Urban Development Corporation Petitioner Vs. City Of Detroit Respondent

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1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 URBAN DEVELOPMENT CORPORATION 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001232 

 

Respondent. 

 

 

 

Parcel No. 13009300-5 

____________________________________________________________________________/ 

ANSWER TO PETITION and 

AFFIRMATIVE DEFENSES 

Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer 

to the Petition filed in this matter states the following: 

1. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

2. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

3. Respondent admits as true. 

4. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

5. Respondent admits. 

6. Respondent admits as true. 

7. Respondent admits as true. 

8. Respondent admits as true.

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

17. Respondent admits as true. 

18. Respondent admits as true.

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3 

 

COUNT I – PETITIONER QUALIFIES FOR PROPERTY TAX 

EXEMPTION UNDER MCL 211.7o 

 

19. Respondent restates and incorporates its responses to paragraphs 1-18 as if fully 

stated herein. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

22. Respondent denies these allegations as untrue. 

23. Respondent states that this is a proper recitation of MCL 211.7o(1) 

24. Respondent states that this is a proper recitation of Michigan Department of Treasury 

Bulletin 26 of 2017. 

25. Respondent admits as true that a copy of the Quit Claim Deed dated July 20,2006 is 

attached as Exhibit 1 and leaves Petitioner to its proofs that it currently occupied 

solely by the Taxpayer. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

27. Respondent admits as true that a copy of Exhibit 2 is attached to the Petition, but leaves 

Petitioner to its proofs regarding the storage of landscaping equipment and materials. 

28. Respondent admits that caselaw does permit storage of items in an otherwise vacant 

property as meeting one prong of the 3 prong requirement for exemption, but leaves 

Petitioner to its proofs that it is entitled to an exemption.

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4 

 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

30. Respondent admits that the Michigan Tax Tribunal ruling in Welcome Missionary led 

to a ruling that the property was tax exempt and the decision was upheld by the 

Michigan Court of Appeals. Petitioner is held to its proofs for the remaining 

allegations in the corresponding paragraph. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these all 

34. Respondent admits as true that this is included in the Petitioner’s Articles of 

Incorporation ( Exhibit 3) 

35. Respondent admits as true. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations. 

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

of the allegations contained in this paragraph, and therefore denies these allegations.

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5 

 

40. Respondent lacks knowledge or information sufficient to form a belief as to

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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. 26-001232

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City of Detroit (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

Mary Beth

M.I.

Last Name

Cobbs

Firm Name (if any)

City of Detroit

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

2 Woodward Avenue

Suite 500

City or Town

Detroit

State

 Michigan

ZIP Code

48226

Telephone Number

(313) 237-3075

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

cobbm@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

/s/Mary Beth Cobbs

/s/

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Page 1

51536479.1/066667.00481 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

URBAN DEVELOMENT CORPORATION, 

MTT Docket No. 26-001232 

Petitioner, 

Parcel No. 13009300-5 

v. 

CITY OF DETROIT, 

Respondent. 

 ____________________________________________ 

MILLER, CANFIELD, PADDOCK AND 

STONE, P.L.C. 

Gregory A. Nowak (P39240) 

Attorney for Petitioner 

150 West Jefferson, Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 

Fax: (313) 496-8452 

 ____________________________________________ 

CERTIFICATE OF SERVICE 

The undersigned states that the Petition with Exhibits relative to the above-referenced matter 

were served with sufficient postage fully prepaid thereon upon the following persons as follows: 

Janice M. Winfrey, Clerk 

City of Detroit 

2 Woodward Avenue, Sute 200 

Detroit, MI 48226 

(served 8/24/2026) 

Charles Ericson, Assessor 

City of Detroit 

2 Woodward Avenue, Sute 804 

Detroit, MI 48226 

(served 8/25/2026)

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51536479.1/066667.00481 

Cathy M. Garrett, Clerk 

Wayne County 

2 Woodward Avenue, Sute 201 

Detroit, MI 48226

(served 8/24/2026)

Monique Bryant, Secretary 

Board of Education 

Detroit Public School District 

3011 W Grand Blvd 

Detroit, MI 48202 

(served 8/26/2026)

Scott T Vandemergel, Director 

Wayne County Equalization 

400 Monroe Street, 6th Floor 

Detroit, MI 48226 

(served 8/24/2026) 

Rachel Eubanks, State Treasurer 

Michigan Department of Treasury 

430 W. Allegan St. 

Lansing, MI 48933 

(served 8/25/2026)

I declare that the statements above are true to the best of my knowledge, information and belief. 

