Record Finder / 26-001429-TT
Michigan

The Kroger Co Of Michigan Petitioner Vs. City Of Royal Oak Respondent

Petitioner
The Kroger Co Of Michigan
Respondent
City Of Royal Oak

Case overview

Docket number
26-001429-TT
Status
Answer Due
CaseType
ET Property
Division
ET
County
Oakland
Judge
No judge assigned

Docket history

Line #SubjectFilerLine RefEnter Date/Post MarkFeeRelated Item
5Answer was receivedRESPNot recorded10/06/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
4Proof of service of petition was received.Not recordedNot recorded09/08/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
3Petition has been verifiedPET108/12/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
2Notice of Docket Number ETNot recordedNot recorded08/12/2026Not recordedDownload
1A petition was received.PETNot recorded05/26/2026$600.00Download
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload

Documents

Answer_Kroger RO_FINAL.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

THE KROGER CO. OF MICHIGAN, 

 

 

 

Petitioner, 

 

v 

 

CITY OF ROYAL OAK, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001429 

Parcel No. 72-25-14-126-010 

 

_____________________________________________________________________________/ 

 

MICHELLE (MIKKI) M. SILVEY (P69494) 

ALEX MORSE 

CAMERON BECKNER 

DUCHARME, MCMILLEN, 

& ASSOCIATES, INC. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 689-6467 

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 admits the allegations in Paragraph 1. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent admits the allegations in Paragraph 3. 

4. 

Respondent lacks knowledge or information sufficient to form a belief as to the 

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

Page 2

2

5. 

Respondent admits the allegations in Paragraph 5. 

6. 

Respondent admits no protest was made but neither admits nor denies the necessity 

of such a protest as the General Property Tax Act speaks for itself. 

7. 

Respondent admits the allegations in Paragraph 7. 

8. 

Respondent admits the allegations in Paragraph 8. 

9. 

Respondent admits the allegations in Paragraph 9. 

10. 

Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations set forth in Paragraph 10 and, therefore, leaves Petitioner to its proofs. 

11. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 11 but denies 

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

12. 

Respondent acknowledges Petitioner’s identification of the 2026 tax year as being 

at issue but denies any issue with the identified tax year. 

13. 

The values for the property identified above as established by Respondent’s Board 

of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

$14,195,440 

$7,097,720 

$6,853,000 

14. 

Respondent contends that the values for the property identified above are as 

follows: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$14,195,440 

$7,097,720 

$6,853,000 

15. 

The values in dispute are as follows: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

16. 

Respondent denies the allegations in Paragraph 16, including subparagraphs (a)-

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

Page 3

3

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. 

17. 

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. 

 

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: October 6, 2026 

 

 

 

(248) 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).

Page 4

4

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 

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

Page 5

5

12.

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EntireTribunalCaseISAnswer.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001429

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Royal Oak (OAKLAND)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone 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.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

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

248-731-3089

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: 

/s/Kelsea M. Melcher

/s/

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SCANNED KROGER - CITY OF ROYAL OAK 26-001429.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

THE KROGER CO. OF MICHIGAN. 

) 

Petitioner, 

) 

MTT DOCKET NO. 26-001429-TT 

) 

City of Royal Oak, 

) 

) 

) 

Respondent. 

) 

PROOF OF SERVICE 

Michelle (Mikki) M. Silvey, being first duly sworn, deposes and says that on the 8" day of 

September 2026 she served a copy of the Petition upon the following persons by placing 

same in an envelope properly addressed to each via USPS first class thereon: 

Lisa Brown 

City of Royal Oak School District 

Oakland County Clerk 

Maryanne VanHaitsma, 

1200 North Telegraph Road 

School Board Secretary 

Building 12E 

800 DeVillen 

Pontiac, MI 48341 

Royal Oak, MI 48073 

Micheal R. Lohmeier 

Michigan State Treasurer 

Oakland County Equalization Director 

Department of Treasury 

1200 N. Telegraph Road 

Treasury Building 

Pontiac, MI 48341 

430 West Allegan 

Lansing, MI 48922 

Micka (0 Shs 

Michelle (Mikki) M. Silvey (P69494) 

Authorized Agent

Page 2

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

THE KROGER CO. OF MICHIGAN. 

