MTT_Petition_2800_Lenox_FINAL.pdf

Ioan Miclea Petitioner V City Of Troy Respondent · 26-000488-TT

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MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

PETITION FOR PROPERTY TAX APPEAL

Tax Year: 2026

PETITIONER INFORMATION

Name:

Ioan & Grigoriana Miclea

Address:

2800 Lenox Drive, Troy, Michigan 48098-2392

Phone:

(586) 260-6186

Email:

jmiclea@yahoo.com

PROPERTY INFORMATION

Parcel Number:

88-20-07-102-027

Property Address:

2800 Lenox Drive, Troy, Michigan 48098

Classification:

401 – Residential Improved

Municipality:

City of Troy, Oakland County

ASSESSMENT VALUES IN DISPUTE

Troy 2026 Value

Petitioner's Contention

State Equalized Value (SEV):

$316,590

$207,500 or less

Assessed Value:

$316,590

$207,500 or less

Taxable Value:

$291,830

$242,229 or less

Implied True Cash Value:

$633,180

$415,000 or less

STATEMENT OF FACTS

1.

Petitioners Ioan and Grigoriana Miclea purchased the subject property at 2800 Lenox Drive, Troy,

Michigan on November 4, 2021, for a purchase price of $415,000 (Warranty Deed recorded

January 26, 2022, Oakland County). This was an arm's-length market transaction.

2.

Under MCL 211.27a, the transfer of ownership in November 2021 triggered uncapping of the

Taxable Value for the 2022 tax year, resetting the TV to equal the 2022 SEV.

3.

For the 2022 tax year, the City of Troy initially assessed the property at an SEV of approximately

$300,000, implying a True Cash Value of approximately $600,000 — far exceeding the actual

November 2021 arm's-length sale price of $415,000.

4.

Petitioners disputed the 2022 assessment using an appraisal obtained by the prior owner in

March 2021, which estimated the property's value at $500,000. As a result, Troy reduced the

2022 SEV to $250,000, and the Taxable Value was set at $250,000 (equal to SEV in the

uncapping year).

5.

Since 2022, Troy has applied the Proposal A inflation cap each year, increasing the Taxable

Value as follows:

Year

SEV

Taxable Value

TV Increase

2022

$250,000

$250,000

(uncapped)

2023

$299,430

$262,500

+5.0%

2024

$348,430

$275,620

+5.0%

2025

$365,280

$284,160

+3.1%

2026

$316,590

$291,830

+2.7%

6.

For the 2026 tax year, the City's March Board of Review declined to make any change to the

assessment. This petition follows that required local proceeding.

GROUNDS FOR APPEAL

GROUND 1: THE 2022 BASE SEV WAS SET INCORRECTLY, AND THE ERROR HAS

COMPOUNDED EACH YEAR SINCE THROUGH THE PROPOSAL A CAP MECHANISM

The foundational error in Petitioners' assessment history is that the 2022 SEV was set at $250,000 —

based on a pre-sale appraisal from March 2021 — rather than at $207,500, which is 50% of the actual

November 2021 arm's-length sale price of $415,000.

Under MCL 211.27(1), True Cash Value means "the usual selling price" of the property. Michigan

courts have consistently held that a recent arm's-length sale of the subject property is the most

probative evidence of True Cash Value. See Antisdale v Galesburg, 420 Mich 265 (1984); Huron Valley

State Bank v Pontiac, 121 Mich App 110 (1982).

The March 2021 appraisal used to set the 2022 SEV is inferior evidence for three reasons:

(a) It predates the actual sale by eight months;

(b) The actual sale occurred at $415,000 — $85,000 below the appraised value — demonstrating

the appraisal overstated market value; and

(c) The sale itself IS the market's determination of True Cash Value and supersedes any pre-sale

estimate.

The correct 2022 SEV, based on the actual sale price, should have been $207,500 (50% of $415,000).

Instead, it was set at $250,000 — an overstatement of $42,500 at the base year. Because the Proposal

A cap applies each year to the prior year's Taxable Value, this initial error has compounded forward:

Year

Correct TV

Troy's TV

Excess TV

2022

$207,500

$250,000

+$42,500

2023

$217,875

$262,500

+$44,625

2024

$228,769

$275,620

+$46,851

2025

$235,861

$284,160

+$48,299

2026

$242,229

$291,830

+$49,601

The correct 2026 Taxable Value, properly calculated from the arm's-length purchase price, is $242,229

— not $291,830. Troy's 2026 TV exceeds the correct amount by $49,601.

GROUND 2: THE 2026 SEV IMPLIES A TRUE CASH VALUE THAT IS UNSUPPORTED BY AND

INCONSISTENT WITH MARKET EVIDENCE

Troy's 2026 SEV of $316,590 implies a True Cash Value of $633,180. This figure is not supported by

market evidence for the following reasons:

(a) The subject property sold at arm's-length in November 2021 for $415,000. Troy's current

implied TCV of $633,180 represents a 52.6% increase over the actual purchase price in just four

years.

(b) The Troy residential market has not experienced appreciation consistent with this increase. To

the contrary, median list prices in Troy declined approximately 7% year-over-year as of March

2026, and price per square foot declined approximately 4% over the same period.

(c) The subject property is a 1977-built home of 2,734 square feet on approximately one acre. An

implied TCV of $633,180 equates to approximately $231 per square foot — inconsistent with

comparable sales in the immediate neighborhood.