Dated: September 1, 2026 

Respectfully submitted, 

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

Attorneys for Petitioner 

/ s / Gregory A. Nowak 

Gregory A. Nowak (P39240) 

150 West Jefferson Ave., Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 

Email: nowakmillercanfield.com

Page 3

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Page 8

9/1/26,

Page 9

9

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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: 26-001232

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: Certificate of Service - Petition

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

50878507.2/066667.00481 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

URBAN DEVELOMENT CORPORATION, 

MTT Docket No. 26-____________ 

Petitioner, 

Parcel No. 13009300-5 

v. 

CITY OF DETROIT, 

Respondent. 

 ____________________________________________ 

MILLER, CANFIELD, PADDOCK AND 

STONE, P.L.C. 

Gregory A. Nowak (P39240) 

Attorney for Petitioner 

150 West Jefferson, Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 

Fax: (313) 496-8452 

 ____________________________________________ 

PETITION

NOW COMES, Petitioner, URBAN DEVELOPMENT CORPORATION, by and through its 

attorneys, Miller, Canfield, Paddock and Stone, P.L.C., and petitions this Tribunal as follows: 

GENERAL ALLEGATIONS 

1, 

Petitioner, URBAN DEVELOPMENT CORPORATION (the "Taxpayer"), is a Michigan non-

profit corporation with its principal place of business located at PO BOX 441691, DETROIT, MI 48244. 

2.

Petitioner is a party in interest as the owner of the Subject Property (described below).

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50878507.2/066667.00481 

3.

Respondent, CITY OF DETROIT (the “City”) is a municipality, existing under the laws of the 

State of Michigan and is responsible for the property tax assessments levied again the Subject Property 

(defined below). 

4.

Petitioner owns certain real property located at 19209 Mt Elliott, Detroit, MI 48234, Parcel 

no. 13009300-5 (the “Subject Property”). 

5.

The Subject Property is located at 19209 Mt Elliott, City of Detroit, County of Wayne, State 

of Michigan and is in the Detroit School District. 

6.

On information and belief, the Subject Property is classified as Industrial-Improved as to 

Parcel No. 13009300-5. 

7.

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

of Review are: 

Tax Year

True Cash Value

Assessed Value

Taxable Value

2026

$190,000

$95,000

$95,000

8.

The City withdrew the property tax exemption for tax year 2026. 

9.

Additionally, the Taxpayer received notification of an effort to revoke the exemption for prior 

periods through a State Tax Commission proceeding which the Commission had dismissed. 

10.

It appears that the City withdrew the exemption because they believe that the Subject 

Property cannot be in use partially due to utilities not being connected. 

11.

The Taxpayer stores items in the building such as lawn mowers and gardening equipment 

which is used for the volunteer activities that the Taxpayer coordinates. 

12.

The Taxpayer also holds community events and gatherings at the property at least once a 

month and have a generator on-site at the Subject Property.

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50878507.2/066667.00481 

13.

On May 14, 2025, the Taxpayer mailed a letter to the assessor to confirm that they actively 

use the Subject Property for storage of materials and equipment which are necessary for its community 

beautification work and also to hold regular events. 

14.

The Taxpayer did not receive a response from the City. 

15.

The Taxpayer is a non-profit corporation which meets Michigan’s definition of a charitable 

institution. 

16.

The Subject Property should be exempt from property tax. 

17.

The Taxpayer protests the basis for the City’s withdrawal of the exemption. 

18.

This appeal contests the withdrawal of the property tax exemption of the Subject Property, 

and is being submitted prior to the May 31, 2026 deadline related to commercial and industrial taxpayers. 

COUNT I — PETITIONER QUALIFIES FOR PROPERTY TAX EXEMPTION UNDER MCL 211.7o 

19.

Petitioner restates and incorporates herein paragraphs 1 through 18 above. 

20.

The City provided no explanation for the basis of the exemption withdrawal. 

21.

The statutes do not authorize the Assessor withdrawal the exemption without a substantive 

basis for the withdrawal. 

22.

The withdrawal was unlawful. 

23.

MCL 211.7o(1) provides: 

(1) Real or personal property owned and occupied by a nonprofit charitable institution while 

occupied by that nonprofit charitable institution solely for the purposes for which that nonprofit 

charitable institution was incorporated is exempt from the collection of taxes under this act. 

24.

Michigan Department of Treasury Bulletin 26 of 2017 dated December 12, 2017 provides 

that in determining whether a taxpayer is qualified for the exemption, a three part test is applied. If all three 

prongs of the test are met, then a claimant qualified for the charitable institution exemption. 

