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Petition Argos Building LLC.pdf

Argos Building LLC Petitioner Vs. City Of Kalamazoo Respondent · 26-000813-TT

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STATE OF MICHIGAN

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Argos Building LLC,

Petitioner,

v.

MTT Docket No. 26_________

Parcel ID 06-15-377-100

City of Kalamazoo,

Respondent.

______________________________________________________________________________

PETITION

Argos Building LLC (“Petitioner”), through its attorney Eva Cantarella at the law firm Hertz

Schram PC, petitions this Tribunal as follows:

1.

Petitioner is a limited liability company whose business address is 215 E. Michigan

Avenue, Suite 200, Kalamazoo, MI 49007-3909.

2.

The Subject Property is a six-story office building built in 1988 comprising 36,542

leaseable square feet, situated on 0.17 acres at 141 E. Michigan Avenue, Kalamazoo, MI, and further

identified by parcel ID number 06-15-377-100.

3.

Petitioner is the party in interest, as Petitioner is responsible for paying the property

taxes on the Subject Property.

4.

Respondent City of Kalamazoo levies and collects the property taxes on the Subject

Property.

5.

The Subject Property is classified 201 Commercial Improved and was built for its

current use as an office building.

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6.

The Subject Property is located in Kalamazoo County and is in the Kalamazoo City

school district.

7.

This Petition concerns issues relating to (a) valuation, (b) assessment, and (c) taxable

value.

8.

For the 2026 year, Respondent determined the following assessed, state-equalized,

and taxable values for the Subject Property:

Respondent’s 2026 Value

Contentions

Assessed Value

State-Equalized

Value

Taxable Value

Parcel ID 06-15-377-100

$1,570,800

$1,570,800

$1,570,800

9.

Petitioner did not protest Respondent’s value contentions to the City of Kalamazoo

Board of Review.

10.

Based on Respondent’s contention of Assessed Value, Respondent determined the

Subject Property’s true cash value to equal $3,141,600 [double the AV].

11.

For the following reasons, Petitioner contends Respondent has over-valued the

Subject Property.

12.

The Subject Property is 27.77% vacant and most of its leased space is short term,

meaning it is at risk of losing more tenants and becoming more vacant over the next few years.

13.

Perhaps not surprisingly, the Subject Property’s 2025 net operating income (after

excluding interest, amortization and depreciation from expenses) was only $33,272!

14.

One reason for the Subject’s high vacancy is that it has no on-site parking. In fact,

there is no way to create such parking because the site is only 0.17 acres in size–just a little bigger

than the footprint of the building.

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15.

Although there are a few metered parking spots along the street, the closest surface

lot or parking garage is about a block away.

16.

Additionally, both elevators in the building are in urgent need of replacement. In fact,

one elevator is currently not working at all.

17.

Written quotes to replace the elevators have exceeded $800,000.

18.

When Petitioner purchased the Subject Property, Petitioner was unaware the elevators

were in poor mechanical condition and on the verge of needing to be replaced.

19.

Given the foregoing, Petitioner contends the 2026 true cash value of the Subject

Property is $2,000,000 and therefore the 2026 assessed, state-equalized, and taxable values should

be as follows:

Petitioner’s 2026 Value

Contentions

Assessed Value

State-Equalized

Value

Taxable Value

Parcel ID 16-15-377-100

$1,000,000

$1,000,000

$1,000,000

20.

Petitioner is unaware of any dispute concerning the value of a statutory “addition”

or “loss” in determining the Subject Property’s taxable value.

21.

Should Petitioner hereafter become aware of any such dispute, Petitioner reserves the

right to amend this Petition to reflect the dispute.

22.

Petitioner requests that the Tax Tribunal enter an Order (i) reducing the 2026

assessed, state-equalized and taxable values of the Subject Property to the amounts contended by

Petitioner, and (ii) requiring Respondent to pay Petitioner any refunds attributable to such reductions,

plus allowable interest and costs.

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Respectfully submitted

Hertz Schram PC

/s/ Eva T. Cantarella 

Eva T. Cantarella (P51917)

Attorney for Petitioners

1760 S. Telegraph Road

Bloomfield Hills, MI 48302-0183

off. (248) 335-5000; fax. (248) 335-3346

ecantarella@hertzschram.com 

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