to Amend 25-002276 24559387.1
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Joint Motion for Abeyance.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, v CLINTON TOWNSHIP, Respondent. Docket No. 25-002276 Parcel No. 16-11-34-328-004 _____________________________________________________________________________/ MICHAEL B. SHAPIRO (P20282) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA A. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-003079 The parties, by and through their respective counsel, state the following in support of the above captioned Motion: 1. The above captioned appeal concerns the 2025 valuation of the big box store commonly known as Target – Parcel No. 16-11-34-328-004 - located in Macomb County. 2. With the exception of the tax year at issue, the parties, property, and issues raised in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in MTT Docket No. 24-003079 – an appeal concerning the 2024 tax year. 3. The above captioned 2025 appeal is ready to be placed on a Prehearing General Call and Order of Procedure.
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2 4. However, as of the filing of the above captioned Motion, the 2024 matter (MTT Docket No. 24-003079) has not yet been resolved. A Prehearing Conference is scheduled for December 16-30, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered until Summer 2026 at the earliest. 5. A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24- 003079 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it could potentially be a waste of time and resources for the parties and the Tribunal to proceed with the above captioned appeal when the prior 2024 appeal remains pending. 6. To proceed with this case before a resolution regarding MTT Docket No. 24- 003079 has been reached would likely not constitute an efficient administration of justice. 7. Proceeding with the above captioned appeal will require the parties and the Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above captioned appeal in abeyance at this juncture before substantial time and resources have been spent – including, but not limited to, the preparation of prehearing statements and valuation disclosures – is in the interest of efficiency to all parties involved and judicial economy. 8. As evidenced above, there is good cause for granting this Motion to hold the above captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24- 003079. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-003079.
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3 Respectfully submitted, HONIGMAN LLP /s/ Daniel L. Stanley_______________ MICHAEL B. SHAPIRO (P20282) DANIEL L. STANLEY (P57052) Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 Dated: October 20, 2025 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 (248) 731-3089 Dated: October 20, 2025
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Payment Receipt Application: Merchant: Merchant City/State: Merchant Location Code: Payment Status: Result Message: Confirmation Number: Payment Date: Posting Date: Billing Information: Payment Amount: Card Type: Account #: Authorization Code: Method: Michigan Tax Tribunal - 8023112272 Michigan Tax Tribunal Dimondale, MI 00001 Success Success 25102050948780 10/20/2025 10/20/2025 Laura Hallahan 2573 Leroy Lane West Bloomfield, MI 48324 mtt@hallahanlaw.com 50.00 USD VISA XXXXXXXXXXXX9550 82556G Not Present
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1 Martin, Anna (LARA) From: noreply@fiserv.com Sent: Monday, October 20, 2025 1:57 PM To: MTT Subject: Payment
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25-002276 Grant Abeyance.pdfRead complete document text →
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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 Target Corporation, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-002276 Clinton Township, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE On October 20, 2025, the parties filed a joint motion requesting that the Tribunal hold this case in abeyance pending resolution of MTT Docket No. 24-003079, which is currently pending before the Tribunal. In the motion, the parties state that except for the tax year at issue, the above-mentioned case pertains to the same parties, property, and claims as the subject appeal, and its resolution could impact the proceedings in this matter. MTT Docket No. 24-003079 will not be scheduled for a hearing until early 2026, and a Final Opinion and Judgment will likely not be issued until Summer 2026 at the earliest. Proceeding in this matter could waste time and resources for both the parties and the Tribunal while MTT Docket No. 24-003079 remains pending. The Tribunal has considered the motion and the case file and finds that placing this case in abeyance pending resolution of MTT Docket No. 24-003079 will facilitate the efficient administration of justice, as that resolution may have a direct bearing on the outcome of the instant appeal. Therefore, IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 days of the resolution of MTT Docket No. 24-003079 as to the need for further proceedings in this matter. Entered: October 22, 2025 By _____________________________ cs 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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Joint Motion for Abeyance.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, v CLINTON TOWNSHIP, Respondent. Docket No. 25-002276 Parcel No. 16-11-34-328-004 _____________________________________________________________________________/ MICHAEL B. SHAPIRO (P20282) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA A. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-003079 The parties, by and through their respective counsel, state the following in support of the above captioned Motion: 1. The above captioned appeal concerns the 2025 valuation of the big box store commonly known as Target – Parcel No. 16-11-34-328-004 - located in Macomb County. 2. With the exception of the tax year at issue, the parties, property, and issues raised in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in MTT Docket No. 24-003079 – an appeal concerning the 2024 tax year. 3. The above captioned 2025 appeal is ready to be placed on a Prehearing General Call and Order of Procedure.
