The Hazelton LLC, Petitioner Vs. City Of Royal Oak, 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

The Hazelton LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001922

City Of Royal Oak,

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: July 7, 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

The Hazelton LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001922

City Of Royal Oak,

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: July 7, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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

Page 1

4934-9665-2731.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

THE HAZELTON, LLC, 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

MTT Docket No. 25-001922 

 

v. 

 

CITY OF ROYAL OAK, 

 

 

 

Respondent. 

______________________________________________________________________________/ 

 

FOLEY & LARDNER LLP 

 

 

 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Petitioner 

 

 

 

Attorneys for Respondent 

By: Jason Conti (P55617) 

 

 

 

By: Seth O’Loughlin (P80257) 

500 Woodward Avenue, Suite 2700 

 

 

1750 S. Telegraph Road, Suite 202 

Detroit, Michigan 48226 

 

 

 

Bloomfield Hills, Michigan 48302 

(313) 234-7100 

 

 

 

 

(248) 731-3089 

jconti@foley.com 

 

 

 

 

soloughlin@hallahanlaw.com 

______________________________________________________________________________/ 

 

JOINT STIPULATION TO WITHDRAW APPEAL WITHOUT COSTS TO EITHER PARTY 

 

 

Petitioner The Hazelton, LLC and Respondent City of Royal Oak hereby notify the Tribunal that the 

parties voluntarily stipulate to the withdrawal of this appeal without costs to any party. 

 

FOLEY & LARDNER LLP 

 

 

 

 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Petitioner 

 

 

 

 

Attorneys for Respondent 

 

By: /s/ Jason Conti 

 

 

 

 

 

By: /s/ Seth O’Loughlin 

 

 

Jason Conti (P55617) 

 

 

 

 

 

Seth O’Loughlin (P80257) 

500 Woodward Avenue, Suite 2700 

 

 

 

1750 S. Telegraph Road, Suite 202 

Detroit, Michigan 48226 

 

 

 

 

Bloomfield Hills, Michigan 48302 

(313) 234-7177 

 

 

 

 

 

(248) 731-3089 

 

 

 

 

 

 

 

 

Dated: July 6, 2026 

 

 

 

 

 

Dated: July 6, 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: 25-001922

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: Stipulation to withdraw appeal

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

NOTICE OF DECEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

The Hazelton LLC,

Petitioner,

v

 

 

City Of Royal Oak,

Respondent.

 MTT Docket No. 25-001922

Please be advised that 25-001922 has been placed on a two-week Prehearing General 

Call commencing December 16, 2026. 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. 25-001922

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 August 19, 2026. Valuation disclosures will not be admitted into evidence 

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

admissible) except upon a finding of good cause by the Tribunal.

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

Statements by August 19, 2026. Witnesses, with the exception of rebuttal witnesses, 

will not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

August 19, 2026, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

December 16, 2026, which means all discovery has been requested, all Motions to 

Compel have been filed, and all requested or ordered discovery has been exchanged 

by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s 

valuation disclosure, the opposing party’s valuation expert, and the witnesses identified 

on the opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: January 16, 2026

Page 3

MTT Docket No. 25-001922

Page 3 of 3

PROOF OF SERVICE

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

parties or their attorneys or

Page 4

STATE

Page 5

M

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

THE HAZELTON, LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF ROYAL OAK, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001922 

Parcel No. 72-25-22-155-041 

 

_____________________________________________________________________________/ 

 

JASON CONTI (P55617) 

FOLEY & LARDNER LLP 

Attorney for Petitioner 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7177 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Royal Oak, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the truth 

of the assertions set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

2

4. 

Respondent admits the subject property is classified as commercial real. 

Respondent lacks the information and knowledge necessary to respond to the remainder of the 

allegations set forth in Paragraph 4 and, therefore, leaves Petitioner to its proofs. 

5. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies 

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

6. 

Respondent acknowledges Petitioner’s belief as to a dispute relative to the value of 

a loss but denies that any such loss has occurred. 

7. 

Respondent neither admits nor denies the statement in Paragraph 7 for the reason that 

no assertion was made. In further answer, Petitioner only sets forth a hypothetical condition (i.e., “if 

P.A. 174 of 2006 requires a board of review protest . . .”) but then fails to state whether or not a protest 

was made. 

