SFLD Hotel - Petition Severed 2025.pdf
Sfld Hotel LLC, Petitioner Vs. City Of Southfield, Respondent · 25-002508-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL SFLD Hotel LLC, Petitioner, v MTT Docket No. 25-002508 City of Southfield, Respondent. ENTIRE TRIBUNAL PROPERTY TAX SEVERED PETITION 1. Property Parcel Nos: 76-24-21-100-134 (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. The property identified above is classified as Commercial. 4. A protest to the Board of Review was not required. 5. The property or properties at issue are located in Oakland County. The property or properties’ address is: 27033 Northwestern Hwy, Southfield MI 6. The assessment or assessments at issue were established by the (applicable local governmental unit): City of Southfield 7. Petitioner’s legal residence or principal office address is: 7125 Orchard Lake Road, Ste 301, West Bloomfield, MI 48322 8. 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 or loss? ___ Yes ___No
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________uniformity of the property or properties’ assessment ________the property or the properties’ exemption from ad valorem taxation under MCL ______ 9. The tax year(s) at issue are: 2025 10. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 13,377,900 6,688,950 6,688,950 11. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 6,000,000 3,000,000 3,000,000 12. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 7,377,900 3,688,950 3,688,950 13. Petitioner requests the following relief (attach additional page if necessary): Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 taxable value and state equalized value of Petitioner’s Property to the amounts listed above in paragraph 11, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach additional page if necessary): The 2025 assessment, including state equalized value and taxable value, imposed on Petitioner’s Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: a. The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes;
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b. The assessment, including taxable value and/or state equalized value, is based upon an erroneous determination of the true cash value of that portion of Petitioner’s Property that is taxable under Michigan Law, and is based upon the application of wrong principles, and, c. The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminates against Petitioner and denies Petitioner its constitutional rights to uniformity, equal protection and due process of law. Signature of Petitioner’s Authorized Representative or, if none, Petitioner: __________________________________________________________________ Shawn G. Jappaya, Esq. Address: 7125 Orchard Lake Road. Suite 301 West Bloomfield, MI 48322 Telephone Number: (248) 626-6800 Email Address: shawn@jappayalaw.com Date: August 1, 2025