Record Finder / 26-001655-TT
Michigan

The Kroger Co Of Michigan Petitioner Vs. City Of Roseville Respondent

Petitioner
The Kroger Co Of Michigan
Respondent
City Of Roseville

Case overview

Docket number
26-001655-TT
Status
Ready Schedule
CaseType
ET Property
Division
ET
County
Macomb
Judge
No judge assigned

Docket history

Line #SubjectFilerLine RefEnter Date/Post MarkFeeRelated Item
5Answer was receivedRESPNot recorded09/23/2026Not 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 verifiedNot recorded108/20/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
2Notice of Docket Number ETNot recordedNot recorded08/20/2026Not recordedDownload
1A petition was received.Not recordedNot recorded05/28/2026$600.00Download
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload

Documents

Rsvl - Kroger MTT Answer Aff Defs & POS.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, 

vs. 

MTT Docket No. 26-001655-TT 

CITY OF ROSEVILLE, 

Respondent. 

MICHELLE M. SILVEY (P69494) 

TIMOTHY D. TOMLINSON (P48519) 

ALEX MORSE 

TOMLINSON & MCGRAIL, PLLC 

DuCharme, McMillen & Assoc. Inc. 

Attorneys for Respondent 

Representatives for Petitioner 

22600 Hall Rd., Ste. 102 

9229 Delegates Row, Suite 375 

Clinton Township, MI 

48036 

Indianapolis, IN 46240 

(586) 263-5050 

(317) 689-6467 — ofc 

ttomlinson@ttlmlaw.com 

(917) 488-7825 — mobile 

msilvey@dmainc.com 

amorse@dmainc.com 

RESPONDENT'S ANSWER TO PETITION 

(Entire Tribunal, 2026 Tax Year) 

NOW COMES the Respondent, City of Roseville, by and through its attorneys, Tomlinson 

& McGrail, PLLC, and in answer to Petitioner’s Petition, states as follows: 

1. 

Respondent admits paragraph 1. 

2. 

Respondent admits paragraph 2. 

3. 

Respondent admits paragraph 3. 

4. 

Respondent neither admits nor denies paragraph 4 being without sufficient 

information to form a reasonable belief thereto. 

5. 

Respondent admits paragraph 5. 

6. 

Respondent admits paragraph 6. 

7. 

Respondent admits paragraph 7.

Page 2

10. 

11 

12. 

13. 

14. 

15. 

16. 

Respondent admits paragraph 8. 

Respondent admits paragraph 9. 

Respondent neither admits nor denies paragraph 4 being without sufficient 

information to form a reasonable belief thereto. 

Respondent denies paragraph 11 because it is untrue, leaving Petitioner to its 

proofs. 

Respondent admits paragraph 12. 

Respondent admits paragraph 13. 

Defendant denies paragraph 14 because it is untrue, leaving Petitioner to its 

proofs. 

Defendant denies paragraph 15 because it is untrue, leaving Petitioner to its 

proofs. 

Defendant denies paragraph 16, including (a) thru (d), because it is untrue, 

leaving Petitioner to its proofs. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition, affirm the values as determined by Respondent, and award costs and attorney fees 

wrongfully incurred in having to defend this matter. 

Respectfully submitted, 

TOMLINSON & MCGRAIL, PLLC 

7 

TIMOTHY D. TOMLINSON (P48519) 

Attorneys for Respondent 

22600 Hall Road, Ste. 102 

ATIFICATE OF SERVICE 

Clinton Twp., MI 48036 

2] carifies that the foregoing ing 

pi 

(586) 263-5050 

ttomlinson@ttlmlaw.com 

Ey: {3} Overnight 

Co 

{J Hand Delj 

[=| Corie 

Signature 

Dated: September 18, 2026 

Ton

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

THE KROGER CO. OF MICHIGAN, 

Petitioner, 

VS. 

CITY OF ROSEVILLE, 

Respondent. 

MTT Docket No. 26-001655-TT 

MICHELLE M. SILVEY (P69494) 

ALEX MORSE 

DuCharme, McMillen & Assoc. Inc. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 689-6467 — ofc 

(917) 488-7825 — mobile 

msilvey@dmainc.com 

amorse@dmainc.com 

TIMOTHY D. TOMLINSON (P48519) 

TOMLINSON & MCGRAIL, PLLC. 

Attorneys for Respondent 

22600 Hall Rd., Ste. 102 

Clinton Township, MI 

48036 

(586) 263-5050 

ttomlinson@ttlmlaw.com 

RESPONDENT'S AFFIRMATIVE DEFENSES 

NOW COMES the Respondent, City of Roseville, by and through its attorneys, 

Tomlinson & McGrail, PLLC, and for its Affirmative Defenses, states as follows: 

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. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of 

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

the Respondent. 

3. 

Petitioner fails to allege that the mode and method of appraising its property 

failed to conform to the mode and method applied in the case of all of the

Page 4

10. 

properties in the Respondent’s taxing unit for the year in question. 

Petitioner fails to allege specific and sufficient facts to establish the true cash 

value, assessed value and taxable value of its property. 

Petitioner fails to allege specific and sufficient facts to support its allegation that 

the assessed value of its property, as equalized, is at a factor other than 50% and 

also fails to allege specific and sufficient facts to support is allegations that that 

the property’s taxable value is improper. 

Petitioner fails to show that any rate other than 50% after equalization was 

applied to the true cash value of its property, as well as to the properties of all 

others to arrive at the respective equalized assessments. 

