20260914_PropertyTax_MIStateTribunal_VS4_wt.pdf
Toni Zhang, Petitioner V City Of Ann Arbor, Respondent · 25-002568-TT
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Michigan Tax Tribunal Appeal Tax Year 2025 Tongxiao (Toni) Zhang & Tong Wang Parcel Number: 09-09-10-402-133 3071 N. Spurway Drive, Ann Arbor, MI 48105 Michigan Tax Tribunal Hearing: October 15, 2026 MTT Case No. 25-002568
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Table of Contents • I. Executive Summary & Requested Relief • II. Market Evidence • III. Subject Property — Location & Proximity Impairment • IV. Comparable Sales Analysis • V. Reconciliation & Requested Valuation • Attachments / Supporting Evidence 2
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Executive Summary / Requested Relief Basis for Appeal: Petitioner contends that the 2025 SEV of $398,600 exceeds 50% of the subject property's True Cash Value as of December 31, 2024. Petitioner's Position • North Oaks resale evidence shows that property values have not uniformly appreciated since the subject's July 2021 purchase. • A review of all identified repeat sales within North Oaks since July 2021 shows that 11 of 16 properties (68.75%) subsequently sold below their prior purchase prices.* • The subject property has an unusual and permanent proximity/privacy impairment that is not adequately reflected in Respondent's comparable sales. • Model/floor plan and lot/location characteristics materially affect market value within the community and should be considered when selecting and adjusting comparable sales. • Each of Respondent's three comparable sales has materially superior characteristics that require appropriate adjustments when estimating the subject property's value. • Based on the market evidence and adjustments presented in this appeal, Petitioner respectfully requests a True Cash Value of $611,854 and a corresponding SEV of $305,927. *Source from public records 3
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Market Evidence: North Oaks Villa Sales Pair Data Since July 2021 • There are a total of 16 condos in our community that were purchased in or after July 2021 (when petitioner’s condo was purchased) and then subsequently sold later. • Of these 16 condos, 11 (68.75%) subsequently sold below their prior purchase prices. • The largest price drop observed is over $90,000 and the largest percentage drop is over 10%. • The purchase-price-weighted average annual percentage change is −1.77%, indicating an overall declining price trend of the North Oaks Villa condos since July 2021. Using 365 days per year, the period from July 22, 2021 to December 31, 2024 is approximately 3.45 years. 4 Address Purchase Date Sale Date Yeas in-between Purchase Price Sale Price Price Change Price Change % Annual % Change 1 3077 N SPURWAY DR 2021-07-12 2026-06-10 4.91 624,995 610,000 -14,995 -2.40% -0.49% 2 3079 N SPURWAY DR 2021-07-16 2024-07-17 3.00 690,000 758,000 68,000 9.86% 3.18% 3 3106 MILLBURY LN 2021-09-10 2024-04-22 2.61 838,801 799,000 -39,801 -4.74% -1.84% 4 3083 N SPURWAY DR 2022-01-27 2024-04-17 2.22 615,000 660,000 45,000 7.32% 3.23% 5 3095 MILLBURY LN 2022-04-22 2026-02-20 3.83 965,471 875,000 -90,471 -9.37% -2.53% 6 3097 MILLBURY LN 2022-04-28 2023-10-11 1.45 677,593 699,000 21,407 3.16% 2.16% 7 3099 MILLBURY LN 2022-05-24 2025-08-01 3.19 653,674 600,000 -53,674 -8.21% -2.65% 8 3101 MILLBURY LN 2022-05-25 2022-12-16 0.56 926,928 850,000 -76,928 -8.30% -14.30% 9 3111 MILLBURY LN 2022-09-07 2024-03-29 1.56 714,367 667,000 -47,367 -6.63% -4.31% 10 3312 SUNTON RD 2022-10-20 2026-04-08 3.47 799,846 740,000 -59,846 -7.48% -2.22% 11 3302 SUNTON RD 2023-01-24 2025-06-20 2.40 819,119 735,000 -84,119 -10.27% -4.41% 12 3306 SUNTON RD 2023-02-28 2025-10-10 2.61 705,000 700,000 -5,000 -0.71% -0.27% 13 3370 ROSEFORD BLVD 2023-03-21 2026-08-31 3.45 574,995 525,000 -49,995 -8.69% -2.60% 14 3372 ROSEFORD BLVD 2023-03-28 2025-01-23 1.83 626,175 679,000 52,825 8.44% 4.53% 15 3020 N SPURWAY DR 2023-05-23 2026-07-28 3.18 845,000 800,000 -45,000 -5.33% -1.71% 16 3334 ROSEFORD BLVD 2024-05-17 2025-04-18 0.92 680,000 695,000 15,000 2.21% 2.40%
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The subject's July 2021 purchase price predates the material site changes in 2024 and therefore should not be relied upon without consideration of those subsequent changes. Based on our review of North Oaks, the subject property's rear building separation appears to be among the closest in the community. Typical wider separation between other condominium buildings within the community Versus Smaller trees were planted near the neighboring deck to provide screening. One tree died in 2025, and others have shown limited health due to space issue, according to comments received from the community's landscaping contractor. Unique Adverse Situation 5
