Tim Hortons: Tdl Group Corp Et Al Petitioner Vs. City Of Dearborn Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

Tim Hortons: TDL Group Corp Et Al, 

 Petitioner, 

vs. 

City of Dearborn, 

 Respondent. 

MTT Docket No. 26-001579 

Tax ID# 82-09-222-05-018 

 

Joshua T. Shillair, Esq. (P72674) 

Colliers International 

400 W. 4th Street, Suite 350 

Royal Oak, MI 48067 

(248) 226-1632 

Representative for Petitioner 

Aaron Powers 

WCA ASSESSING 

38110 Executive Dr., Ste. 200 

Westland, MI 48185 

(734) 331-3980 

Authorized Representative for 

Respondent 

 

RESPONDENT'S ANSWER TO PETITION 

 

NOW COMES the Respondent, City of Dearborn, by and through its Representative, WCA Assessing, 

and in answer to the Petition filed herein, states as follows: 

1. Respondent admits the parcel number and property address. Respondent's records identify City of 

Dearborn as owner and Tim Horton's as taxpayer. Respondent denies the remaining allegations. 

2. Admits. 

3. Admits. 

4. Admits. 

5. Admits. 

6. Admits. 

7. Admits.

Page 2

8. Admits. 

 

9. Admits. Respondent's 2026 values are as follows: 

Tax 

Year 

Parcel ID 

True Cash 

Value 

Assessed 

Value 

Taxable Value 

2026 

82-09-222-05-018 

$1,037,000 

$518,500 

$432,851 

2026 

Totals 

 

$1,037,000 

$518,500 

$432,851 

 

10. Denies. 

11. Denies. 

12. Denies. Respondent believes the amount in dispute is zero dollars: 

Tax 

Year 

Parcel ID 

True Cash 

Value 

Assessed 

Value 

Taxable Value 

2026 

82-09-222-05-018 

$0 

$0 

$0 

2026 

Totals 

 

$0 

$0 

$0 

 

13. Denies. 

WHEREFORE, Respondent, City of Dearborn, asserts that the case lacks merit and 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 representation fees. 

Dated: August 24, 2026 

 

Respectfully Submitted, 

 

WCA Assessing 

 

 

_____________________________________ 

 

Aaron P. Powers 

Representative for Respondent 

38110 Executive Drive, Ste. 200 

Westland, Michigan 48185 

734-331-3980

Page 3

PROOF OF SERVICE 

The undersigned, being first duly sworn, deposes and says that she, Haley B. Johnson, placed in the 

United States Mail, postage prepaid, a copy of the following, properly addressed: 

DATE: 

August 24, 2026 

 

DOCUMENT: 

Respondent's Answer to Petition 

 

ADDRESSEE(S): 

Joshua T. Shillair, Esq. 

Colliers International 

400 W. 4th Street, Suite 350 

Royal Oak, MI 48067 

 

/s/Haley B. Johnson_________ 

 Haley B. Johnson 

August 24, 2026

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

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001579

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Dearborn (WAYNE)

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

Aaron

M.I.

P

Last Name

Powers

Firm Name (if any)

WCA Assessing

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

38110 Executive Dr.

STE 200

City or Town

Westland

State

 Michigan

ZIP Code

48185

Telephone Number

7343313980

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

MTTappeals@wcaassessing.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Aaron P Powers

/s/

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Page 1

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Tim Hortons: TDL Group Corp Et Al, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

City of Dearborn, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

City of Dearborn 

Assessing Office 

16901 Michigan Ave. 

Dearborn, MI, 48126 

(313) 943-2000 

 

 

 

_____________________________________________________________________________/ 

 

2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, Tim Hortons: TDL Group Corp Et Al, has the legal 

residence or principal office address of 130 King St W, Suite 300,Toronto, ON M5X 

1E1, Canada. Petitioner is a party in interest with respect to property taxes on property 

parcel no(s). (hereinafter referenced as the Subject Property) 82 09 222 05 018. If the 

Subject Property in this petition includes more than one (1) real property tax parcel, the 

Subject Property’s tax parcels are contiguous. 

2. The Subject Property is located in Wayne County.

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, City of Dearborn of Wayne County, assesses and collects property taxes on 

the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. 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. Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

21203 MICHIGAN, DEARBORN, MI 48124 

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

and (d) uniformity. 

8. The tax year(s) at issue are: 2026 

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2026 

82 09 222 05 

018 

$1,037,000.00 

$518,500.00 

$432,851.00 

 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of 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, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable 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, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

82 09 222 05 

018 

$651,200.00 

$325,600.00 

$325,600.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2026 

82 09 222 05 018 

$192,900.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 4 of 5 

 

WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an 

Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject 

Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

COLLIERS INTERNATIONAL 

 

 

 

 

 

 

Representative for Petitioner 

 

 

 

 

 

 

 

By:_/s/ Joshua T. Shillair__Dated:05/18/2026 

 

 

 

 

 

 

Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

400 E 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com

Page 5

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 5 of 5 

 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY

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

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

Tim Hortons: TDL Group Corp Et Al

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

130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada

130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada

City or Town

TORONTO

State

Michigan

ZIP Code

12345

Telephone Number

2482261632

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

tax.efile@colliers.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

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

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

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

tax.efile@colliers.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]