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2 4. However, as of the filing of the above captioned Motion, the 2024 matter (MTT Docket No. 24-003079) has not yet been resolved. A Prehearing Conference is scheduled for December 16-30, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered until Summer 2026 at the earliest. 5. A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24- 003079 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it could potentially be a waste of time and resources for the parties and the Tribunal to proceed with the above captioned appeal when the prior 2024 appeal remains pending. 6. To proceed with this case before a resolution regarding MTT Docket No. 24- 003079 has been reached would likely not constitute an efficient administration of justice. 7. Proceeding with the above captioned appeal will require the parties and the Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above captioned appeal in abeyance at this juncture before substantial time and resources have been spent – including, but not limited to, the preparation of prehearing statements and valuation disclosures – is in the interest of efficiency to all parties involved and judicial economy. 8. As evidenced above, there is good cause for granting this Motion to hold the above captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24- 003079. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-003079.
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3 Respectfully submitted, HONIGMAN LLP /s/ Daniel L. Stanley_______________ MICHAEL B. SHAPIRO (P20282) DANIEL L. STANLEY (P57052) Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 Dated: October 20, 2025 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 (248) 731-3089 Dated: October 20, 2025
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Payment Receipt Application: Merchant: Merchant City/State: Merchant Location Code: Payment Status: Result Message: Confirmation Number: Payment Date: Posting Date: Billing Information: Payment Amount: Card Type: Account #: Authorization Code: Method: Michigan Tax Tribunal - 8023112272 Michigan Tax Tribunal Dimondale, MI 00001 Success Success 25102050948780 10/20/2025 10/20/2025 Laura Hallahan 2573 Leroy Lane West Bloomfield, MI 48324 mtt@hallahanlaw.com 50.00 USD VISA XXXXXXXXXXXX9550 82556G Not Present
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1 Martin, Anna (LARA) From: noreply@fiserv.com Sent: Monday, October 20, 2025 1:57 PM To: MTT Subject: Payment
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Order_Setting_Aside_R_Default.2025-08-29_11-48-21.0000.pdfRead complete document text →
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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 Target Corporation, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002276 Township Of Clinton, 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 7, 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: August 29, 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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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 Target Corporation, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002276 Township Of Clinton, 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 7, 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: August 29, 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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25-002276.pdfRead complete document text →
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RECEIVED AUG 1 8 2025 MICHIGAN TAX TRIBUNAL STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL TARGET CORPORATION, Petitioner, Docket No. 25-002276 v Parcel No. 16-11-34-328-004 CLINTON TOWNSHIP, Respondent. / MICHAEL B. SHAPIRO (P20282) JACKIE J. COOK (P68781) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA A. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, M1 48302 (248) 731-3089 ANSWER TO PETITION AFFIRMATIVE DEFENSES ANSWER Respondent, Clinton Township, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent neither admits nor denies the allegations set forth in Paragraph 1 as Petitioner’s Petition and the Tribunal’s Order speak for themselves. 2. Respondent lacks the information and knowledge necessary to respond to the truth of the allegations set forth in Paragraph 2 and, therefore, leaves Petitioner to its proofs.
