Petition.pdf
Dundee Place Apartments, LLC; Dundee Place Apartments II, LLC; Dundee Place Petitioner Vs. Township Of Dundee Respondent · 26-000457-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL DUNDEE PLACE APARTMENTS, LLC; DUNDEE PLACE APARTMENTS II, LLC; DUNDEE PLACE APARTMENTS III, LLC; and DUNDEE PLACE APARTMENTS IV, LLC, Docket No. 26- Petitioners, Parcel Nos. 5842-014-015-91 v. 5842-014-015-30 5842-014-015-90 DUNDEE TOWNSHIP, 5842-040-711-41 Respondent. Jason C. Long (P59244) Jerome P. Pesick (P29039) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Entire Tribunal Property Tax Petition Petitioners Dundee Place Apartments, LLC; Dundee Place Apartments II, LLC; Dundee Place Apartments III, LLC; and Dundee Place Apartments IV, LLC, by and through their attorneys, Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal Property Tax Petition. The Parties 1. Petitioners are commonly controlled Michigan limited liability companies, all of which have their registered offices located at 321 Woodland Pass, Ste. 300, E. Lansing, Michigan 48823.
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2 2. Respondent Dundee Township is a Michigan general law township with its principal offices located at 179 Main St., Dundee, Michigan 48131. The Subject Properties 3. Petitioners are parties in interest in properties identified as: (a) Parcel No. 5842-014-015-91, commonly known as 140 Helle Blvd., Dundee, Michigan 48131. (b) Parcel No. 5842-014-015-30, commonly known as 124 Helle Blvd., Dundee, Michigan, 48131. (c) Parcel No. 5842-015-015-90, commonly known as property along Helle Blvd., Dundee, Michigan 48131. And (d) Parcel No. 5842-040-711-41, commonly known as property along Waterstradt Commerce Dr., Dundee, Michigan 48131. These properties are referred to in this Petition as the “Subject Properties.” 4. The Subject Properties are physically contiguous. 5. The Subject Properties are used as an apartment complex with consolidated office, management, and administrative functions. 6. The Subject Properties are located in Monroe County and are within the Dundee Community Schools public school district. The 2025 Property Tax Assessments 7. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Properties.
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3 8. For the 2026 tax year, Respondent classified the Subject Properties as commercial real property. 9. For the 2026 tax year, Respondent established the Subject Properties’ assessments for property taxes in the amounts set forth on the attached Multiple Parcel Form. 10. Petitioners contend that lawful assessments of the Subject Properties for the 2026 tax year cannot exceed the amounts set forth on the attached Multiple Parcel Form. 11. The amounts in dispute therefore equal the amounts set forth on the attached Multiple Parcel Form. 12. This Petition presents issues involving the Subject Properties’ valuation for property tax assessment purposes. Petitioners do not believe that this Petition presents any issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), defines those terms, but reserve their rights to assert issues involving losses should information supporting such issues become available. 13. The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are based on the misapplication of valuation principles, and (d) otherwise violate Petitioners’ rights.
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4 14. Petitioners do not assert that the Subject Properties’ 2026 assessments are not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Properties’ values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed the values set forth as Petitioner’s contentions on the attached Multiple Parcel Form and granting Petitioners all other relief to which they are entitled under Michigan law. Respectfully Submitted, WILLIAMS WILLIAMS RATTNER & PLUNKETT, PC By: /s/ Jason C. Long Jason C. Long (P59244) Jerome P. Pesick (P29039) Dated: April 1, 2026 Attorneys for Petitioners
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5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL DUNDEE PLACE APARTMENTS, LLC; DUNDEE PLACE APARTMENTS II, LLC; DUNDEE PLACE APARTMENTS III, LLC; and DUNDEE PLACE APARTMENTS IV, LLC, Docket No. 26- Petitioners, Parcel Nos. 5842-014-015-91 v. 5842-014-015-30 5842-014-015-90 DUNDEE TOWNSHIP, 5842-040-711-41 Respondent. Jason C. Long (P59244) Jerome P. Pesick (P29039) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Petition Multiple Parcel Form 1. The values for the Subject Properties established by Respondent’s Board of Review are: Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 5842-014-015-91 10,141,240 5,070,620 4,624,534 2026 5842-014-015-30 11,085,000 5,542,500 5,271,852 2026 5842-014-015-90 9,632,420 4,816,210 4,816,210 2026 5842-040-711-41 18,322,600 9,161,300 8,345,640 2026 Totals 49,181,260 24,590,630 23,058,236 Copies of the Subject Properties’ Notices of Assessment are attached to this Multiple Parcel Form as Exhibit A.
