X Holdings LLC, Petitioner Vs. City Of Warren, Respondent

Page 1

RECEIVED 

SEP 3 0 2025 

Cnkii: 

1847 

Amt: $50.00 

ranInfosde06 

26059101-1 

09/29/2% 

MICHIGAN TAX TRIBUNAL 

ir 

TranInfo:4606 

 26059101-1 

09/29/25 

=) 

ID: 

FOLTER LAW GROUP 

’ 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

X Holdings LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MOAHR Docket No. 25-002512 

City of Warren 

Respondent. 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

(VALUATION) 

1. The subject property is in Macomb 

County. 

2. 

Parcel Number: 12-13-34-101-028 

(If more than one parcel is at issue, attach a completed Multiple Parcel Stipulation 

Form addressing all other parcels at issue.) 

3. 

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

of Review are: 

Tax year 

Assessed Value (AV) 

| Taxable Value (TV) 

2025 

1,056,340 

1,056,340 

4. 

The values for the property identified above as stipulated by the parties for 

settlement purposes are: 

Tax year 

True Cash Value 

AV 

Tv 

2025 

1,800,000 

900,000 

900,000 

5. 

If the stipulated TV does not equal the prior year TV multiplied by the applicable 

inflation rate multiplier, explain why (e.g., transfer of ownership, additions, losses,

Page 2

MOAHR Docket No. 25-002612 

Page 2 of 2 

of the refund, the walver of interest, etc. (attach additional page if necessary): 

’ 

d 

efunds 

shall 

be 

ble 

jointly 

to 

Petitio 

d 

"Polte 

"(Rep), 

and mailed to: Polter Law Group, 2600 W Big Beaver, Ste L100, Troy, Mi 48084 

NOTE: The Stipulation MUST include ALL parcels and ALL tax years included in the 

appeal (including subsequent tax years on or after April 1 of each year for appeals 

pending in the Small Claims Division). The parties may agree, however, to withdraw the 

appeal of specific parcels and/or tax year(s). 

IF APPLICABLE, complete the following section(s). Otherwise, LEAVE BLANK. 

7. The parties agree to the withdrawal of parcef number: 

(If more than one parcel is being withdrawn, attach a separate page addressing 

all other parcels being withdrawn.) 

8. 

The partles agree to the withdrawal of tax year(s) 

Signat 

Petitioner's Authorized gpa 

tive or, If none, Petitioner: 

E} 

) 

p 

~ 

\ 

= 

Printed Name: Stephen Polter, JD, MBA (P72591) 

Date: August 22, 2025 

Signature of Respondent's authorized representative; 

J 

1% 

Printed Name: Jennifer Pierce (P57078) Attorney for Respondent 

Date: August 22, 2025

Page 3

"

£ 

i 

0 

Po lter fein Caer 

2600 W. Bic BEAVER RD, 

oo 

Suite L 100 

Er 

$e 

TROY, Ml “5084

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 

X Holdings LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002512 

 

City of Warren, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-002512 

Page 2 of 2 

 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, and (xviii) after June 30, 2025, through December 31, 2025, at the rate of 

8.66%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

By

 

 

Entered: September 8, 2025 

jc 

 

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

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

RECEIVED 

SEp 0 4 2025 

pena, 

AR 

2 

MICHIGAN TAX TRIBUNAL 

. 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

X Holdings LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MOAHR Docket No, 25-002512 

City of Warren 

, 

Respondent. 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

(VALUATION) 

1. 

The subject property is in Macomb 

2. 

Parcel Number: 12-13-34-101-028 

(If more than one parcel is at issue, attach a completed Multipte Parcel Stipulation 

Form addressing all other parcels at issue.) 

County. 

3. 

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

of Review are: 

Tax year 

Assessed Value (AV) 

Taxable Value (TV) 

2025 

1,066,340 

1,056,340 

4, 

The values for the property identified above as stipulated by the parties for 

settlement purposes are: 

Tax year 

True Cash Value 

AV 

Tv 

2025 

1,800,000 

900,600 

900,000 

5. 

If the stipulated TV does not equal the prior year 

TV multiplied by the applicable 

inflation rate multiplier, explain why (e.g., transfer of ownership, additions, losses, 

omitted property etc.)

Page 2

MOAHR Docket No. 25-002612 

Page 2 of 2 

of the refund, the waiver of interest, etc. (attach additional page if necessary): 

All and any refunds shall be payable jointly to Petitioner and "Polter Law" (Rep), 

and mailed to: Polter Law Group, 2600 

W Big Beaver, Ste L100, Troy, MI 48084 

NOTE: The Stipulation MUST include ALL parcels and ALL tax years included in the 

appeal (including subsequent tax years on or after April 

1 of each year for appeals 

pending in the Small Claims Division). The parties may agree, however, to withdraw the 

appeal of specific parcels and/or tax year(s). 

