Wal-Mart Real Estate Business Trust, Petitioner Vs. City Of Warren, Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

RIPLEY VENTURES, LLC, 

 

 

 

Petitioner, 

 

v 

 

REDFORD TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001684 

 

 

_____________________________________________________________________________/ 

 

JASON CONTI (P55617) 

FOLEY & LARDNER LLP 

Attorney for Petitioner 

500 Woodward Ave, Suite 2700 

Detroit, MI 48226 

(313) 234-7100 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

RESPONDENT’S RESPONSE TO PETITIONER’S MOTION TO AMEND 

PETITION TO CONTEST 2026 ASSESSED AND TAXABLE VALUES 

 

Respondent, Redford Township, by and through its attorneys, Hallahan & Associates, 

P.C., responds to the allegations made in Petitioner’s Motion to Amend as follows: 

1. 

Respondent admits the allegations in Paragraph 1 to the extent Petitioner’s real 

property pertains to the two parcels of real property identified to be at issue in Petitioner’s 

Petition. 

2. 

Respondent denies the allegations in Paragraph 2, including subparagraphs (a)-

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

and/or taxable values do not exceed permitted amounts, do not exceed the percentage of true 

cash value permitted by law, were correctly determined and are based upon correct application of

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2 

 

proper principles, and the values and Respondent’s mode of assessment are non-discriminatory 

and constitutional. 

3. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Motion but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. Respondent incorporates by reference the affirmative defenses set forth in 

its Answer to Petition herein. 

WHEREFORE, Respondent, Redford Township, requests the Tribunal enter an Order 

Denying Petitioner’s Motion to Amend and dismissing the appeal. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Kelsea M. Melcher_____________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: June 16, 2026 

(248) 731-3089 

 

 

 

 

 

 

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Response to 

Petitioner’s Motion to Amend to: 

 

Jason Conti 

Foley & Lardner LLP 

jconti@foley.com 

 

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

 

 

/s/ Kelsea M. Melcher_________________ 

Dated: June 16, 2026 

Kelsea M. Melcher

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

MICHIGAN TAX TRIBUNAL

Docket Number: 25-002292

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

Party Filing Document 

Respondent

Files

Document Type: Response to Motion

Attachment File Name: MTA 26 Response_Ripley_FINAL

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Wal-Mart Real Estate Business Trust, 

Petitioner, 

MTT Docket No. 25-002292 

v 

City of Warren, 

Respondent. 

Jackie J. Cook (P68781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Bldg. 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Motion to Amend Petition to Contest 

2026 Assessed Value, State Equalized Value, and Taxable Value 

Petitioner, Wal-Mart Real Estate Business Trust, through its attorneys, Honigman LLP, 

moves to amend the Petition in this matter to include the following: 

1.

In 2026, Respondent’s board of review determined the taxable value of 

Petitioner’s Property to be $5,402,161 and Respondent’s board of review assessed Petitioner’s 

Property at $6,540,130, which will result in a state equalized value of the same amount, based 

upon the tentative equalization factor. 

2.

The 2026 assessment – including the state equalized and taxable values – 

imposed on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and

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75737789.1 

the mode of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on 

Petitioner, because they 

a.

Exceed amounts permitted by the Michigan Constitution and applicable statutes; 

b. Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

c.

Are based on the application of wrong principles and an erroneous determination 

of the true cash value of that portion of Petitioner's Property that is taxable under 

Michigan law, if any; and 

d. Discriminate against Petitioner and deny Petitioner its constitutional rights to 

uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner moves that this Motion be granted, and Petitioner requests that 

the Tribunal enter an Order: (i) reducing the 2026 assessed value and state equalized value from 

$6,540,130 to $3,100,000; (ii) reducing the 2026 taxable value from $5,402,161 to $3,100,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: May 28, 2026 

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Jackie J. Cook (P68781) 

Daniel L. Stanley (P57052) 

2290 First National Bldg. 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

dstanley@honigman.com

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75737789.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Wal-Mart Real Estate Business Trust, 

Petitioner, 

MTT Docket No. 25-002292 

v 

City of Warren, 

Respondent. 

Jackie J. Cook (P68781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Bldg. 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Proof of Service

Lisa Joseph affirms that on May 28, 2026 she served a copy of Petitioner's Motion to 

Amend Petition to Contest 2026 Assessed Value, State Equalized Value, and Taxable Value and 

this Proof of Service in connection with the above-entitled cause upon the following: 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

via electronic mail. 

/s/ Lisa Joseph___________________________ 

 Dated: May 28, 2026_____ 

Lisa Joseph

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Docket #: 25-002292

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

Wal-Mart Real Estate Business Trust, 

 

 

 

Petitioner, 

 

v 

 

City of Warren, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002292 

 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-001158 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of the big box store 

commonly known as Walmart – Parcel No. 12-13-10-353-009 - located in Macomb County. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-001158 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

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2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-001158) has not yet been resolved. A Prehearing Conference is scheduled for 

September 23, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

001158 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

001158 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

001158. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-001158.