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6 Proximity Penalty: High-Density Clustering Drives a ~11.8% Value Variance in Identical Models A 3 2 1 Visual Diagnostic: Property A occupies a premium, less-constrained corner lot with open rear exposure. Property 1 is tightly hemmed in by surrounding structures, creating a permanent impairment to privacy. Property Comparison Base Model (Premium Lot) Clustered Model (Proximity Penalty) Price Impact ($) Value Variance (%) A vs. 1 Property A Property 1 -$122,046 -11.80% 3277 Hayster Ln 3269 Hayster Ln $1,030,612 $908,566 1 A Property Address Sale Date Sale Price Model Floor Area # Bedroom # Full Bath # 1/2 Bath 3277 HAYSTER Dr 10/21/2024 $1,030,612Brandeis 2,620 4 4 1 3269 HAYSTER 10/09/2024 $908,566Brandeis 2,685 4 4 1 • Property 1 is currently listed on Zillow for sale and had a recent (09/10) price cut that brought the list price down to $865,000, over $43,000 lower than its purchase price. • It has been listed for 83 days already as of 09/25. • Property 3 is the subject property, back-to-back with property 2, which has the closest proximity in the entire community, only 10 ft apart.
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Petitioner’s Unit Value • Petitioner’s condo was purchased on July 22nd, 2021 at a price of $737,797. • Applying the −1.77% annual percentage change, applied over the time period of 3.45 years from July 2021 to December 31, 2024, valuation of the Petitioner’s condo purchased in July 2021 on December 31, 2024 is calculated as follows: 𝑽𝒂𝒍𝒖𝒆𝑀𝑎𝑟𝑘𝑒𝑡 𝑇𝑟𝑒𝑛𝑑= 737,797× 1 −0.0177 3.45 = 693,712 • Note1: there are 3.45 years between July 22nd, 2021, and December 31st, 2024. • Note2: the −1.77% annual price change is a purchase-price-weighted average of the repeat-sale observations. Weighting by purchase price gives equal weight to each dollar of transaction value rather than equal weight to each property. • Considering the proximity penalty observed in the adjacent neighborhood, given that the subject property (property 3) suffered from an even tighter proximity with property 2, applying the -11.8% penalty on the above value results in: 𝑽𝒂𝒍𝒖𝒆𝑇𝐶𝑉= 693,712× 1 −0.118 = 611,854 𝑽𝒂𝒍𝒖𝒆𝑆𝐸𝑉= 611,854 ÷ 2 = 305,927 7
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Comparables Sales Analysis Petitioner agrees that the Sales Comparison Approach is an appropriate method of valuation. The principal disagreement is whether Respondent’s selected comparable sales and adjustments adequately reflect the subject property’s model/floor plan, location characteristics, and unique proximity/privacy impairment as of December 31, 2024. 8 • Unit’s Features such as Model/floor plan and Lot Location Have a Material Impact on Market Value • Among Non-Brandeis 2024 sales, Non- premium lot properties averaged $244/SF, compared with $325/SF for Bandeis model and premium lots — approximately 25% in difference. • City’s assessments statistics also indicate a noticable discrapency between SEV/TCV/Market sales. Non-premium lots were assessed, on average, 18% above the 50% of actual sale price, compared with only 7% for Brandeis & premium lots. Source of condos were sold in the community in 2024 (exclusion of 2 model houses)
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Respondent’s Comparable Sale #1 — Adjustment Analysis • Comp #1 is similar to the subject in floor area (2,716 vs. 2,735 sq. ft.), but it differs in two important value characteristics: model/floor plan and lot location. • Comp #1 is a Brandeis model and has an Open Meadow lot, while the subject is a non-Brandeis model without a comparable premium lot feature. Community sales data presented in this petition indicate that model/floor plan and lot characteristics materially affect sale prices within North Oaks. (Please see the attachment) • This distinction is also evident in the original purchase prices. Comp #1 sold for $793,012 in September 2020, compared with $737,797 for the subject in July 2021, despite their similar features other than model/floor plan. • Importantly, Comp #1 resold for $765,000 in January 2024 — $28,012 (3.5%) below its September 2020 purchase price. This is a reflextion of the market trend. Therefore, its $765,000 sale should not be applied directly to the subject without appropriate adjustments for model/floor plan, lot characteristics, and the subject’s adverse proximity/privacy condition. • Complete price difference by unit features such as model plan and lot location is in attachment. 9 Comparables Sales Analysis