) 

) 

Petitioner, 

) 

MTT DOCKET NO. 26-001429-TT 

) 

City of Royal Oak, 

) 

) 

) 

Respondent. 

) 

PROOF OF SERVICE 

Michelle (Mikki) M. Silvey, being first duly sworn, deposes and says that on the 8" day of 

September 2026 she served a copy of the Petition upon the following persons by placing 

same in an envelope properly addressed to each via certified mail thereon: 

Anthony Switkowski 

City of Royal Oak Assessor 

203 S Troy Street 

Royal Oak, MI 48067 

Melanie Halas 

City of Royal Oak Clerk 

203 S Troy Street 

Royal Oak, MI 48067 

Mics (0 ve) 

Michelle (Mikki) M. Silvey (P69494) 

Authorized Agent

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

THE KROGER CO. OF MICHIGAN 

. 

MTT Docket No. 26-001429-TT 

Petitioner, 

v 

City of Royal Oak 

Respondent. 

Michelle (Mikki) M. Silvey (P69494) 

Alex Morse 

Cameron Beckner 

DuCharme, McMillen & Associates, Inc. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 596-3260 

msilvey@dmainc.com 

amorse@dmainc.com 

cbeckner@dmainc.com 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No.: 72-25-14-126-010 

2. 

The property identified above is 

_real 

3. 

Only one parcel of property is the subject of this appeal. 

4. 

Petitioner owns and/or otherwise holds an interest in the parcel of property that is the 

subject of this appeal. 

5. 

The property identified above is classified as 201 Commercial-Improved

Page 4

MTT Docket No. 26-001429-TT 

Page 2 of 3 

6. 

10. 

11. 

12. 

13. 

14. 

15. 

The assessments) at issue were not protested to Respondent’s March, July, or December 

Board of Review as a protest was not required. 

The property or properties at issue are in Oakland 

County. 

The property or properties’ address is: 

2200 E 12 Mile Rd, Royal Oak, MI 48067-1504 

City of Royal Oak 

The assessment(s) at issue were established by the: 

Petitioner’s legal residence or principal office address is: 

1014 Vine Street, Cincinnati, OH 45202 

This appeal involves issues relating to the property or properties’ true cash and taxable 

values and uniformity. 

The tax year at issue is: 2026. 

The values for the property identified above as established by Respondent’s 2026 Board 

of Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2026 

$14,195,440 

$7,097,720 

$6,853,000 

Petitioner contends the values for tax year 2026 are no more than the following: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2026 

$6,646,860 

$3,323,430 

$3,323,430 

The values in contention for tax year 2026 are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2026 

$7,548,580 

$3,774,290 

$3,529,570

Page 5

MTT Docket No. 26-001429-TT 

Page 3 of 3 

16. The 2026 assessments imposed on the subject property and the taxes to be levied and 

collected are invalid because: 

(a) The assessment, including state equalized and/or taxable value, exceeds the amount 

permitted by the Michigan Constitution and applicable statutes; 

(b) The assessment, including state equalized 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 is based on the misapplication of valuation principles, and 

(d) The assessment otherwise violates Petitioner’s rights. 

WHEREFORE, Petitioner respectfully requests this honorable Tribunal hear this case and 

enter an order reducing the 2026 true cash, state equalized and taxable values and direct 

Respondent to refund to Petitioner any excess taxes, fees, and penalties paid, plus interest and 

costs, and all other relief to which it is entitled under Michigan law and as is appropriate under 

the circumstances. 

Respectfully submitted, 

DuCharme, McMillen & Associates, Inc. 

icis(0 

& 

Mic (0 

2) 

Michelle (Mikki) M. Silvey (P69494) 

Petitioner's Representative 

Dated: May 

26 2026 

By:

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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: 26-001429

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: SCANNED KROGER - CITY OF ROYAL OAK 26-001429

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Kroger - City of Royal Oak.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

__________________________________________, 

MTT Docket No. 26-_____BBB_-TT

Petitioner, 

v 

__________________________________________, 

Respondent. 