8. 

Respondent denies the allegations in Paragraph 8, 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. 

9. 

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. 

 

 

WHEREFORE, Respondent, City of Royal Oak, 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.

Page 3

3

 

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: September 24, 2025 

 

 

 

(258) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Royal Oak, asserts the following affirmative defenses: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

3. 

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

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

4. 

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

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

its agents. 

5. 

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

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

Respondent’s taxing unit for the year in question. 

6. 

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

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

Page 4

4

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 self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to

Page 5

5

P

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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. 25-001922

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Royal Oak (OAKLAND)

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

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

4896-2639-2931.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

THE HAZELTON, LLC, 

 

 

 

MTT Docket No. 25-001922 

 

 

 

 

 

 

 

Parcel No. 72-25-22-155-041 

Petitioner, 

 

v 

 

CITY OF ROYAL OAK, 

 

 

 

Respondent. 

________________________________________/ 

 

FOLEY & LARDNER LLP 

Attorneys for Petitioner 

By: Jason Conti (P55617) 

500 Woodward Avenue, Suite 2700 

Detroit, Michigan 48226 

(313) 234-7100 

jconti@foley.com 

_____________________________________________/ 

 

PROOF OF SERVICE 

 

On August 27, 2025, I caused to be served, via the methods listed below, a copy of Petitioner’s 

Petition for 2025 Tax Year, Notice of Docket Number, and this Proof of Service on: 

County Clerk 

1200 N. Telegraph Road 

Building 12E 

Pontiac, Michigan 48341 

 

via U.S. mail

County Equalization Director 

250 Elizabeth Lake Road 

Suite 1000 W 

Pontiac, Michigan 48341 

 

via U.S. mail

Secretary of Local School Board 

Royal Oak Schools 

800 DeVillen 

Royal Oak, Michigan 48073 

 

via U.S. mail 

 

State Treasurer 

Michigan Dep’t of Treasury 

Treasury Building 

430 W. Allegan Street 

Lansing, Michigan 48922 

 

via U.S. mail 

 

 

 

City of Royal Oak Clerk 

or Township Supervisor 

203 S. Troy Street 

Royal Oak, Michigan 48067 

 

via Certified Mail 

 

City of Royal Oak Assessor 

203 S. Troy Street 

Royal Oak, Michigan 48067 

 

via Certified Mail

Page 2

2 

4896-2639-2931.1 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

By: s/ Jason Conti (P55617) 

 

 

 

500 Woodward Avenue, Suite 2700 

 

Detroit, Michigan 48226 

 

(313) 234-7100 

 

jconti@foley.com

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Page 1

1 

4914-3529-6071.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

THE HAZELTON, LLC, 

 

 

 

MTT Docket No. _____________ 

 

 

 

 

 

 

 

[Parcel No. 72-25-22-155-041] 

Petitioner, 

 

v 

 

CITY OF ROYAL OAK, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2025 TAX YEAR 

 

 

THE HAZELTON, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, states: 

 

1. 

Petitioner’s principal office address is 2617 Beacon Hill, Auburn Hills, Michigan 48326. 

Petitioner is a party in interest with respect to property taxes on real property tax parcel no. 72-25-22-155-

041 (the “Subject Property”), also known as 222 E 6th Street, Royal Oak, Michigan 48067. 

 

2. 

Respondent the City of Royal Oak (“Respondent”) assesses and collects property taxes on 

the Subject Property. 

 

3. 

In 2025, Respondent determined the taxable and assessed values of the Subject Property 

to be $3,083,380 and $3,083,380 respectively which will result in a state equalized value in the same 

amount based upon the tentative equalization factor. 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject Property was 

originally designed to be used for Commercial purposes. 

 

5. 

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

and (d) uniformity.

Page 2

2 

4914-3529-6071.1 

 

6. 

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

relative to the value of a loss. 

 

7. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March 2025. 