Petitioner, in essence, asks that this Honorable Tribunal grant it an illegal 

preference by application of a method of assessment different from that employed 

in the assessment of other properties in the Respondent’s taxing unit. 

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

state equalization as to the which it has no legal standing and cannot maintain a 

cause of action. 

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 reduce Petitioner’s 

otherwise equitable tax burden. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in accordance with statutory and constitutional 

requirements.

Page 5

11. 

Respondent reserves the right to add to these Affirmative Defenses any new 

Affirmative Defenses that discovery reveals. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss 

the Petition, affirm the values as determined by Respondent, and award costs and attorney fees 

wrongfully incurred in having to defend this matter. 

Respectfully submitted, 

TOMLINSON & MCGRAIL, PLLC 

TIMOTHY D. TOMLINSON (P48519) 

Attorneys for Respondent 

22600 Hall Rd., Ste. 102 

Clinton Township, MI 48036 

(586) 263-5050 

ttomlinson@ttlmlaw.com 

Dated: September 18, 2026 

~=RTIFICATE OF SERVICE 

os certifies that the foregoing Ai 

art 

above causes to each 

of 

tho 

Eo 

jive 

addresses

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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. 26-001655

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Roseville (MACOMB)

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

Timothy

M.I.

D

Last Name

Tomlinson

Firm Name (if any)

Tomlinson & McGrail, PLLC

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

22600 Hall Road

Suite 102

City or Town

Clinton Township

State

 Michigan

ZIP Code

48036

Telephone Number

5862635050

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

ttomlinson@ttlmlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Timothy D. Tomlinson

/s/

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SCANNED KROGER - CITY OF ROSEVILLE 26-001655 POS.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. 

26-001655-TT 

) 

) 

City of Roseville. 

) 

) 

) 

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: 

Anthony G. Forlini 

Roseville Community Schools 

Macomb County Clerk 

Joseph DeFelice, School Board Secretary 

40 N Main Street 

18975 Church Street 

Mount Clemens, MI 40843 

Roseville, MI 48066 

Kristen M. Sieloff 

Michigan State Treasurer 

Macomb County Equalization Director 

Department of Treasury 

1 S Main, 6" Floor 

Treasury Building 

Mount Clemens, MI 40843 

430 West Allegan 

Lansing, MI 48922 

j 

SK 

Micke, (( 

®) 

Michelle (Mikki) M. Silvey (P69494) 

Authorized Agent

Page 2

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

THE KROGER CO OF MICHIGAN. 

) 

Petitioner, 

) 

MTT DOCKET NO. 

26-001655-TT 

) 

) 

City of Roseville. 

) 

) 

) 

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: 

City of Roseville Assessor 

Brook Openshaw 

29777 Gratiot Avenue 

Roseville MI 48066 

City of Roseville Clerk 

Jennifer A. Zelmanski 

29777 Gratiot Avenue 

Roseville MI 48066 

ide 

((0 S 

Mice (0 

5) 

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. 26-001655-TT 

Petitioner, 

Vv 

City of Roseville 

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.: 08-14-03-354-002 

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. 26-001655-TT 

Page 2 of 3 

6. 

The assessment(s) at issue were not protested to Respondents March, July, or December 

Board of Review as a protest was not required. 

7. 

The property or properties at issue are in Macomb 

County. 

8. 

The property or properties’ address is: 

20891 13 Mile Rd, Roseville, MI 48066 

9. 

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

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

1014 Vine Street, Cincinnati, OH 45202 

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 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2026 

$9,282,800 

$4,641,400 

$3,520,016 

14. 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 

$4,570,000 

$2,285,000 

$2,285,000 

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

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2026 

$4,712,800 

$2,356,400 

$1,235,016

Page 5

MTT Docket No. 26-001655-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. 

Mic (0 eo) 

Dated: May 

28 2026 

By: 

Michelle (Mikki) M. Silvey (P69494) 

Petitioner's Representative

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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: 26-001655

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 ROSEVILLE 26-001655 POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Kroger - City of Roseville.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 Roseville

08-14-03-354-002

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 

 Macomb

 20891 13 Mile Rd, Roseville, MI 48066

City of Roseville

 1014 Vine Street, Cincinnati, OH 45202

$9,282,800

$4,641,400

$3,520,016

$4,570,000

$2,285,000

$2,285,000

$4,712,800

$2,356,400

$1,235,016

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

28

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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]

20891 13 Mile Rd,

Roseville

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48066

Taxing Authority (City or Township)

City Of Roseville (MACOMB) 

County

Macomb

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:

08-14-03-354-002

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:

4641400

Current Taxable Value as established by the Board of Review:

3520016

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

4570000

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

2285000

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

2285000

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: 26052887159645

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-08-20_16-43-10.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.: 26-001655

City Of Roseville, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: August 20, 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 Roseville.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 Roseville

08-14-03-354-002

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 

 Macomb

 20891 13 Mile Rd, Roseville, MI 48066

City of Roseville

 1014 Vine Street, Cincinnati, OH 45202

$9,282,800

$4,641,400

$3,520,016

$4,570,000

$2,285,000

$2,285,000

$4,712,800

$2,356,400

$1,235,016

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

28

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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]

20891 13 Mile Rd,

Roseville

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48066

Taxing Authority (City or Township)

City Of Roseville (MACOMB) 

County

Macomb

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:

08-14-03-354-002

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:

4641400

Current Taxable Value as established by the Board of Review:

3520016

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

4570000

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

2285000

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

2285000

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: 26052887159645

Supporting Waiver Documents:

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