______________________________/ 

Michelle (Mikki) M. Silvey (P69494) 

Alex Morse 

Cameron Beckner 

DuCharme, McMillen & Associates, Inc. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 596-3260

msilvey@dmainc.com

amorse@dmainc.com

cbeckner@dmainc.com

______________________________/ 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. Property Parcel No.: ________________________________

2. The property identified above is _________________.

3. Only one parcel of property is the subject of this appeal.

4. Petitioner owns and/or otherwise holds an interest in the parcel of property that is the

subject of this appeal.

5. The property identified above is classified as ___________________________________.

THE KROGER CO. OF MICHIGAN

City of Royal Oak

72-25-14-126-010

 real

201 Commercial-Improved

Page 2

MTT Docket No. 26-______BBB-TT

Page 2 of 3 

6. The assessment(s) at issue were not protested to Respondent’s March, July, or December

Board of Review as a protest was not required.

7. The property or properties at issue are in ________________ County.

8. The property or properties’ address is:

______________________________________________________________________.

9. The assessment(s) at issue were established by the: _____________________________.

10. Petitioner’s legal residence or principal office address is:

______________________________________________________________________.

11. This appeal involves issues relating to the property or properties’ true cash and taxable

values and uniformity.

12. The tax year at issue is: 2026.

13. The values for the property identified above as established by Respondent’s 2026 Board

of Review are:

Tax 

Year 

True Cash 

Value 

Assessed 

Value 

Taxable 

Value 

2026 

14. Petitioner contends the values for tax year 2026 are no more than the following:

Tax 

Year 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2026 

15. The values in contention for tax year 2026 are:

Tax 

Year 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2026 

 Oakland 

 2200 E 12 Mile Rd, Royal Oak, MI 48067-1504

City of Royal Oak

 1014 Vine Street, Cincinnati, OH 45202

$14,195,440

$7,097,720

$6,853,000

$6,646,860

$3,323,430

$3,323,430

$7,548,580

$3,774,290

$3,529,570

Page 3

MTT Docket No. 26-_____BBB_-TT 

Page 3 of 3 

16. The 2026 assessments imposed on the subject property and the taxes to be levied and

collected are invalid because:

(a) The assessment, including state equalized and/or taxable value, exceeds the amount

permitted by the Michigan Constitution and applicable statutes;

(b) The assessment, including state equalized 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 is based on the misapplication of valuation principles, and

(d) The assessment otherwise violates Petitioner’s rights.

WHEREFORE, Petitioner respectfully requests this honorable Tribunal hear this case and 

enter an order reducing the 2026 true cash, state equalized and taxable values and direct 

Respondent to refund to Petitioner any excess taxes, fees, and penalties paid, plus interest and 

costs, and all other relief to which it is entitled under Michigan law and as is appropriate under 

the circumstances. 

Respectfully submitted, 

DuCharme, McMillen & Associates, Inc. 

Dated: __________ ___, 2026

By: 

______________________________

Michelle (Mikki) M. Silvey (P69494)

Petitioner’s Representative

May

26

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EntireTribunalCaseISPetition.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

THE KROGER CO. OF MICHIGAN

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

1014 Vine Street

City or Town

Cincinnati

State

Ohio

ZIP Code

45202

Telephone Number

9174887825

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

msilvey@dmainc.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Michelle (Mikki)

M.I.

M

Last Name

Silvey

Firm Name (if any)

DuCharme, McMillen & Associates

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

9229 Delegates Row, Ste 375

City or Town

Indianapolis

State

Indiana

ZIP Code

46240

Telephone Number

917-488-7825

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

msilvey@dmainc.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

2200 E 12 Mile Rd

Royal Oak

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

72-25-14-126-010

Classification of Property: Real (check one)

Commercial (check one)

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

7097720

Current Taxable Value as established by the Board of Review:

6853000

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

6646860

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

3323430

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

3323430

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ Michelle (Mikki) M. Silvey

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686949945

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-08-12_16-38-54.pdfRead complete document text →
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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 Kroger Co Of Michigan, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001429

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: August 12, 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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Kroger - City of Royal Oak.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

__________________________________________, 

MTT Docket No. 26-_____BBB_-TT

Petitioner, 

v 

__________________________________________, 

Respondent. 

