LMP Ann Arbor Petition 2.0.pdf

Lmp Ann Arbor Property Owner LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001001-TT

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1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

LMP ANN ARBOR PROPERTY OWNER, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel Nos. 09-09-29-108-044 

v. 

 

 

 

 

 

 

 

 

 09-09-29-108-042 

 

CITY OF ANN ARBOR, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Williams Williams Rattner & Plunkett, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner LMP Ann Arbor Property Owner, LLC, by and through its attorneys, 

Williams Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal 

Property Tax Petition. 

The Parties 

1. 

Petitioner LMP Ann Arbor Property Owner, LLC, is a Michigan limited 

liability company with its registered offices located at 3410 Belle Chase Way, Ste. 

600, Lansing, Michigan 48911. 

2. 

Respondent the City of Ann Arbor is a Michigan municipal corporation 

with its principal offices located at 301 E. Huron St., Ann Arbor, Michigan 48104.

2 

The Subject Property 

3. 

Petitioner owns two contiguous parcels of real property identified as 

Parcel No. 09-09-29-108-044, commonly known as 616 E. Washington St., Ann Arbor, 

Michigan 48104, and Parcel No. 09-09-29-108-042, commonly known as 630 E. 

Washington St., Ann Arbor, Michigan 48104. These properties are referred to 

collectively in this Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Washtenaw County and are within 

the Ann Arbor public school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ 

assessments for property taxes in the amounts set forth in Paragraph 1 of the 

attached Petition Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments for the Subject Properties 

for the 2026 tax year cannot exceed the amounts set forth in Paragraph 2 of the 

attached Petition Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts set forth in 

Paragraph 3 of the attached Petition Multiple Parcel Form.

3 

10. 

This Petition presents issues involving the Subject Properties’ valuation 

for assessment purposes. This Petition presents issues involving “additions” as the 

General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), defines that term. 

Petitioner does not believe that this Petition presents any issues arising out of 

“losses” as the GPTA defines that term but reserves its right to assert issues involving 

losses should information supporting such issues become available. 

11. 

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 Petitioner’s rights. 

12. 

Petitioner does 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 be consistent with the 

values set forth in Paragraph 2 of the attached Multiple Parcel Form and granting 

Petitioner all other relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

Williams Williams Rattner & Plunkett, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

 Jason C. Long (P59244) 

Dated: May 15, 2026 

 

 

Attorneys for Petitioner

4 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

LMP ANN ARBOR PROPERTY OWNER, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel Nos. 09-09-29-108-044 

v. 

 

 

 

 

 

 

 

 

 09-09-29-108-042 

 

CITY OF ANN ARBOR, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Williams Williams Rattner & Plunkett, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Petition Multiple Parcel Form 

 

 

1. 

Respondent’s 2026 March Board of Review established the Subject 

Properties’ assessments in the following amounts: 

Parcel Number 

 

True Cash Value 

Assessed Value 

Taxable Value 

09-09-29-108-044 

109,918,800 

54,959,400 

53,042,215 

09-09-29-108-042 

 6,993,800 

 3,496,900 

 3,453,421 

Totals 

 

 

116,912,600 

58,456,300 

56,495,636 

 

Copies of the Notices of Assessment are attached to this Petition Multiple Parcel 

Form as Exhibit A. 

 

2. 

Petitioner contends that lawful assessments for the Subject Properties 

cannot exceed the following amounts: 

Parcel Number 

 

True Cash Value 

Assessed Value 

Taxable Value 

09-09-29-108-044 

85,000,000 

42,500,000 

42,500,000 

09-09-29-108-042 

 5,000,000 

 2,500,000 

 2,500,000 

Totals 

 

 90,000,000 

45,000,000 

45,000,000

5 

 

3. 

The amounts in dispute therefore equal the following amounts: 

 

Parcel Number 

 

True Cash Value 

Assessed Value 

Taxable Value 

09-09-29-108-044 

24,918,800 

12,459,400 

10,542,215 

09-09-29-108-042 

 1,993,800 

 996,900 

 953,421 

Totals 

 

 

26,912,600 

13,456,300 

11,495,636

Exhibit A

Michigan Department of Treasury, 

1018 (Rev. 10-25) 

THIS 

IS NOT A TAX BILL 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under tho autherily of Public Act 206 of 1893, Sec. 211.24c and Sec.211.34¢, as amended. 