1. Is the real estate owned and occupied by the exemption claimant? 

2. Is the exemption claimant a nonprofit charitable institution?

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50878507.2/066667.00481 

3. Is the real estate occupied by the claimant solely for the purposes for which the claimant was 

incorporated? 

25.

The Subject Property is a 9,000-square-foot industrial facility which is owned by the 

Taxpayer as demonstrated by the last deed of record, Quit Claim Deed dated July 20, 2006 and recorded on 

November 27, 2006 in Liber 45647, page 1126, Wayne County Register of Deeds. The real estate is currently 

occupied solely by the Taxpayer. Exhibit 1. 

26.

The Taxpayer actively maintains the Subject Property. 

27.

The Subject Property stores landscaping equipment and materials for use in neighborhood 

beautification projects. Exhibit 2. 

28.

Caselaw has established that storage of items in an otherwise vacant property by a nonprofit 

charity is sufficient to meet the active use requirement. For example, Welcome Missionary Baptist Church v. 

City of Pontiac, decided by the Michigan Tax Tribunal and subsequently upheld by the Michigan Court of 

Appeals in 2017 (MTT Docket No. 13-004543; COA No. 330487).

29.

Welcome Missionary is a significant precedent for charitable organizations in Michigan with 

properties used for storage or outreach. The dispute involved a former nursing home located at 532 Orchard 

Lake Road, which was adjacent to the main church building. The church initially used the building for a health 

outreach program, but later transitioned to using it primarily to store donated food and furniture pending 

distribution to the community. The

Page 5

508

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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

URBAN DEVELOPMENT CORPORATION

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

PO BOX 441691

City or Town

DETROIT

State

Michigan

ZIP Code

48244

Telephone Number

(313)468-7083

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

vpeake@urbandevelopmentcorp.org

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Gregory

M.I.

A.

Last Name

Nowak

Firm Name (if any)

Miller Canfield Paddock & Stone PLC

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

150 West Jefferson Ave, Ste 2500

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3134967963

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

nowak@millercanfield.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]

19209 Mt Elliott

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48234

Taxing Authority (City or Township)

City of Detroit (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:

13009300-5

Classification of Property: Real (check one)

Industrial (check one)

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

95000

Current Taxable Value as established by the Board of Review:

95000

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

190000

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

0

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

0

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/ Gregory A Nowak

Payment Information

Amount: 250

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052186436197

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

Urban Development Corporation, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001232

City of Detroit, 

Respondent.

NOTICE OF DOCKET NUMBER

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

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

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

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

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

issuance of this notice evidencing the service of the petition. 

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

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

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

the notice may result in the dismissal of this case.

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

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

will result in Respondent being placed in default.

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

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

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

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 30, 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

50878507.2/066667.00481 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

URBAN DEVELOMENT CORPORATION, 

MTT Docket No. 26-____________ 

Petitioner, 

Parcel No. 13009300-5 

v. 

CITY OF DETROIT, 

Respondent. 

 ____________________________________________ 

MILLER, CANFIELD, PADDOCK AND 

STONE, P.L.C. 

Gregory A. Nowak (P39240) 

Attorney for Petitioner 

150 West Jefferson, Suite 2500 

Detroit, Michigan 48226 

(313) 963-6420 

Fax: (313) 496-8452 

 ____________________________________________ 

PETITION

NOW COMES, Petitioner, URBAN DEVELOPMENT CORPORATION, by and through its 

attorneys, Miller, Canfield, Paddock and Stone, P.L.C., and petitions this Tribunal as follows: 

GENERAL ALLEGATIONS 

1, 

Petitioner, URBAN DEVELOPMENT CORPORATION (the "Taxpayer"), is a Michigan non-

profit corporation with its principal place of business located at PO BOX 441691, DETROIT, MI 48244. 

2.

Petitioner is a party in interest as the owner of the Subject Property (described below).

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50878507.2/066667.00481 

3.

Respondent, CITY OF DETROIT (the “City”) is a municipality, existing under the laws of the 

State of Michigan and is responsible for the property tax assessments levied again the Subject Property 

(defined below). 

4.

Petitioner owns certain real property located at 19209 Mt Elliott, Detroit, MI 48234, Parcel 

no. 13009300-5 (the “Subject Property”). 

5.

The Subject Property is located at 19209 Mt Elliott, City of Detroit, County of Wayne, State 

of Michigan and is in the Detroit School District. 

6.

On information and belief, the Subject Property is classified as Industrial-Improved as to 

Parcel No. 13009300-5. 

7.

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

of Review are: 

Tax Year

True Cash Value

Assessed Value

Taxable Value

2026

$190,000

$95,000

$95,000

8.

The City withdrew the property tax exemption for tax year 2026. 

9.