IF APPLICABLE, complete the following section(s). Otherwise, LEAVE BLANK. 

7. 

The parties agree to the withdrawal of parcel number: 

(If more than one parcel is being withdrawn, attach a separate page addressing 

all other parcels being withdrawn.) 

titioner's Authorized pa 

8. 

The parties agree to the withdrawal of tax year(s) 

Ww, 

ray if none, Petitioner: 

INNA KAR 

d 

Re 

SS 

L 

Printed Name: Stephen Polter, JD, MBA (P72591) \ 

Date: August 22, 2025 

Signature of Respondent's authorized representative: 

Qenniiter Prisca 

J 

[4 

Printed Name: Jennifer Pierce (P57078) Attorney for Respondent 

Date: August 22, 2025

Page 3

L—— === 

EPT/N 

EXPRESS PROPERTY 

TAX APPEALS LLC 

A division of Polter Law Group 

BA4175013 

2600 W Big Beaver 

| Ste L100 

Troy, MI 48084

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

RECEIVED 

SEp 0 4 2025 

pena, 

AR 

2 

MICHIGAN TAX TRIBUNAL 

. 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

X Holdings LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MOAHR Docket No, 25-002512 

City of Warren 

, 

Respondent. 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

(VALUATION) 

1. 

The subject property is in Macomb 

2. 

Parcel Number: 12-13-34-101-028 

(If more than one parcel is at issue, attach a completed Multipte Parcel Stipulation 

Form addressing all other parcels at issue.) 

County. 

3. 

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

of Review are: 

Tax year 

Assessed Value (AV) 

Taxable Value (TV) 

2025 

1,066,340 

1,056,340 

4, 

The values for the property identified above as stipulated by the parties for 

settlement purposes are: 

Tax year 

True Cash Value 

AV 

Tv 

2025 

1,800,000 

900,600 

900,000 

5. 

If the stipulated TV does not equal the prior year 

TV multiplied by the applicable 

inflation rate multiplier, explain why (e.g., transfer of ownership, additions, losses, 

omitted property etc.)

Page 2

MOAHR Docket No. 25-002612 

Page 2 of 2 

of the refund, the waiver of interest, etc. (attach additional page if necessary): 

All and any refunds shall be payable jointly to Petitioner and "Polter Law" (Rep), 

and mailed to: Polter Law Group, 2600 

W Big Beaver, Ste L100, Troy, MI 48084 

NOTE: The Stipulation MUST include ALL parcels and ALL tax years included in the 

appeal (including subsequent tax years on or after April 

1 of each year for appeals 

pending in the Small Claims Division). The parties may agree, however, to withdraw the 

appeal of specific parcels and/or tax year(s). 

IF APPLICABLE, complete the following section(s). Otherwise, LEAVE BLANK. 

7. 

The parties agree to the withdrawal of parcel number: 

(If more than one parcel is being withdrawn, attach a separate page addressing 

all other parcels being withdrawn.) 

titioner's Authorized pa 

8. 

The parties agree to the withdrawal of tax year(s) 

Ww, 

ray if none, Petitioner: 

INNA KAR 

d 

Re 

SS 

L 

Printed Name: Stephen Polter, JD, MBA (P72591) \ 

Date: August 22, 2025 

Signature of Respondent's authorized representative: 

Qenniiter Prisca 

J 

[4 

Printed Name: Jennifer Pierce (P57078) Attorney for Respondent 

Date: August 22, 2025

Page 3

L—— === 

EPT/N 

EXPRESS PROPERTY 

TAX APPEALS LLC 

A division of Polter Law Group 

BA4175013 

2600 W Big Beaver 

| Ste L100 

Troy, MI 48084

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

RECEIVED 

JUL 2 9 2005 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

X Holdings LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 25-002512 

City of Warren 

; 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Stephen Polter 

states that on July2$, 2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. Assessor (via certified mail): 

1 City Square # 310, Warren, MI 48093 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

1 City Square # 310, Warren, MI 48093 

3. 

County Equalization Director (via first class mail or personal service): 

1S Main St 6th floor, Mt Clemens, MI 48043 

4. 

County Clerk (via first class mail or personal service): 

120 N Main St, Mt Clemens, MI 48043 

5. 