L-4400 

FROM CITY OF ANN ARBOR 

PARCEL IDENTIFICATION 

ASSESSOR'S OFFICE 

PARCEL NUMBER: 

09-09-29-108-044 

PO BOX 8647 

PROPERTY ADDRESS: 

ANN ARBOR, Mi 48107 

616 E WASHINGTON ST 2 

Ann Arbor, MI 48104 

SCHOOL DISTRICT CODE: 

81010 

OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: 

EXEMPTIONS 

FAA for PROPERTY OWNER, LLC 

% Exempt 

As "Homeowners Principal Residence™: 

0% 

ARLSBAD CA 

9201 

% Exempt 

As "Qualified Agricultural Property™ 

0% 

Cc 

A 

3 

% Exempt 

As "MBT Industrial Personal™: 

0% 

% Exempt As "MBT Commercial Personal™: 

0% 

Food ‘Disabled Veteran or Surviving 

[J Yes 

= 

No 

Exemptas “Development Property”: 

0 Yes 

[13] 

No 

LEGAL DESCRIPTION: 

UNIT 2 616 EAST WASHINGTON STREET CONDOMINIUM 

SPLIT/COMBINED ON 03/10/2022 FROM 09-09-29-108-037, 09-08-29-108-036, 08-09-29-108-035, 09-09-29-108-034, 09-09-29-108-01 

ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 

201 

Commercial 

PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 

201 

Commercial 

The 

Taxable 

Value 

entered 

in 

the " 

\ 

e Taxable 

Value entered 

in the ‘CHANGE FROM PRIOR 

YEAR TO 

PRIORAMOUNT | CURRENT TENTATIVE | CHANGE FROM 

CURRENT YEAR" column does NOT indicate the change in your 

- 

; 

P 

property taxes. Property taxes are calculated based on the 2026 

YEAR: 

AMOUNT YEAR: 

RIOR YEAR TO 

TAXABLE VALUE (Line 1) 

2025 

2026 

CURRENT YEAR 

TAXABLE VALUE: 

21,633413 

53,042,215 

31,408,802 

ASSESSED VALUE: 

TENTATIVE EQUALIZATION FACTOR: 

1.000 

STATE EQUALIZED VALUE (SEV): 

22,093,200 

22,093,200 

32,866,200 

Assessor Change Reason(s): 

arket Adjustment, Partial Construction 

1 

2. 

3. 

4. 

5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [Ives 

[3] No 

6. 

M

Michigan Department of Treasury, 

1019 (Rev. 10-25) 

THIS 

IS NOT A TAX BILL 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of Public Act 206 of 1883, Sec. 211.24c 

and Sec.211.34c, as amended. 

L-4400 

LMP ANN ARBOR PROPERTY OWNER LLC 

% Exempt 

As "Homeowners Principal Residence” 

FROM cron aon 

i 

PO BOX 8647 

PROPERTY ADDRESS: 

ANN ARBOR, MI 48107 

630 E WASHINGTON ST 

Ann Arbor, Mi 48103 

SCHOOL DISTRICT CODE: 

81010 

OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: 

EXEMPTIONS 

0% 

1.000 

4. STATE EQUALIZED VALUE (SEV): 

PO BOX 130339 

% Exempt As "Qualified Agricultural Property™ 

0% 

CARLSBAD CA 92013 

% Exempt 

As "MBT Industrial Personal”: 

0% 

% Exempt 

As "MBT Commercial Personal®: 

0% 

Exempt 

As "Disabled Veteran or Surviving 

Spouse™ 

0 Yes 

[= 

No 

Exempt 

As "Development Property”: 

[J Yes 

[X] 

No 

LEGAL DESCRIPTION: 

- 

h 

oo 

UNIT 3 630 EAST WASHINGTON STREET CONDOMINIUM 

SPLIT/COMBINED ON 03/09/2022 FROM 09-09-29-108-038; 

ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 

201 

Commercial 

PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 

201 

Commercial 

The Taxable Value entered in the "CHANGE FROM PRIOR YEAR TO 

CURRENT YEAR" column does NOT indicate the change in your 

PRIORAMOUNT | CURRENT TENTATIVE | CHARGE FROM 

property taxes. Property taxes are calculated based on the 2026 

YEAR: 

AMOUNT YEAR: 

PRIOR YEAR 

° 

TAXABLE VALUE (Line 1) 

2025 

2026 

CURRENT 

YEA 

1. TAXABLE VALUE: 

317,548 

3,453,421 

3,135,873 

2. ASSESSED VALUE: 

3. TENTATIVE EQUALIZATION FACTOR: 

3,127,300 

5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? [yes 

x No 

6. Assessor Change Reason(s): 

Market Adjustment, Parcel Review, New Construction

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