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6 2. Petitioner contends that lawful assessments for the Subject Properties cannot exceed the following amounts: Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 5842-014-015-91 8,640,000 4,320,000 4,320,000 2026 5842-014-015-30 7,920,000 3,960,000 3,960,000 2026 5842-014-015-90 5,040,000 2,520,000 2,520,000 2026 5842-040-711-41 6,480,000 3,240,000 3,240,000 2026 Totals 28,080,000 14,040,000 14,040,000 3. The values in dispute for the Subject Properties therefore equal the following amounts: Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 5842-014-015-91 1,501,240 750,620 304,534 2026 5842-014-015-30 3,165,000 1,582,500 1,311,852 2026 5842-014-015-90 4,592,420 2,296,210 2,296,210 2026 5842-040-711-41 11,842,600 5,921,300 5,105,640 2026 Totals 21,101,260 10,550,630 9,018,236
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Exhibit A
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Michigan Department of Treasury, Mectigah Depart THIS IS NOT A TAX BILL L-4400 Notice of Assessment, Taxable Valuation, and Property Classification This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c, as amended. FROM DUNDEE TOWNSHIP PARCEL IDENTIFICATION 179 MAIN STREET PARCEL NUMBER: 5842 014 015 91 DUNDEE, MI 48131 PROPERTY ADDRESS: BRYAN RENIUS, ASSESSOR 140 HELLE BLVD DUNDEE, MI 48131 SCHOOL DISTRICT CODE: 58050 OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: BN EXEMPTIONS *xw%+*%*RUTO**MIKED AADC 493 T9 BL #i# % Exempt As "Homeowners Principal Residence": .00% DUNDEE PLACE APTS LLC 9% Exempt As "Qualified Agricultural Property": .00% 321 WOODLAND PASS STE 100 EAST LANSING, MI 48823-2085 % Exempt As "MBT Industrial Personal": .00% (ELLY FLL TREE ELT FU TTT Rt PRE UE 1 EE [LET % Exempt As "MBT Commercial Personal: 00% Exempt As "Disabled Veteran or Surviving Spouse": O Yes [x] No Exempt As "Qualified Forest Property": O Yes Xl No Exempt As "Development Property": [1 Yes Xx No LEGAL DESCRIPTION: LAND SITUATED IN THE VILLAGE OF DUNDEE, COUNTY OF MONROE, STATE OF MICHIGAN BEING FURTHER DESCRIBED AS: PART OF THE SE 1/4 OF SEC 14, T6S.R6E, DUNDEE TWP, MONROE COUNTY, MI BEGINNING AT A PT S89 DEG 21' 58" E, A DIS ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 201 Commercial PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 201 Commercial The change in taxable value will increase/decrease your tax bill PRIOR AMOUNT CURRENT. CHANGE FROM ) TENTATIVE AMOUNT for the 2026 year by approximately: $5731 YEAR: 2025 YEAR. 226 | CORRENT YEAR 1. TAXABLE VALUE: 4,502,955 4,624,534 121,579 2. ASSESSED VALUE: 5,082,310 5,070,620 -11,690 3. TENTATIVE EQUALIZATION FACTOR: 1.000 : 4. STATE EQUALIZED VALUE (SEV): 5,082,310 5,070,620 -11,690 5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [yes No 6. Assessor Change Reason(s): MARKET ADJUSTMENT The 2026 Inflation rate Multiplier is: 1.027 Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the Following: Name: Telephone Number: Email Address: BRYAN RENIUS 734-529-2650 DUNDEETOWNSHIPASSESSING@YAHOO.COM March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: MARCH BOARD OF REVIEW WILL MEET FOR APPOINTMENTS ON MONDAY, MARCH 9, 2026 FROM 1 PM TO 4 PM AND 6 PM TO 9 PM AND TUESDAY, MARCH 10, 2026 FROM 9 AM TO 3 PM AT THE DUNDEE TOWNSHIP HALL - 179 MAIN STREET, DUNDEE, MI 48131. PLEASE CALL (734) 529-2650 TO MAKE AN APPOINTMENT OR EMAIL DUNDEETOWNSHIPASSESSING@YAHOO.COM. YOU MAY ALSO APPEAL BY LETTER. ALL LETTERS MUST BE RECIEVED NO LATER THAN MARCH 10, 2026 AT 12:00 PM (POSTMARKS NOT ACCEPTED). 3669
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SRB Ty THIS IS NOT A TAX BILL L-4400 Notice of Assessment, Taxable Valuation, and Property Classification This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c, as amended. FROM DUNDEE TOWNSHIP PARCEL IDENTIFICATION 179 MAIN STREET PARCEL NUMBER: 5842 014 015 30 DUNDEE, MI 48131 PROPERTY ADDRESS: BRYAN RENIUS, ASSESSOR 124 HELLE BLVD DUNDEE, MI 48131 SCHOOL DISTRICT CODE: ~~ 58050 OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: Jo. EXEMPTIONS S44%AA4*AUTO*+MIXED AADC 493 T9 P1 H### % Exempt As "Homeowners Principal Residence": .00% DUNDEE PLACE APARTMENTS II LLC % Exempt As "Qualified Agricultural Property”: 00% 321 WOODLAND PASS STE 100 . Si 0; EAST LANSING, MI 48823-2085 % Exempt As "MBT Industrial Personal: .00% [71 LEY | FECCELE) FLLERTY 11 TT ELLER LTT LLL LE EL A % Exempt As "MBT Commercial Personal": 00% Exempt As "Disabled Veteran or Surviving Spouse": O Yes = No Exempt As "Qualified Forest Property": O Yes No Exempt As "Development Property”: O Yes No LEGAL DESCRIPTION: PER SURVEY SEC 14 T6S R6E 9.195 AC COM S 89 DEG 21'58"E ALG S LI OF SEC 14 317.37 FT & N 0 DEG 54'57"E 1387.58 FT FR THE S 1/4 COR OF SD SEC 14 TH N 0 DEG 54'57"E 717.25 FT TH S 89 DEG 05'03"E 355 FT TH S 0 DEG 54'57"W 24.52 FT TH S 89 DEG 05'03"E 140 FT TH S 0 DEG 54'57"W 204.72 FT TH S 89 DEG 05'03"E 234.32 FT TH S ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 201 Commercial PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 201 Commercial The change in taxable value will increase/decrease your tax bill PRIOR AMOUNT CURRENT CHANGE FROM \ TENTATIVE AMOUNT PRIOR YEAR TO for the 2026 year by approximately: $6533 YEAR: 2025 YEAR: 2026 CURRENT YEAR 1. TAXABLE VALUE: 5,133,255 5,271,852 138,597 2. ASSESSED VALUE: 5,535,930 5,542,500 6,570 3. TENTATIVE EQUALIZATION FACTOR: 1.000 i i 4. STATE EQUALIZED VALUE (SEV): 5,535,930 5,542,500 6,570 5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [Yes No 6. Assessor Change Reason(s): MARKET ADJUSTMENT The 2026 Inflation rate Multiplier is: 1.027 Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the Following: Name: Telephone Number: Email Address: BRYAN RENIUS 734-529-2650 DUNDEETOWNSHIPASSESSING@YAHOO.COM