Secretary of the local school board (via first class mail or personal service): 

12900 Frazho, Warren MI 48089 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer

Page 2

Rel Led Carne ~ rk 

i 

mn 

wl pif li UBTHIE [ite dull 

5 

=

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

X HOLDINGS LLC 

MOAHR Docket #. 25-002512 

Petitioner, 

Parcel ID No. 12-13-34-101-028 

v. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER (P72591) 

Attorney for Petitioner 

2600 W. Big Beaver, Suite L100 

Troy, Michigan 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, MI 48093 

(586) 574-4671 

ipierce@cityofwarren.org 

/ 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) SS. 

COUNTY OF MACOMB) 

On 

the date 

below, 

| 

sent 

via 

e-mail 

to 

Stephen 

Polter 

at spolter@polterlaw.com, 

a 

copy 

of 

Respondent City 

of Warren’s Response to Petition, Affirmative Defenses and Proof of

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

X HOLDINGS LLC 

MOAHR Docket #. 25-002512 

Petitioner, 

Parcel ID No. 12-13-34-101-028 

V. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER (P72591) 

Attorney for Petitioner 

2600 W. Big Beaver, Suite L100 

Troy, Michigan 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, MI 48093 

(586) 574-4671 

ipierce@cityofwarren.org 

/ 

RESPONSE TO PETITION 

Respondent, 

City 

of Warren, 

by 

its 

attorney, MARY MICHAELS, 

City Attorney and 

JENNIFER PIERCE, Assistant City Attorney, in response to the Petition states as follows: 

1. 

Respondent admits the allegations contained in paragraph 1.

Page 2

6. 

Respondent 

admits 

the 

allegations 

contained 

in 

paragraph 

6 

for assessing 

purposes. 

7. 

No allegations are set forth in paragraph 7 and therefore no response is necessary. 

8. 

No allegations are set forth in paragraph 8 and therefore no response is necessary. 

9. 

No 

allegations 

are 

set 

forth 

in 

paragraph 

9 

and 

therefore 

no response 

is 

necessary.. 

10. 

Respondent admits the allegations in paragraph 10. 

11. 

Respondent admits the allegations contained in paragraph 11. 

12. 

In response 

to Paragraph 

12, Respondent 

is without knowledge 

or information 

sufficient to form a belief as to the truth of the allegations, and therefore leaves Petitioner to its 

proofs. 

13. 

In response to Paragraph 

13, Respondent 

is without knowledge or information 

sufficient to form a belief as to the truth of the allegation and therefore leaves Petitioner to its 

proofs. 

14. 

Respondent admits the allegations contained in paragraph 14. 

15. 

No 

allegations 

are 

set 

forth 

in 

paragraph 

15 

and therefore 

no response 

is 

necessary. 

186. 

Respondent admits the amounts set forth for the assessed and taxable values. 

Respondent further states that the true cash value is $2,112,686.00. 

17. 

In response to Paragraph 

17, Respondent 

is without knowledge 

or information 

sufficient to form 

a belief as to the truth of the allegation and therefore leaves Petitioner to its 

proofs.

Page 3

20. 

No 

allegations 

are 

set 

forth 

in paragraph 

20 and 

therefore 

no response 

is 

necessary. 

THEREFORE, Respondent City of Warren requests this Tribunal deny the requested 

relief, dismiss the Petition with prejudice, and award Respondent costs 

it incurred in the defense 

of this appeal. 

Respectfully submitted, 

By: 

[slJennifer Pierce 

JENNIFER PIERCE (P57078) 

Assistant City Attorney 

Attorneys for Respondent 

Dated: July 10, 2025 

JP/s Response to Petition, Affirmative Defenses and POS — X Holdings LLC — ID 113560

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

X HOLDINGS LLC 

Petitioner, 

Vv. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER (P72591) 

Attorney for Petitioner 

2600 W. Big Beaver, Suite L100 

Troy, Michigan 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Ml 48093 

(586) 574-4671 

ipierce@cityofwarren.org 

MOAHR Docket #. 25-002512 

Parcel ID No. 12-13-34-101-028 

AFFIRMATIVE DEFENSES 

Respondent, 

City 

of Warren, 

by 

its 

attorney, MARY MICHAELS, 

City Attorney and 

JENNIFER PIERCE, Assistant City Attorney, 

in response to the Petition, submit the following 

Affirmative Defenses:

Page 5

Tribunal. 

4, 

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

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

agents. 

5. 

Petitioner failed 

to allege that the mode and method 

of assessing the subject 

property fails to conform to the mode and method applied 

in the case of all other properties in 

Respondent's taxing unit for the year in question. 

6. 

Petitioner failed to show that any factor other than fifty percent (50%) was applied 

to the true cash value of Petitioner's property, as well as all others, to arrive at the respective 

assessments appearing on the roll, and also failed to allege specific and sufficient facts to support 

its allegations that the property's taxable value is improper. 