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Respondent’s Comparable Sale #2 — Adjustment Analysis • Comp #2 differs materially from the subject in gross living area (2,403 vs. 2,735 sq. ft.) and bathroom count, reducing its direct comparability. • Although both properties are Non-Brandeis models, Comp #2 has an Open Meadow lot, while the subject is situated on a non-premium lot. Community sales evidence presented in the attachments indicates that lot characteristics materially affect sale prices within North Oaks. • Comp #2 is located relatively close to the subject, making the contrast in site characteristics particularly relevant: Comp #2 benefits from an open meadow view, while the subject is affected by unusually close building proximity and reduced privacy/view. • Market evidence presented in the attachments indicates a meaningful value differential (20%) associated with open meadow premium versus non-premium lot characteristics. Accordingly, Comp #2’s favorable lot condition should be adjusted when applying its sale price to the subject. • Therefore, Comp #2’s $758,000 sale price should not be applied directly to the subject without appropriate adjustments for gross living area, bathroom count, lot characteristics, and the subject’s adverse proximity/privacy condition. • Respondent also recognizes the differences in gross living area and bathroom count, which further limits the weight that Comp #2 should receive as direct evidence of the subject’s value. • Complete price difference by unit features such as model plan and lot location is in attachment. 10 Comparables Sales Analysis
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Respondent’s Comparable Sale #2 — Adjustment Analysis • Comp #3 is reasonably similar to the subject in floor area (2,620 vs. 2,735 sq. ft.) and has the same bedroom/bathroom configuration, but differs in two important value characteristics: model/floor plan and lot location. • Comp #3 is a Brandeis model, while the subject is Non-Brandeis. Community sales evidence indicates meaningful price differences among models/floor plans; therefore, an appropriate model adjustment should be considered. • Comp #3 also benefits from a Back-to-Woods lot, while the subject is situated on a non-premium lot. The wooded setting provides greater separation, privacy, and view characteristics that the subject does not have. • These differences are particularly important because the subject has the opposite condition: unusually close building proximity and permanent loss of privacy/view. Thus, Comp #3 represents a superior location relative to the subject. • Comp #3 sold for $799,000 in April 2024. Its sale price therefore should not be a reference or applied directly to the subject without appropriate adjustments for model/floor plan, premium lot characteristics, and the subject’s adverse proximity/privacy condition. • Complete price difference by unit features such as model plan and lot location is in attachment. 11 Comparables Sales Analysis
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Key Findings • Respondent's three comparable sales provide relevant market evidence, but none is directly comparable to the subject without appropriate adjustments. • Comp #1 and Comp #3 are Brandeis models, while the subject is a Non-Brandeis model. Both also have superior lot/location characteristics. • Comp #2 is a Non-Brandeis model, but it is materially smaller and benefits from an open-meadow setting that the subject does not have. • None of the three comparables reflects the subject property's unusually close building proximity and permanent loss of privacy, screening, and open-space exposure. Conclusion • The Respondent's comparable sales should therefore be adjusted for the material differences in model/floor plan, size/features, lot/location, and the subject's unique proximity/privacy impairment before being used to estimate the subject property's True Cash Value. Notes: Petitioner appreciates Respondent's effort in identifying a list of North Oaks Sales in 2024 (Attached list). However, our review of the available 2024 North Oaks sales records indicates that certain sales and property characteristics require updating or clarification. 12 Comparable Sales Analysis — Conclusion