21203 MICHIGAN

DEARBORN

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48124

Taxing Authority (City or Township)

City Of Dearborn (WAYNE) 

County

Wayne

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

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

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:

82 09 222 05 018

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:

518500

Current Taxable Value as established by the Board of Review:

432851

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

651200

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

325600

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

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/ /s/Joshua T. Shillair

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787091792

Supporting Waiver Documents:

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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

Tim Hortons: TDL Group Corp Et Al, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001579

City Of Dearborn, 

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 19, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v Dearborn 

Parcel Number: 

MTT Docket No.: 26-001579 

Page 1 of 2 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

TIM HORTONS: TDL GROUP CORP ET AL, 

 

Petitioner, 

v 

MTT Docket No. 26-001579 

DEARBORN, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Senior Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

City of Dearborn Assessing Department 

16901 Michigan Avenue 

Dearborn, MI 48126 

313-943-2030 

_____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

STATE OF MICHIGAN 

) 

 

)ss 

COUNTY OF OAKLAND 

) 

 

Jennifer Lunsford, states that on 8/6/2026, in compliance with TTR 221, she did place in the US 

mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number as well 

as this Proof of Service of Petition for the above captioned appeal to the units of government listed 

on the second page of this Proof of Service of Petition. 

 

/s/Jennifer Lunsford 

Jennifer Lunsford 

 

Karen Cameron states that she submitted electronically on 8/6/2026, to the Michigan Tax Tribunal 

a copy of this Proof of Service of Petition at eFile through www.etaxappeal.lara.state.mi.us. 

 

/s/Karen Cameron 

Karen Cameron

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v Dearborn 

Parcel Number: 

MTT Docket No.: 26-001579 

Page 2 of 2 

 

By Certified Mail 

 

Assessor’s Office 

City of Dearborn Assessing Department 

16901 Michigan Avenue 

Dearborn, MI 48126 

 

Office of the City/Township Clerk 

Dearborn 

Clerk's Office 

16901 Michigan Avenue 

Dearborn, MI 48126 

 

By First Class Mail 

 

Director of Equalization 

Wayne County 

Equalization Director 

400 Monroe Street, Suite 200 

Detroit, MI 48226 

 

County Clerk’s Office 

Wayne County 

Clerk’s Office 

2 Woodward Avenue, Suite 201 

Detroit, MI 48226 

 

Secretary of the School Board 

Dearborn Public Schools 

18700 Audette Street 

Dearborn, MI 48124 

 

Treasurer for the State of Michigan 

Michigan Department of Treasury 

Lansing, MI 48922

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

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: 26-001579

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: POS_Tim_Hortons_TDL_Group_Corp_Et_Al_26-001579

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Tim Hortons: TDL Group Corp Et Al, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

City of Dearborn, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

City of Dearborn 

Assessing Office 

16901 Michigan Ave. 

Dearborn, MI, 48126 

(313) 943-2000 

 

 

 

_____________________________________________________________________________/ 

 

2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, Tim Hortons: TDL Group Corp Et Al, has the legal 

residence or principal office address of 130 King St W, Suite 300,Toronto, ON M5X 

1E1, Canada. Petitioner is a party in interest with respect to property taxes on property 

parcel no(s). (hereinafter referenced as the Subject Property) 82 09 222 05 018. If the 

Subject Property in this petition includes more than one (1) real property tax parcel, the 

Subject Property’s tax parcels are contiguous. 

2. The Subject Property is located in Wayne County.

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, City of Dearborn of Wayne County, assesses and collects property taxes on 

the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. 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. Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

21203 MICHIGAN, DEARBORN, MI 48124 

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

and (d) uniformity. 

8. The tax year(s) at issue are: 2026 

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2026 

82 09 222 05 

018 

$1,037,000.00 

$518,500.00 

$432,851.00 

 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of 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, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable 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, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

82 09 222 05 

018 

$651,200.00 

$325,600.00 

$325,600.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2026 

82 09 222 05 018 

$192,900.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 4 of 5 

 

WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an 

Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject 

Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

COLLIERS INTERNATIONAL 

 

 

 

 

 

 

Representative for Petitioner 

 

 

 

 

 

 

 

By:_/s/ Joshua T. Shillair__Dated:05/18/2026 

 

 

 

 

 

 

Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

400 E 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com

Page 5

2026 Entire Tribunal Property Tax Petition & Proof of Service 

Tim Hortons: TDL Group Corp Et Al v City of Dearborn 

Parcel Number: 82 09 222 05 018 

MTT Docket No.: 

 

Page 5 of 5 

 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY

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

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

Tim Hortons: TDL Group Corp Et Al

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

130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada

130 King St W, Suite 300,Toronto, ON M5X 1E1, Canada

City or Town

TORONTO

State

Michigan

ZIP Code

12345

Telephone Number

2482261632

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

tax.efile@colliers.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

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

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

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

tax.efile@colliers.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]

21203 MICHIGAN

DEARBORN

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48124

Taxing Authority (City or Township)

City Of Dearborn (WAYNE) 

County

Wayne

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

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

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:

82 09 222 05 018

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:

518500

Current Taxable Value as established by the Board of Review:

432851

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

651200

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

325600

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

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/ /s/Joshua T. Shillair

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787091792

Supporting Waiver Documents:

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.