7. 

Petitioner failed to submit any evidence warranting relief from the assessments to 

the Board of Review. 

8. 

Petitioner, 

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

state equalization as to which 

it has no legal standing and cannot maintain a cause of action. 

9. 

Respondent reserves the right to raise additional defenses as may become known 

to it during the course of these proceedings. 

Respectfully submitted, 

By: 

[slJennifer Pierce 

JENNIFER PIERCE (P57078) 

Assistant City Attorney 

Attorneys for Respondent 

Dated: July 10, 2025

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Page 1

X HOLDINGS LLC 

Petitioner, 

Vv. 

CITY OF WARREN, 

Respondent. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

MOAHR Docket #. 25-002512 

Parcel ID No. 12-13-34-101-028 

STEPHEN POLTER (P72591) 

Attorney for Petitioner 

2600 W. Big Beaver, Suite L100 

Troy, Michigan 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, MI 48093 

(586) 574-4671 

jpierce@cityofwarren.org 

/ 

APPEARANCE 

PLEASE ENTER 

the appearance 

of MARY MICHAELS, 

Acting 

City Attorney, 

and 

JENNIFER PIERCE, Assistant City Attorney, 

as attorneys for the Respondent 

in the above- 

captioned cause of action. 

Respectfully submitted, 

MARY MICHAELS (P44601)

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

X HOLDINGS LLC 

MOAHR Docket #. 25-002512 

Petitioner, 

Parcel ID No. 12-13-34-101-028 

V. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER (P72591) 

Attorney for Petitioner 

2600 W. Big Beaver, Suite L100 

Troy, Michigan 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Ml 48093 

(586) 574-4671 

ipierce(@cityofwarren.org 

/ 

PROOF OF SERVICE 

STATE OF MICHIGAN) 

) SS. 

COUNTY OF MACOMB) 

On the date below, 

| sent by e-mail, a copy of our Appearance and Proof of 

Service to: Mr. Stephen Polter at spolter@polterlaw.com. 

| declare that the statements above are true to the best of my information, 

knowledge, and belief.

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Page 1

RECEIVED 

JUN 02 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

ST ANSING 

DIRECTOR 

X Holdings LLC 

; 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 

City of Warren 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 12-13-34-101-028 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

x 

real ___ personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? __ Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4, 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201Comm

Page 2

MTT Docket No. 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Macomb 

County. The 

property or properties’ address is: 

22950 Van Dyke 

Warren, Ml 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): Warren 

Petitioner's legal residence or principal office address is: 

901 N Larch 

Lansing MI 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition orloss? ___ Yes __ No

Page 3

MTT Docket No. 

Page 3 of 4 

16. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

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

Board of Review are: 

Taxable Value 

1,056,340 

Assessed Value 

1,056,340 

Tax Year 

True Cash Value 

2025 

2,112,680 

17. 

Petitioner contends that the values for the property identified above are: 

Taxable Value 

Tax Year 

True Cash Value 

State Equalized Value 

2025 

1,600,000 

800,000 

800,000 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

512,680 

256,340 

256,340 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Reduction of TCV and accordingly AV/TV to more reflect these accurate figures based on comps, 

condition, income, vacancy, etc.

Page 4

MTT Docket No. 

Page 4 of 4 

Printed Name of detitioners Authorized Representative or, if none, Petitioner: 

Stephen Polter 

Email Address: spolter@polterlaw.com 

Mailing Address: 

2600 W Big Beaver, Ste L100, Troy, MI 48084 

Telephone Number: 248-213-6800 

Date: May 25, 2025

Page 5

May 27, 2025 

RECEIVED 

—— 

- 

o 

MAY-80 2025 

f= [= 

I FAN 

MICHIGAN TAX TRIBUNAL 

EXPRESS PROPERTY TAX APPEALS LLL 

A division of Polter Law Group 

2nd Floor Michigan Tax Tribunal 

2407 N. Grand River Avenue 

Lansing, Michigan 48906 

Re: 

Multiple 2025 PTA 

To whom it may concern, 

This mailing contains sixty-three (“63”) commetcial property tax appeals/petitions and one 

(“1”) multi (2) contiguous residential appeal/petition, along with the requisite filing fees, as follows: 

SXM LLC v Hadley Twp. (multi — 2) Res., along with 2 checks (#1345-46) for 

$125 ea. 

CCCU v Muskegon/Fruitpott, along with 2 checks; one (#1320) for $250, one 

(#1393) for $150 (totaling $400). 

CCCU v Commetce Twp., along with 2 checks; one (#1321) for $250, one (#1391) 

for $150 (totaling $400). 