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4. Respondent admits the allegations in Paragraph 4 to the extent it is the entity that assesses and collects property taxes with relation to the parcel identified in the Petition. S. Respondent admits the allegations in Paragraph 5 as to the stated values. 6. Respondent admits the allegations in Paragraph 6 as to the stated classification. 7. Upon information and belief, Respondent admits the allegations in Paragraph 7. 8. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 8 and, therefore, leaves Petitioner to its proofs. 9. Respondent acknowledges the issues raised by Petitioner in Paragraph 9 but denies Petitioner’s claims have merit and further denies Petitioner is entitled to any relief. 10. Respondent acknowledges Petitioner’s belief of a dispute relative to the value of a loss but denies that such a loss has occurred. 11. Respondent neither admits nor denies the allegations in Paragraph 11 as the General Property Tax Act speaks for itself. 12. Respondent denies the allegations in Paragraph 12, including subparagraphs (a)- (d), 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. 13. Respondent acknowledges the relief requested by Petitioner in the final paragraph of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in
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WHEREFORE, Respondent, Clinton Township, 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 11, 2025 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent, Clinton Township, 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. Alki Development Cov 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.
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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 the Tribunal to grant it preference by application of a
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HALLAHAN
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Order_Holding_Party_in_Default.2025-08-07_16-52-15.0000.pdfRead complete document text →
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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 Target Corporation, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002276 Township Of Clinton, 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 7, 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.
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MTT Docket No. 25-002276 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)
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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 Target Corporation, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002276 Township Of Clinton, 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: August 7, 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
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STATE OF MICHIGAN RECEIVED <' Ne : JON (1205 gx MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Target Corporation, Petitioner, v. Clinton Twp., Respondent. MTT Docket No. 25-002276 Parcel No. 16-11-34-328-004 Michael B. Shapiro (P20282) Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com jcook@honigman.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea A. Melcher (P85821) Hallahan & Associates, P.C. Attorneys for Respondent 1750 S. Telegraph Rd., Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com Proof of Service Lisa Joseph states that she is employed by Honigman LLP, attorneys for Petitioner, and that on June 11, 2025, she did serve a copy of Petitioner's Entire Tribunal Property Tax Petition, with docket number, upon the parties named on the attached list. Dated: June 11, 2025 Jeon pph Lisa Joseph 7 /
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BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK CLINTON TWP. - MACOMB 40700 ROMEO PLANK ROAD CLINTON TWP., MI 48038-2917 ASSESSOR CLINTON TWP. - MACOMB 40700 ROMEO PLANK ROAD CLINTON TWP., MI 48038-2917 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK MACOMB COUNTY ATTN: F. KRYCIA ADM BLDG. 1 S. MAIN ST., 8TH FLOOR MT. CLEMENS, MI 48043 DIRECTOR OF EQUALIZATION MACOMB COUNTY ATTN: F. KRYCIA ADM BLDG. 1 S. MAIN ST., 8TH FLOOR MT. CLEMENS, MI 48043 SECRETARY OF SCHOOL BOARD CLINTONDALE COMMUNITY SCHOOLS 35100 LITTLE MACK AVENUE CLINTON TWP., MI 48035-2633 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 VIA ELECTRONIC MAIL
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ET_Notice_of_Docket_Number.2025-06-16_11-49-34.0000.pdfRead complete document text →
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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 Target Corporation, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002276 Township Of Clinton, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this Notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this Notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this Notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the Notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: __Tribunal Clerk________ Entered: June 16, 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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Petition 2025 (per Sever Order) Target v Clinton Twp. - (25-002276).pdfRead complete document text →
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25-0013 60809402.2 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Target Corporation, Petitioner, v. Clinton Twp., Respondent. MTT Docket No. 25-002276 Parcel No. 16-11-34-328-004 Michael B. Shapiro (P20282) Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com jcook@honigman.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea A. Melcher (P85821) Hallahan & Associates, P.C. Attorneys for Respondent 1750 S. Telegraph Rd., Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com Entire Tribunal Property Tax Petition Target Corporation (“Petitioner”), through its attorneys, Honigman LLP, says: 1. Petitioner hereby files this Entire Tribunal Property Tax Petition pursuant to and as required by Michigan Tax Tribunal Order Severing 2025 Tax Year and Assigning it to Docket No. 25-002276, dated June 5, 2025. 2. Petitioner's principal office address is P.O. Box 9456, TPN-0950, Minneapolis, MN 55440.