______________________________/ 

Michelle (Mikki) M. Silvey (P69494) 

Alex Morse 

Cameron Beckner 

DuCharme, McMillen & Associates, Inc. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 596-3260

msilvey@dmainc.com

amorse@dmainc.com

cbeckner@dmainc.com

______________________________/ 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. Property Parcel No.: ________________________________

2. The property identified above is _________________.

3. Only one parcel of property is the subject of this appeal.

4. Petitioner owns and/or otherwise holds an interest in the parcel of property that is the

subject of this appeal.

5. The property identified above is classified as ___________________________________.

THE KROGER CO. OF MICHIGAN

City of Royal Oak

72-25-14-126-010

 real

201 Commercial-Improved

Page 2

MTT Docket No. 26-______BBB-TT

Page 2 of 3 

6. The assessment(s) at issue were not protested to Respondent’s March, July, or December

Board of Review as a protest was not required.

7. The property or properties at issue are in ________________ County.

8. The property or properties’ address is:

______________________________________________________________________.

9. The assessment(s) at issue were established by the: _____________________________.

10. Petitioner’s legal residence or principal office address is:

______________________________________________________________________.

11. This appeal involves issues relating to the property or properties’ true cash and taxable

values and uniformity.

12. The tax year at issue is: 2026.

13. The values for the property identified above as established by Respondent’s 2026 Board

of Review are:

Tax 

Year 

True Cash 

Value 

Assessed 

Value 

Taxable 

Value 

2026 

14. Petitioner contends the values for tax year 2026 are no more than the following:

Tax 

Year 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2026 

15. The values in contention for tax year 2026 are:

Tax 

Year 

True Cash 

Value 

State Equalized 

Value 

Taxable 

Value 

2026 

 Oakland 

 2200 E 12 Mile Rd, Royal Oak, MI 48067-1504

City of Royal Oak

 1014 Vine Street, Cincinnati, OH 45202

$14,195,440

$7,097,720

$6,853,000

$6,646,860

$3,323,430

$3,323,430

$7,548,580

$3,774,290

$3,529,570

Page 3

MTT Docket No. 26-_____BBB_-TT 

Page 3 of 3 

16. The 2026 assessments imposed on the subject property and the taxes to be levied and

collected are invalid because:

(a) The assessment, including state equalized and/or taxable value, exceeds the amount

permitted by the Michigan Constitution and applicable statutes;

(b) The assessment, including state equalized 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 is based on the misapplication of valuation principles, and

(d) The assessment otherwise violates Petitioner’s rights.

WHEREFORE, Petitioner respectfully requests this honorable Tribunal hear this case and 

enter an order reducing the 2026 true cash, state equalized and taxable values and direct 

Respondent to refund to Petitioner any excess taxes, fees, and penalties paid, plus interest and 

costs, and all other relief to which it is entitled under Michigan law and as is appropriate under 

the circumstances. 

Respectfully submitted, 

DuCharme, McMillen & Associates, Inc. 

Dated: __________ ___, 2026

By: 

______________________________

Michelle (Mikki) M. Silvey (P69494)

Petitioner’s Representative

May

26

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

THE KROGER CO. OF MICHIGAN

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

1014 Vine Street

City or Town

Cincinnati

State

Ohio

ZIP Code

45202

Telephone Number

9174887825

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

msilvey@dmainc.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Michelle (Mikki)

M.I.

M

Last Name

Silvey

Firm Name (if any)

DuCharme, McMillen & Associates

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

9229 Delegates Row, Ste 375

City or Town

Indianapolis

State

Indiana

ZIP Code

46240

Telephone Number

917-488-7825

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

msilvey@dmainc.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

2200 E 12 Mile Rd

Royal Oak

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

72-25-14-126-010

Classification of Property: Real (check one)

Commercial (check one)

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

7097720

Current Taxable Value as established by the Board of Review:

6853000

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

6646860

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

3323430

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

3323430

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ Michelle (Mikki) M. Silvey

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686949945

Supporting Waiver Documents:

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