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3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ Daniel L. Stanley_________________ 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

 

 

Dated: September 19, 2025 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

Dated: September 19, 2025

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Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

Wal-Mart Real Estate Business Trust, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002292 

 

City of Warren, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

On September 19, 2025, the parties filed a joint motion requesting that the Tribunal hold 

this case in abeyance pending resolution of Docket No. 24-001158, which is currently 

pending before the Tribunal. In the motion, the parties state that resolution of the 2024 

case, involving the same parties, parcel, and legal issue, shall have a direct effect upon 

this appeal. They state that resolution of that case may result in the efficient 

administration of justice and guide resolution of this case. 

 

The Tribunal has considered the motion and the case file and finds that the parties have 

shown good cause to grant the motion. Placing this case in abeyance pending 

resolution of Docket No. 24-001158 will facilitate the efficient administration of justice, 

as that resolution may have a direct bearing on the outcome of the instant appeal. 

Therefore, 

 

IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of the resolution of Docket No. 24-001158 as to the need for further proceedings in 

this matter. 

 

 

 

Entered: September 23, 2025 

 

By _____________________________ 

bw 

 

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

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

Wal-Mart Real Estate Business Trust, 

 

 

 

Petitioner, 

 

v 

 

City of Warren, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002292 

 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-001158 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of the big box store 

commonly known as Walmart – Parcel No. 12-13-10-353-009 - located in Macomb County. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-001158 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

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2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-001158) has not yet been resolved. A Prehearing Conference is scheduled for 

September 23, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

001158 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

001158 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

001158. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-001158.

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3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ Daniel L. Stanley_________________ 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

 

 

Dated: September 19, 2025 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

Dated: September 19, 2025

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

WAL-MART REAL ESTATE BUSINESS TRUST, 

 

 

 

Petitioner, 

 

v 

 

CITY OF WARREN, 

 

 

 

Respondent. 

 

 

MTT Docket No. 25-002292 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

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

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

1. 

Respondent neither admits nor denies the allegations in Paragraph 1 as the 

Tribunal’s Order and Petitioner’s Petition speak for themselves. 

2. 

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

of the allegations set forth in Paragraph 2 and, therefore, leaves Petitioner to its proofs.

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2

3. 

Respondent admits the allegations in Paragraph 3 as to parcel number and location. 

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

remainder of the allegations set forth in Paragraph 3 and, therefore, leaves Petitioner to its proofs. 

4. 

Respondent admits the allegations in Paragraph 4 insofar as it is the entity that 

assesses and collects property taxes with relation to the parcel identified in the Petition. 

5. 

Respondent admits the allegations in Paragraph 5 as to the stated values. 

6. 

Respondent admits the allegations in Paragraph 6. 

7. 

Upon information and belief, Respondent admits the allegations in Paragraph 7. 

8. 

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

of the allegations set forth in Paragraph 8 and, therefore, leaves Petitioner to its proofs. 

9. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 9 but denies 

that Petitioner’s claims have merit and denies Petitioner is entitled to any relief. 

10. 

Respondent acknowledges Petitioner’s belief relative to the value of a loss but 

denies that such a loss has occurred. 

11. 

Respondent neither admits nor denies the allegations in Paragraph 11 as the General 

Property Tax Act speaks for itself. 

12. 

Respondent denies the allegations in Paragraph 12, including subparagraphs (a)-

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

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional.

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3

13. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent, City of Warren, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

__/s/Laura M. Hallahan________________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: July 21, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Warren, asserts the following affirmative defenses: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

3. 

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

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

4. 

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

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

its agents.

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4

5. 

Petitioner has failed to allege that the mode

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5

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002292

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Warren (MACOMB)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

RECEIVED «- 

JUN 11 2025 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Wal-Mart Real Estate Business Trust, 

Petitioner, 

v. 

City of Warren, 

Respondent. 

MTT Docket No. 25-002292 

Parcel No. 12-13-10-353-009 

Michael B. Shapiro (P20282) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

jcook@honigman.com 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea A. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Rd., Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

Ihallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

Proof of Service 

Lisa Joseph states that she is employed by Honigman LLP, attorneys for Petitioner, and 

that on June 11, 2025, she did serve a copy of Petitioner's Entire Tribunal Property Tax Petition, 

with docket number, upon the parties named on the attached list. 

Dated: June 11, 2025 

Jf 

fin Groep 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

WARREN 

ONE CITY SQUARE 

WARREN, MI 48093 

ASSESSOR 

WARREN 

ONE CITY SQUARE 

WARREN, MI 48093 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

DIRECTOR OF EQUALIZATION 

MACOMB COUNTY 

ATTN: F. KRYCIA ADM BLDG. 