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Reconciliation & Requested Valuation • 2024 Community Market Evidence: A 6.01% adjustment from market trend analysis • Trend of the sales of the community (North Oaks Villa) 𝑽𝒂𝒍𝒖𝒆𝑀𝑎𝑟𝑘𝑒𝑡 𝑇𝑟𝑒𝑛𝑑= 737,797× 1 −0.0177 3.45 = 693,712 • Subject Property-Specific Adjustment: A 11.8 % property-specific adjustment is therefore used as a reasonable market-supported indication of the subject property's unique location disadvantage of Proximity and permanent Privacy Impairment 𝑽𝒂𝒍𝒖𝒆𝑇𝐶𝑉= 693,712× 1 −0.118 = 611,854 𝑽𝒂𝒍𝒖𝒆𝑆𝐸𝑉= 611,854 ÷ 2 = 305,927 • Combining facts generated from the complete data of North Oaks (Villa), in addition to the disadvantage of location, site, Permanent privacy/view loss, All produce indications approximately $611,854 SEV, with assessment value of $305,927. 13
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References and Acknowledgments • Data, maps and pictures used in this analysis are taken and/or from public ready resouce, including government website • Market and comparable-sales information was compiled with assistance and input from members of the North Oaks community and real estate professionals affiliated with Reinhart Realtors and Keller Williams. • Property characteristics, location, condition, model differences, and other relevant factors were considered in selecting and analyzing comparable sales. • Public property records, listing information, community information, photographs, maps, and other supporting materials are included or referenced where applicable. • The petitioners are responsible for the analysis, calculations, and conclusions presented in this appeal. 14
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Thank You! • We respectfully request that the Tribunal consider the actual 2024 market evidence together with the subject property's permanent and unique location disadvantages, including unusually close building proximity, loss of screening and privacy, and reduced open-space exposure. • We appreciate the City's September 16, 2026 site inspection and respectfully request that the observed site conditions be considered together with the comparable-sales evidence presented in this appeal. 15
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Attachment: Market Evidence Vs. City’s Assessment • Brandeis Model is significantly higher in total value (28%) and unit value (14%) for the same features and space • Overall, City Assessment value is 7-8% higher than market sales. Source of condos were sold in the community in 2024 (exclusion of 2 model townhouses) 16
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Attachment: 2024 Sales — Model (Brandeis Vs. Non-Brandeis) & Lot Locations (Premium Vs Non-Premium) • Lot Location Has a Material Impact on Market Value • Among Non-Brandeis 2024 sales, premium-lot properties averaged $308/SF, compared with $244/SF for non-premium lots — approximately 20% in difference of price per SF. • Differenciation of City’s assessments among the lot and models show less distinction. Non-premium lots were assessed, on average, 18% above 50% of actual sale price, compared with only 4% for premium lots. Source of condos were sold in the community in 2024 (exclusion of 2 model houses) 17
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• Lot Location Has a Material Impact on Market Value • Among Brandeis 2024 sales, Brandeis lot properties averaged $325/SF, while Non- Brandeis & Open Meadow lot is $303/SF • The City’s assessments is higher in general compare to the SEV/TMV Source of condos were sold in the community in 2024 (exclusion of 2 model houses) 18 Attachment: 2024 Sales (Cont’) — Model (Brandeis Vs. Non-Brandeis) & Lot Locations (Premium Vs Non-Premium)
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Attachment: The Brandeis Model’s Award-Winning Design Enhances Its Market Appeal Example: The Brandeis model commands a significantly higher price—approximately 20%—despite having comparable features and a similar exterior appearance. Source of condos sold in the North Oaks Villa community 19
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Attachment: Sample of Brandeis Model 20 Source: Noth Oaks condos sold in the North Oaks Villa community
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Attachment: Respondent’s List of 2024 Sales 21 Petitioner appreciates Respondent's effort in identifying a list of North Oaks Sales in 2024 (Attached list). However, our review of the available 2024 North Oaks sales records indicates that certain sales and property characteristics require updating or clarification. Note: Our review identified certain omissions and discrepancies in this list. For example, Property A (sold October 2024 for $1,030,612), used in the proximity analysis in this appeal, is not included. Several powder room/half- bath counts also appear to be inaccurate, among other discrepancies.