CCCU v Notton Shores, along with 1 check (#1319) in the amount of $250. 

TOCU v Sandusky, along with 1 check (#1317) in the amount of $250. 

TOCU v Owosso, along with 1 check (#1318) in the amount of $250. 

W Investors v FH, along with 1 check (#1378) in the amount of $400. 

Rite Aid Cotp (Lewis) v Pinckney, along with 1 check (#1336) in the amount of 

$400. 

Watren Manor v Warten, along with 2 checks; one (#1311) for $600, one (#1390) 

for $25 (totaling $625 — contiguous multi (2)). 

2Changs v N'Ville, along with 2 checks; one (#1350) for $250, one (#1389) for 

$150 (totaling $400). 

5016 Greenfield v Richfield, along with 1 check (#1330) in the amount of $250. 

Springfield v. Hampton, along with 1 check (#1331) in the amount of $400. 

Westbelt v Clawson, along with 1 check (#1337) in the amount of $400. 

CVS

Page 6

X

Page 7

J

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

X Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002512

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 25, 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

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

RECEIVED 

JUN 02 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

ST ANSING 

DIRECTOR 

X Holdings LLC 

; 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 

City of Warren 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 12-13-34-101-028 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

x 

real ___ personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? __ Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4, 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201Comm

Page 2

MTT Docket No. 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Macomb 

County. The 

property or properties’ address is: 

22950 Van Dyke 

Warren, Ml 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): Warren 

Petitioner's legal residence or principal office address is: 

901 N Larch 

Lansing MI 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition orloss? ___ Yes __ No

Page 3

MTT Docket No. 

Page 3 of 4 

16. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

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

Board of Review are: 

Taxable Value 

1,056,340 

Assessed Value 

1,056,340 

Tax Year 

True Cash Value 

2025 

2,112,680 

17. 

Petitioner contends that the values for the property identified above are: 

Taxable Value 

Tax Year 

True Cash Value 

State Equalized Value 

2025 

1,600,000 

800,000 

800,000 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

512,680 

256,340 

256,340 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Reduction of TCV and accordingly AV/TV to more reflect these accurate figures based on comps, 

condition, income, vacancy, etc.

Page 4

MTT Docket No. 

Page 4 of 4 

Printed Name of detitioners Authorized Representative or, if none, Petitioner: 

Stephen Polter 

Email Address: spolter@polterlaw.com 

Mailing Address: 

2600 W Big Beaver, Ste L100, Troy, MI 48084 

Telephone Number: 248-213-6800 

Date: May 25, 2025

Page 5

May 27, 2025 

RECEIVED 

—— 

- 

o 

MAY-80 2025 

f= [= 

I FAN 

MICHIGAN TAX TRIBUNAL 

EXPRESS PROPERTY TAX APPEALS LLL 

A division of Polter Law Group 

2nd Floor Michigan Tax Tribunal 

2407 N. Grand River Avenue 

Lansing, Michigan 48906 

Re: 

Multiple 2025 PTA 

To whom it may concern, 

This mailing contains sixty-three (“63”) commetcial property tax appeals/petitions and one 

(“1”) multi (2) contiguous residential appeal/petition, along with the requisite filing fees, as follows: 

SXM LLC v Hadley Twp. (multi — 2) Res., along with 2 checks (#1345-46) for 

$125 ea. 

CCCU v Muskegon/Fruitpott, along with 2 checks; one (#1320) for $250, one 

(#1393) for $150 (totaling $400). 

CCCU v Commetce Twp., along with 2 checks; one (#1321) for $250, one (#1391) 

for $150 (totaling $400). 

CCCU v Notton Shores, along with 1 check (#1319) in the amount of $250. 

TOCU v Sandusky, along with 1 check (#1317) in the amount of $250. 

TOCU v Owosso, along with 1 check (#1318) in the amount of $250. 

W Investors v FH, along with 1 check (#1378) in the amount of $400. 

Rite Aid Cotp (Lewis) v Pinckney, along with 1 check (#1336) in the amount of 

$400. 

Watren Manor v Warten, along with 2 checks; one (#1311) for $600, one (#1390) 

for $25 (totaling $625 — contiguous multi (2)). 

2Changs v N'Ville, along with 2 checks; one (#1350) for $250, one (#1389) for 

$150 (totaling $400). 

5016 Greenfield v Richfield, along with 1 check (#1330) in the amount of $250. 

Springfield v. Hampton, along with 1 check (#1331) in the amount of $400. 

Westbelt v Clawson, along with 1 check (#1337) in the amount of $400. 

CVS

Page 6

X

Page 7

J

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.