1 S. MAIN ST., 8TH FLOOR 

MT. CLEMENS, MI 48043 

SECRETARY OF SCHOOL BOARD 

WARREN CONSOLIDATED SCHOOL DISTRICT (MACOMB) 

31300 ANITA DRIVE 

WARREN, MI 48093-1697 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0094

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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

Wal-Mart Real Estate Business Trust, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002292

City Of Warren, 

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: June 16, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

25-0013 

60869504.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Wal-Mart Real Estate Business Trust, 

Petitioner, 

v. 

City of Warren, 

Respondent. 

MTT Docket No. 25-002292 

Parcel No. 12-13-10-353-009 

Michael B. Shapiro (P20282) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com

jcook@honigman.com

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea A. Melcher (P85821) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Rd., Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Entire Tribunal Property Tax Petition 

Wal-Mart Real Estate Business Trust (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1.

Petitioner hereby files this Entire Tribunal Property Tax Petition pursuant to and as 

required by Michigan Tax Tribunal Order Severing 2025 Tax Year and Assigning it to Docket No. 

25-002292, dated June 5, 2025. 

2.

Petitioner's principal office address is 2608 SE J Street, Suite 2, Bentonville, AR 

72716-0555.

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2 

60869504.1 

3.

Petitioner is a party in interest with respect to property taxes on tax parcel number 

12-13-10-353-009 ("Petitioner's Property"), with an address of 29176 Van Dyke Ave, Warren, 

located in Macomb County, Michigan. 

4.

Respondent, City of Warren, assesses and collects property taxes on Petitioner's 

Property. 

5.

Respondent’s March Board of Review set the 2025 taxable value of Petitioner's 

Property at $5,260,138 and set the 2025 assessed value of Petitioner's Property at $6,761,660, 

which will result in a state equalized value in the same amount based upon the tentative 

equalization factor. 

6.

Petitioner's Property is classified as commercial real. 

7.

Petitioner's Property is presently used or available for use for retail purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

retail purposes. 

9.

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

value and (d) uniformity. 

10.

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

relative to the value of a loss. 

11.

A Board of Review protest was not required for Petitioner’s Property. 

12.

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

on Petitioner's 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:

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3 

60869504.1 

(a)

The 2025 assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable 

statutes; 

(b)

The 2025 assessment, including state equalized value and/or taxable value, 

is at a higher percentage of true cash value than permissible under the 

Michigan Constitution and applicable statutes; 

(c)

The 2025 assessment, including taxable value and/or state equalized value, 

is based upon an erroneous determination of the true cash value of that 

portion of Petitioner's Property that is taxable under Michigan law, and is 

based upon the application of wrong principles; and 

(d)

The 2025 assessment, including state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $5,260,138 to $3,800,000; (ii) reducing the 2025 

assessed and state equalized value of Petitioner's Property from $6,761,660 to $3,800,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled.

Page 4

4 

60869504.1 

Dated: June 11, 2025 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Michael B. Shapiro (P20282) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com

Dated: June 11, 2025 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

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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 

Wal-Mart Real Estate Business Trust, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 24-001158 

 

City of Warren, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION TO AMEND 

 

ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT TO 

DOCKET NUMBER 25-002292 

 

On May 5, 2025, Petitioner filed a motion requesting that the Tribunal permit it to amend 

the petition filed in this case to include the 2025 tax year. 

 

On May 27, 2025, Respondent filed a response to the motion. In the response, 

Respondent states that there is insufficient time to conduct discovery or prepare a 

valuation disclosure for the 2025 tax year. As such, the motion should be denied. 

Alternatively, the 2025 tax year should be severed to a separate docket. 

 

The Tribunal has considered the motion and the case file and finds that Petitioner timely 

filed the Motion to Amend, included the necessary information and filing fee, and 

otherwise met all requirements set forth in MCL 205.737 and MCL 205.735a. Due to 

the stage in which this case is at, however, and in the interest of judicial efficiency, the 

2025 tax year shall be severed from this case and assigned to a new docket number. 

Therefore, 

 

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. 

 

IT IS FURTHER ORDERED that Petitioner’s assessment appeal for the 2025 tax year is 

SEVERED and ASSIGNED to Docket No. 25-002292. 

 

IT IS FURTHER ORDERED that Petitioner shall file a petition for the 2025 tax year 

within 21 days of the entry of this Order. The petition shall note the docket number 

assigned by the Tribunal for the 2025 tax year and if filed utilizing the Tribunal’s e-filing 

system, must be filed on the assigned 2025 docket as a “Severed Petition.”1 

 

 

1 Alternatively, the petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via 

United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition 

may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax 

Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933.

Page 2

MTT Docket No. 24-001158 

Page 2 of 2 

 

Failure to comply with this Order may result in Petitioner being held in default, as 

provided by TTR 237. 

 

 

Entered: June 5, 2025 

 

 

 

By _____________________________ 

ejg/sb 

 

 

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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