Docket 26-000571 Pettiion answers.pdf
Fh Hotels Inc Petitioner Vs. City Of Farmington Hills Respondent · 26-000571-TT
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DOCKET: 26-000571 Parcel ID: 22-23-14-101-039 30715 W 12 Mile Road, Farmington hills, MI 48334 PETTITION ANSWERS (For better readability) 8: Invoke the Tribunal’s Authority- Pursuant to MCL 205.735a(4)(a), a protest of the assessment of Commercial Real Property is not required to be made before the local Board of Review to invoke the Tribunal’s jurisdiction. Petitioner is invoking jurisdiction directly. Furthermore, the Petitioner’s authorized representative (General Manager) was physically out of the country during the Board of Review sessions and did not review the notice until March 14, 2026. Upon review, Petitioner noted an increase in taxable value of $935,380, which uncapped the property to an SEV that implies a market value significantly exceeding the actual arm's-length purchase price of $3.3 Million paid on Nov 20, 2026. Petitioner appeals both the SEV and Taxable Value to ensure the assessment reflects the property's True Cash Value as evidenced by the recent sale. 19: Petitioner Requests following relief- Petitioner respectfully requests that the Tribunal: 1. Grant jurisdiction over this appeal pursuant to MCL 205.735a(4)(a) for Commercial Real Property. 2. Correct the 2026 True Cash Value to reflect the actual arm’s-length purchase price of $3,300,000. 3. Reduce the 2026 State Equalized Value (SEV) and Taxable Value to $1,650,000 (50% of the purchase price), effectively correcting the uncapping error. 4. Order the City of Farmington Hills to adjust the 2026 tax rolls to reflect these corrected values prior to the issuance of the Summer and Winter tax bills. 5. Order a refund (plus interest) of any 2026 taxes that may be paid at the current erroneous assessment level during the pendency of this appeal 20. Specific facts for relief requested- • Arm’s-Length Transaction: The subject property was purchased by Petitioner in November 2025 for $3,300,000. This was an arm’s-length transaction between unrelated parties on the open market. • Professional Representation: Both Buyer and Seller were represented by licensed real estate sales agents and legal counsel, ensuring the price was negotiated at fair market value.
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DOCKET: 26-000571 Parcel ID: 22-23-14-101-039 30715 W 12 Mile Road, Farmington hills, MI 48334 • Proximity to Tax Status Date: The November 2025 sale occurred less than 60 days prior to December 31, 2025, tax status date, making the purchase price the most reliable evidence of True Cash Value for 2026. • Physical & Functional Obsolescence: The property is 40 years old (built circa 1986) and suffers from significant physical depreciation and functional obsolescence. The City’s assessment fails to account for the heavy capital expenditure required for a building of this age. • Economic Income & Profitability: The property has demonstrated a lack of profitability for several years. Pursuant to MCL 211.27(1), the assessment must consider "present economic income." The current assessment reflects a theoretical value that the actual income stream cannot support. • Erroneous Uncapping: While the transfer "uncapped" the property, Michigan law (MCL 211.27a) requires the new Taxable Value to be established at 50% of the actual True Cash Value ($1,650,000), not the City's inflated estimate.