Additionally, the Taxpayer received notification of an effort to revoke the exemption for prior 

periods through a State Tax Commission proceeding which the Commission had dismissed. 

10.

It appears that the City withdrew the exemption because they believe that the Subject 

Property cannot be in use partially due to utilities not being connected. 

11.

The Taxpayer stores items in the building such as lawn mowers and gardening equipment 

which is used for the volunteer activities that the Taxpayer coordinates. 

12.

The Taxpayer also holds community events and gatherings at the property at least once a 

month and have a generator on-site at the Subject Property.

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50878507.2/066667.00481 

13.

On May 14, 2025, the Taxpayer mailed a letter to the assessor to confirm that they actively 

use the Subject Property for storage of materials and equipment which are necessary for its community 

beautification work and also to hold regular events. 

14.

The Taxpayer did not receive a response from the City. 

15.

The Taxpayer is a non-profit corporation which meets Michigan’s definition of a charitable 

institution. 

16.

The Subject Property should be exempt from property tax. 

17.

The Taxpayer protests the basis for the City’s withdrawal of the exemption. 

18.

This appeal contests the withdrawal of the property tax exemption of the Subject Property, 

and is being submitted prior to the May 31, 2026 deadline related to commercial and industrial taxpayers. 

COUNT I — PETITIONER QUALIFIES FOR PROPERTY TAX EXEMPTION UNDER MCL 211.7o 

19.

Petitioner restates and incorporates herein paragraphs 1 through 18 above. 

20.

The City provided no explanation for the basis of the exemption withdrawal. 

21.

The statutes do not authorize the Assessor withdrawal the exemption without a substantive 

basis for the withdrawal. 

22.

The withdrawal was unlawful. 

23.

MCL 211.7o(1) provides: 

(1) Real or personal property owned and occupied by a nonprofit charitable institution while 

occupied by that nonprofit charitable institution solely for the purposes for which that nonprofit 

charitable institution was incorporated is exempt from the collection of taxes under this act. 

24.

Michigan Department of Treasury Bulletin 26 of 2017 dated December 12, 2017 provides 

that in determining whether a taxpayer is qualified for the exemption, a three part test is applied. If all three 

prongs of the test are met, then a claimant qualified for the charitable institution exemption. 

1. Is the real estate owned and occupied by the exemption claimant? 

2. Is the exemption claimant a nonprofit charitable institution?

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50878507.2/066667.00481 

3. Is the real estate occupied by the claimant solely for the purposes for which the claimant was 

incorporated? 

25.

The Subject Property is a 9,000-square-foot industrial facility which is owned by the 

Taxpayer as demonstrated by the last deed of record, Quit Claim Deed dated July 20, 2006 and recorded on 

November 27, 2006 in Liber 45647, page 1126, Wayne County Register of Deeds. The real estate is currently 

occupied solely by the Taxpayer. Exhibit 1. 

26.

The Taxpayer actively maintains the Subject Property. 

27.

The Subject Property stores landscaping equipment and materials for use in neighborhood 

beautification projects. Exhibit 2. 

28.

Caselaw has established that storage of items in an otherwise vacant property by a nonprofit 

charity is sufficient to meet the active use requirement. For example, Welcome Missionary Baptist Church v. 

City of Pontiac, decided by the Michigan Tax Tribunal and subsequently upheld by the Michigan Court of 

Appeals in 2017 (MTT Docket No. 13-004543; COA No. 330487).

29.

Welcome Missionary is a significant precedent for charitable organizations in Michigan with 

properties used for storage or outreach. The dispute involved a former nursing home located at 532 Orchard 

Lake Road, which was adjacent to the main church building. The church initially used the building for a health 

outreach program, but later transitioned to using it primarily to store donated food and furniture pending 

distribution to the community. The

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508

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

URBAN DEVELOPMENT CORPORATION

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

PO BOX 441691

City or Town

DETROIT

State

Michigan

ZIP Code

48244

Telephone Number

(313)468-7083

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

vpeake@urbandevelopmentcorp.org

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Gregory

M.I.

A.

Last Name

Nowak

Firm Name (if any)

Miller Canfield Paddock & Stone PLC

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

150 West Jefferson Ave, Ste 2500

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

3134967963

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

nowak@millercanfield.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]

19209 Mt Elliott

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48234

Taxing Authority (City or Township)

City of Detroit (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:

13009300-5

Classification of Property: Real (check one)

Industrial (check one)

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

95000

Current Taxable Value as established by the Board of Review:

95000

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

190000

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

0

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

0

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/ Gregory A Nowak

Payment Information

Amount: 250

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052186436197

Supporting Waiver Documents:

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