March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: MARCH BOARD OF REVIEW WILL MEET FOR APPOINTMENTS ON MONDAY, MARCH 9, 2026 FROM 1 PM TO 4 PM AND 6 PM TO 9 PM AND TUESDAY, MARCH 10, 2026 FROM 9 AM TO 3 PM AT THE DUNDEE TOWNSHIP HALL - 179 MAIN STREET, DUNDEE, MI 48131. PLEASE CALL (734) 529-2650 TO MAKE AN APPOINTMENT OR EMAIL DUNDEETOWNSHIPASSESSING@YAHOO.COM. YOU MAY ALSO APPEAL BY LETTER. ALL LETTERS MUST BE RECIEVED NO LATER THAN MARCH 10, 2026 AT 12:00 PM (POSTMARKS NOT ACCEPTED). 3673
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ne gp Tos. THIS IS NOT A TAX BILL L-4400 Notice of Assessment, Taxable Valuation, and Property Classification This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c, as amended. FROM DUNDEE TOWNSHIP PARCEL IDENTIFICATION 179 MAIN STREET PARCEL NUMBER: 5842 014 015 90 DUNDEE, MI 48131 PROPERTY ADDRESS: BRYAN RENIUS, ASSESSOR HELLE BLVD DUNDEE, MI 48131 SCHOOL DISTRICT CODE: ~~ 58050 OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: _— EXEMPTIONS wk** #4 *AUTOX*MIXED AADC 493 T9 P1 #iH# 9% Exempt As "Homeowners Principal Residence": 00% DUNDEE PLACE APTS III LLC % Exempt As "Qualified Agricultural Property”: 00% 321 WOODLAND PASS [] 0, EAST LANSING, MI 48823-2085 % Exempt As "MBT Industrial Personal”: .00% FIL LEU PO TLL TTT LET TY Ee Le LL % Exempt As "MBT Commercial Personal”: .00% Exempt As "Disabled Veteran or Surviving Spouse™ [ Yes [x] No Exempt As "Qualified Forest Property": O Yes x No Exempt As "Development Property": [1 Yes No LEGAL DESCRIPTION: 5.63 AC. A PARCEL OF LAND BEING PART OF THE SOUTHEAST QUARTER (1/4) OF SECTION FOURTEEN (14), TOWN SIX (6) SOUTH, RANGE SIX (6) EAST, IN THE VILLAGE OF DUNDEE, MONROE COUNTY, MICHIGAN, SAID PARCEL OF LAND BEING BOUNDED ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 202 Commercial PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 202 Commercial The change in taxable value will increase/decrease your tax bill PRIOR AMOUNT Le HME AR CHANGE FROM ; PRIOR YEAR TO forthe 2026 year by approximately: $4490 YEAR: 2025 YEAR: 2026 CURRENT YEAR 1. TAXABLE VALUE: 4,720,944 4,816,210 95,266 2. ASSESSED VALUE: 5,117,050 4,816,210 -300,840 3. TENTATIVE EQUALIZATION FACTOR: 1.000 i ; 4. STATE EQUALIZED VALUE (SEV): 5,117,050 4,816,210 -300,840 5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [Yes No 6. Assessor Change Reason(s): MARKET ADJUSTMENT The 2026 Inflation rate Multiplier is: 1.027 Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the Following: Name: Telephone Number: Email Address: BRYAN RENIUS 734-529-2650 DUNDEETOWNSHIPASSESSING@YAHOO.COM March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: MARCH BOARD OF REVIEW WILL MEET FOR APPOINTMENTS ON MONDAY, MARCH 9, 2026 FROM 1 PM TO 4 PM AND 6 PM TO 9 PM AND TUESDAY, MARCH 10, 2026 FROM 9 AM TO 3 PM AT THE DUNDEE TOWNSHIP HALL - 179 MAIN STREET, DUNDEE, MI 48131. PLEASE CALL (734) 529-2650 TO MAKE AN APPOINTMENT OR EMAIL DUNDEETOWNSHIPASSESSING@YAHOO.COM. YOU MAY ALSO APPEAL BY LETTER. ALL LETTERS MUST BE RECIEVED NO LATER THAN MARCH 10, 2026 AT 12:00 PM (POSTMARKS NOT ACCEPTED). 3671