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60809402.2
3.
Petitioner is a party in interest with respect to property taxes on tax parcel number
16-11-34-328-004 ("Petitioner's Property"), with an address of 33860 Gratiot Ave., Clinton Twp.,
located in Macomb County, Michigan.
4.
Respondent, Clinton Township, assesses and collects property taxes on Petitioner's
Property.
5.
Respondent’s March Board of Review set the 2025 taxable value of Petitioner's
Property at $3,283,962 and set the 2025 assessed value of Petitioner's Property at $4,872,900,
which will result in a state equalized value in the same amount based upon the tentative
equalization factor.
6.
Petitioner's Property is classified as commercial real.
7.
Petitioner's Property is presently used or available for use for retail purposes.
8.
Petitioner believes that Petitioner's Property was originally designed to be used for
retail purposes.
9.
This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable
value and (d) 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.
A Board of Review protest was not required for Petitioner’s Property.
12.
The 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
and operate as a fraud upon the taxpayer for the reasons that:Page 3
3 60809402.2 (a) The 2025 assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 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) The 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 (d) The 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 the 2025 taxable value of Petitioner's Property from $3,283,962 to $2,127,000; (ii) reducing the 2025 assessed value and state equalized value of Petitioner's Property from $4,872,900 to $2,127,000; (iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iv) awarding Petitioner any other relief to which it is entitled.
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4 60809402.2 Dated: June 11, 2025 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: _______________________________________ Michael B. Shapiro (P20282) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com Dated: June 11, 2025 HONIGMAN LLP Attorneys for Petitioner By: _______________________________________ Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com
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24-003079 Amend Sever.pdfRead complete document text →
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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 Target Corporation, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 24-003079 Clinton Township, Presiding Judge Respondent. Joshua M. Wease ORDER GRANTING PETITIONER’S MOTION TO AMEND ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT TO DOCKET NUMBER 25-002276 On May 5, 2025, Petitioner filed a motion requesting that the Tribunal permit it to amend the petition filed in this case to include tax year 2025. On May 27, 2025, Respondent filed a response to the motion. In the response, Respondent states that it opposes Petitioner’s motion. Further, Respondent requests the severance of tax year 2025 because valuation disclosures are due to be filed on August 19, 2025. The Tribunal has considered the motion, response, and the case file and finds that Petitioner timely filed its Motion to Amend, included the necessary information and filing fee, and otherwise met all requirements set forth in MCL 205.737 and MCL 205.735a. Due to the stage in which this case is at, however, and in the interest of judicial efficiency, the 2025 tax year shall be severed from this case and assigned to a new docket number. Therefore, IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. IT IS FURTHER ORDERED that Petitioner’s assessment appeal for the 2025 tax year is SEVERED and ASSIGNED to Docket No. 25-002276. IT IS FURTHER ORDERED that Petitioner shall file a petition for the 2025 tax year within 21 days of the entry of this Order. The petition shall note the docket number assigned by the Tribunal for the 2025 tax year and if filed utilizing the Tribunal’s e-filing system, must be filed on the assigned 2025 docket as a “Severed Petition.”1 1 Alternatively, the petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933.
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MTT Docket No. 24-003079 Page 2 of 2 Failure to comply with this Order may result in Petitioner being held in default, as provided by TTR 237. Entered: June 5, 2025 By _____________________________ bw 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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