GROUND 3: COMPARABLE SALES ON LENOX DRIVE SUPPORT A LOWER VALUE

Two properties on Lenox Drive — the same street as the subject property, within the same Middlesex

Country Home Sites subdivision — sold within the past year at prices inconsistent with Troy's implied

True Cash Value of $633,180. Critically, both comparable properties are newer in construction than the

subject property, which would ordinarily support a higher value. Yet both sold at prices implying a lower

SEV than what Troy has assigned to Petitioners' older home.

Subject Property

Comp #1

Comp #2

Address

2800 Lenox Dr

2752 Lenox Dr

2734 Lenox Dr

Year Built

1977

1987

1989

Sq Footage

2,734 sq ft

2,611 sq ft

2,382 sq ft

Sale Date

11/4/2021

7/16/2025

3/2/2026

Sale Price

$415,000

$584,000

$565,000*

Implied SEV

Troy says $316,590

$292,000

$282,500

* 2734 Lenox sold above asking price of $537,500, reflecting strong demand that still yielded a value well below

Troy's implied TCV for the subject.

Troy's 2026 SEV of $316,590 is $24,590 higher than the SEV implied by the newer 2752 Lenox sale,

and $34,090 higher than the SEV implied by the newer 2734 Lenox sale. A 1977-built home cannot

reasonably be assessed higher than neighboring properties built in 1987 and 1989 that have actually

transacted in the open market at lower values.

GROUND 4: THE DISPROPORTIONATE RELATIONSHIP BETWEEN SEV AND TAXABLE VALUE

IN 2026 FURTHER DEMONSTRATES OVERASSESSMENT

In 2026, Troy reduced the SEV by $48,690 (−13.3%), reflecting a downward market correction. Yet the

Taxable Value increased by $7,670 (+2.7%) due to the Proposal A cap mechanism. As a result, the

Taxable Value now stands at 92.2% of SEV — compared to 77.8% in 2025. This dramatic compression

in a single year illustrates that the Taxable Value has risen to a level approaching the SEV, which

would imply True Cash Value is approaching or equaling the assessed value. The market evidence —

actual sales on this street and in this zip code — does not support that conclusion.

BOARD OF REVIEW HISTORY

Petitioners appeared before the City of Troy March Board of Review on or about March 2026. The

Board declined to make any change, issuing its decision on March 23, 2026 (Exhibit A). This Tribunal

petition follows the required local proceeding per MCL 205.735a.

PETITIONER'S REQUESTED RELIEF

Petitioners respectfully request that the Michigan Tax Tribunal:

1. Find that the True Cash Value of the subject property for the 2026 tax year does not exceed

$415,000 (and more likely reflects current market conditions below that figure);

2. Reduce the 2026 State Equalized Value to no more than $207,500 (50% of the arm's-length

purchase price of $415,000), and in no event exceeding $292,000 (50% of the July 2025 sale price

of the newer comparable at 2752 Lenox Dr);

3. Reduce the 2026 Taxable Value to $242,229, properly calculated from the correct 2022 base

year value using the applicable Proposal A inflation multipliers; and

4. Grant such other relief as the Tribunal deems appropriate.

EXHIBITS

Exhibit A:

2026 Board of Review Decision (City of Troy, dated March 23, 2026) — NO CHANGE

Exhibit B:

2023 Notice of Assessment showing 2022 base values (TV $250,000 / SEV $250,000)

and 2023 inflation multiplier of 1.05

Exhibit C:

Historical assessment and tax record showing TV and SEV for tax years 2021 through

2026

Exhibit D:

Subject Property Purchase Documentation — Warranty Deed / Settlement Statement

evidencing arm's-length purchase on 11/4/2021 for $415,000 [TO BE ATTACHED]

Exhibit E:

Comparable Sale #1 — 2752 Lenox Dr, Troy MI 48098; sale date 7/16/2025; sale price

$584,000; built 1987; 2,611 sq ft [TO BE ATTACHED]

Exhibit F:

Comparable Sale #2 — 2734 Lenox Dr, Troy MI 48098; sale date 3/2/2026; sale price

$565,000 (above asking); built 1989; 2,382 sq ft [TO BE ATTACHED]

Exhibit G:

(Optional) March 2021 Appraisal ($500,000) — to demonstrate actual sale price

supersedes pre-sale estimate as evidence of TCV [TO BE ATTACHED IF AVAILABLE]

CERTIFICATION

I hereby certify that the information contained in this petition is true and accurate to the best of my

knowledge, information, and belief.

_________________________________

 

_________________________________

Ioan Miclea, Petitioner

 

Grigoriana Miclea, Petitioner

Date: _______________

 

Date: _______________

KEY LEGAL AUTHORITY: MCL 211.27(1) — True Cash Value = usual selling price | MCL 211.27a — Transfer of

ownership uncapping | MCL 205.735a — Board of Review appearance requirement | Antisdale v Galesburg, 420

Mich 265 (1984)

EXHIBIT A

2026 Board of Review Decision City of Troy — March 23, 2026

EXHIBIT C

Historical Assessment & Tax Record Taxable Value and SEV, Tax Years 2021–2026

EXHIBIT B

2023 Notice of Assessment 2022 Base Values: TV $250,000 / SEV $250,000

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