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i THIS IS NOT A TAX BILL L-4400 Notice of Assessment, Taxable Valuation, and Property Classification This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34c, as amended. FROM DUNDEE TOWNSHIP PARCEL IDENTIFICATION 179 MAIN STREET PARCEL NUMBER: 5842 040 711 41 DUNDEE, MI 48131 PROPERTY ADDRESS: BRYAN RENIUS, ASSESSOR WATERSTRADT COMMERCE DR DUNDEE, MI 48131 SCHOOL DISTRICT CODE: 58050 OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: i. EXEMPTIONS wad kax* AUTOS MIXED AADC 493 TO Pl H##4 % Exempt As "Homeowners Principal Residence": 00% DUNDEE PLACE APARTMENTS IV LLC 9% Exempt As "Qualified Agricultural Property": 00% 321 WOODLAND PASS STE 300 ) a EAST LANSING, MI 48823-2085 % Exempt As "MBT Industrial Personal": .00% [LET LERLLY | ELEY LY PL EL | LEY ET TU ETT TE EEE UT % Exempt As "MBT Commercial Personal”: .00% Exempt As "Disabled Veteran or Surviving Spouse": OJ Yes ES No Exempt As "Qualified Forest Property": Od Yes No Exempt As "Development Property": [J Yes [X] No LEGAL DESCRIPTION: 5.40 AC. A PARCEL OF LAND BEING PART OF THE SOUTHEAST QUARTER (1/4) OF SECTION FOURTEEEN (14), TOWN SIX (6) SOUTH, RANGE SIX (6) EAST, IN THE VILLAGE OF DUNDEE, MONROE COUNTY, MICHIGAN, SAID PARCEL OF LAND BEING BOUNDED ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 201 Commercial PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 201 Commercial The change in taxable value will increase/decrease your tax bill PRIOR AMOUNT CURRENT CHANGE FROM \ TENTATIVE AMOUNT PRIOR YEAR TO for the 2026 year by approximately: $63429 YEAR: 3025 YEAR: 2026 CURRENT YEAR 1. TAXABLE VALUE: 7,000,000 8,345,640 1,345,640 2. ASSESSED VALUE: 7,000,000 9,161,300 2,161,300 3. TENTATIVE EQUALIZATION FACTOR: 1.000 4. STATE EQUALIZED VALUE (SEV): 7,000,000 9,161,300 2,161,300 5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [Yes No 6. Assessor Change Reason(s): MARKET ADJUSTMENT New Construction The 2026 Inflation rate Multiplier is: 1.027 Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the Following: Name: Telephone Number: Email Address: BRYAN RENIUS 734-529-2650 DUNDEETOWNSHIPASSESSING@YAHOO.COM March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: MARCH BOARD OF REVIEW WILL MEET FOR APPOINTMENTS ON MONDAY, MARCH 9, 2026 FROM 1 PM TO 4 PM AND 6 PM TO 9 PM AND TUESDAY, MARCH 10, 2026 FROM 9 AM TO 3 PM AT THE DUNDEE TOWNSHIP HALL - 179 MAIN STREET, DUNDEE, MI 48131. PLEASE CALL (734) 529-2650 TO MAKE AN APPOINTMENT OR EMAIL DUNDEETOWNSHIPASSESSING@YAHOO.COM. YOU MAY ALSO APPEAL BY LETTER. ALL LETTERS MUST BE RECIEVED NO LATER THAN MARCH 10, 2026 AT 12:00 PM (POSTMARKS NOT ACCEPTED). 3670