 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed on the 

Subject 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: 

 

 

(a) 

The assessment, including state equalized value and/or taxable value, exceeds 

the amount permitted by the Michigan Constitution and applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and applicable 

statutes; 

 

 

(c) 

The assessment, including taxable value and/or state equalized value, are based 

upon an erroneous determination of the true cash value of that portion of the Subject Property that is 

taxable under Michigan law, and are 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 requests that the Tax Tribunal enter an Order reducing the 2025 taxable 

value of the Subject Property from $3,083,380 to $1,000,000, and reducing the 2025 state equalized value 

of the Subject Property from $3,083,380 to $1,000,000, and requiring Respondent to pay Petitioner the 

refunds attributable to such reductions, plus interest and costs.

Page 3

3 

4914-3529-6071.1 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 30, 2025

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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

The Hazelton LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001922

City Of Royal Oak, 

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: July 30, 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 

4914-3529-6071.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

THE HAZELTON, LLC, 

 

 

 

MTT Docket No. _____________ 

 

 

 

 

 

 

 

[Parcel No. 72-25-22-155-041] 

Petitioner, 

 

v 

 

CITY OF ROYAL OAK, 

 

 

 

Respondent. 

________________________________________/ 

 

PETITION FOR THE 2025 TAX YEAR 

 

 

THE HAZELTON, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, states: 

 

1. 

Petitioner’s principal office address is 2617 Beacon Hill, Auburn Hills, Michigan 48326. 

Petitioner is a party in interest with respect to property taxes on real property tax parcel no. 72-25-22-155-

041 (the “Subject Property”), also known as 222 E 6th Street, Royal Oak, Michigan 48067. 

 

2. 

Respondent the City of Royal Oak (“Respondent”) assesses and collects property taxes on 

the Subject Property. 

 

3. 

In 2025, Respondent determined the taxable and assessed values of the Subject Property 

to be $3,083,380 and $3,083,380 respectively which will result in a state equalized value in the same 

amount based upon the tentative equalization factor. 

4. 

The Subject Property is classified as Commercial Real. The Subject Property is presently 

used or available for use for Commercial purposes. Petitioner believes that the Subject Property was 

originally designed to be used for Commercial purposes. 

 

5. 

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

and (d) uniformity.

Page 2

2 

4914-3529-6071.1 

 

6. 

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

relative to the value of a loss. 

 

7. 

If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a 

board of review protest was filed in March 2025. 

 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed on the 

Subject 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: 

 

 

(a) 

The assessment, including state equalized value and/or taxable value, exceeds 

the amount permitted by the Michigan Constitution and applicable statutes; 

 

 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and applicable 

statutes; 

 

 

(c) 

The assessment, including taxable value and/or state equalized value, are based 

upon an erroneous determination of the true cash value of that portion of the Subject Property that is 

taxable under Michigan law, and are 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 requests that the Tax Tribunal enter an Order reducing the 2025 taxable 

value of the Subject Property from $3,083,380 to $1,000,000, and reducing the 2025 state equalized value 

of the Subject Property from $3,083,380 to $1,000,000, and requiring Respondent to pay Petitioner the 

refunds attributable to such reductions, plus interest and costs.

Page 3

3 

4914-3529-6071.1 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By: /s/ Jason Conti 

 

 

 

 

 

 

 

 

 

Jason Conti (P55617) 

 

 

 

 

 

 

500 Woodward Avenue, Suite 2700 

 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

 

(313) 234-7177 

 

 

 

 

 

 

jconti@foley.com 

 

 

Dated: May 30, 2025

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

The Hazelton, LLC

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

2617 Beacon Hill Drive

City or Town

Auburn Hills

State

Michigan

ZIP Code

48326

Telephone Number

3132347177

Fax Number

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

jconti@foley.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

Last Name

Conti

Firm Name (if any)

Foley & Lardner LLP

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

500 Woodward Ave, Ste 2700

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-234-7177

Fax Number

313-234-2800

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

jconti@foley.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]

222 E. 6th Street

Royal Oak

Michigan

48067

Taxing Authority (City or Township)

City Of Royal Oak (OAKLAND)

County

Oakland

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

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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

72-25-22-155-041

Classification of Property: Real 

Commercial

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

3083380

Current Taxable Value as established by the Board of Review:

3083380

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

2000000

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

1000000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest 

State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jason Conti

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.