Amend to add year 2025.pdf
Daniel Zuckerbrod, Petitioner Vs. City Of Southfield, Respondent · 24-004053-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
1 STATE OF MICHIGAN IN THE MICHIGAN TAX TRIBUNAL Daniel and Daphna Zuckerbrod, Petitioners, vs. City of Southfield, Respondent. Docket no. 24–004053 ____________________________________________________________________/ DEAN & FULKERSON, P.C. Thomas P. Christy (P55593) Attorneys for Petitioner 100 West Big Beaver Road, Suite 650 Troy, Michigan 48084 248–362–1300/fax –1358 tchristy@dflaw.com HALLAHAN & ASSOCIATES Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) Attorneys for Respondent 1750 South Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302 248–731–3089 lhallahan@hallahanlaw.com ____________________________________________________________________/ PETITIONER’S MOTION TO AMEND PETITION TO CONTEST 2025 ASSESSED VALUE, TAXABLE VALUE, AND STATE EQUALIZED VALUE Petitioners Daniel and Daphna Zuckerbrod state for their motion: 1. The property at issue in this case is located in the City of Southfield, Oakland County, Michigan; is commonly known as 17565 Alta Vista Drive; has parcel ID #76–24–24–305–010; and is legally described as Lot 139, Sherwood Village Subdivision, according to the recorded plat thereof, as recorded in liber 88 of plats, page 26, Oakland County records. 2. On July 21, 2023, they filed case no. 23–002752 to contest the 2023 assessed value, taxable value, and state equalized value for the property.
Page 2
2 3. On July 31, 2024, they filed a motion to add the 2024 tax year to their appeal. The tribunal later severed the 2024 year into the present case. 4. As of today, the tribunal has not decided the 2024 appeal. 5. The petitioners contest the following related to 2025 real property taxes: (a) taxable value; (b) valuation; (c) assessment; and (d) uniformity. 6. This motion is timely under R792.10219(2) because it is filed before the July 31, 2025 deadline set by MCL 205.735a(6). 7. As required by MCL 205.735a(3), the petitioners appealed the city’s 2025 assessment for the property to the Southfield board of review. The appeal was denied. (Exhibit 1.) 8. The city’s assessor believes that the property’s true cash value for 2025 is $1,102,780; that the property’s assessed value and state equalized value for 2025 are $551,390; and that the taxable value for 2025 is $454,263. 9. Without formal appraisal for 2025, the petitioners believe that the property’s true cash value for 2025 is $995,000; that the property’s assessed value and state equalized value for 2024 should be $497,500; and that the taxable value for 2024 should be $412,854. 10. Thus, the amount in dispute for 2024 is $107,780 as to true cash value, $48,450 as to assessed value and state equalized value, and $41,409 as to taxable value. 11. No changes have been made to the property’s classification, and the petitioner still does not contest the classification.
Page 3
3 12. The dispute is based in part based on an addition or a loss to improvements on the property and the portion of the property’s value subject to the “cap.” 13. The respondent’s 2025 determination of assessed value, taxable value, and state equalized value, and the taxes to be levied and collected upon those determinations, are unlawful and/or operate as a fraud upon the taxpayer because the taxable value and/or state equalized value: (a) exceed the amount permitted by the Michigan constitution and statute; (b) are at a higher percentage of true cash value than permissible under the Michigan constitution and applicable statutes; (c) are based upon erroneous determination of the true cash value; (d) discriminate against the petitioner and deny the petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, the petitioner respectfully requests that the tribunal (a) allow the petitioner to amend its petition under MCL 205.737(4) or otherwise to include the 2025 tax year, and (b) determine that, subject to appraisal, the subject parcel’s 2025 true cash value is $995,000; that its 2025 assessed value and state equalized value are $497,500; and that its 2025 taxable value is $412,854; plus require the respondent to pay to the petitioner refunds attributable to such reductions, interest, and costs.
Page 4
4 Dated: July 30, 2025 Respectfully submitted, DEAN & FULKERSON, P.C. By: /s/ Thomas P. Christy (P55593) Attorneys for Petitioner 100 West Big Beaver Road, Suite 650 Troy, Michigan 48084 248–362–1300/fax –1358 tchristy@dflaw.com PROOF OF SERVICE Thomas P. Christy states that on July 30, 2025, he served a copy of this document upon Laura Hallahan by e-mail at lhallahan@hallahanlaw.com as permitted by TTR 221(11). I declare that the above statements are true to the best of my information, knowledge, and belief. Dated: July 30, 2025 /s/ Thomas P. Christy