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Petition 2025 - BSR 14 (Broder) Royal Oak.pdf

Bsr 14 Mile LLC, Petitioner Vs. City Of Royal Oak, Respondent · 25-002018-TT

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Page 1

25-0029 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BSR 14 Mile LLC, 

Petitioner, 

v. 

City of Royal Oak, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 72-20-32-351-001 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

Petition 

BSR 14 Mile LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 3663 Woodward Avenue, Suite 550, Detroit, 

MI 48201. Petitioner is a party in interest with respect to property taxes on tax parcel number 72-

20-32-351-001 ("Petitioner's Property"), with an address of 3200 W. 14 Mile Rd., Royal Oak, 

located in Oakland County, Michigan. 

2.

Respondent, City of Royal Oak, assesses and collects property taxes on Petitioner's 

Property.

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60718759.1 

3.

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$1,590,850 and assessed Petitioner's Property at $1,590,850, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4.

Petitioner's Property is classified as industrial improved. At all times relevant to 

this case, Petitioner's Property had a building that was not occupied and was not in good condition. 

Petitioner believes that Petitioner's Property was originally designed to be used for industrial 

purposes. 

5.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

6.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7.

No board of review protest was required for Petitioner’s Property. 

8.

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 

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; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan 

Constitution and applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion

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60718759.1 

of Petitioner's Property that is taxable under Michigan law, and is based 

upon the application of wrong principles; and, 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 assessed value, state-equalized value, and taxable value of Petitioner's Property from 

$1,590,850 to $1,250,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 30, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

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