Petition HCOC4 2025 (01991356x7AF06).pdf
Haggerty Corridor Office Centre IV LLC, Petitioner Vs. City Of Novi, Respondent · 25-001859-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL HAGGERTY CORRIDOR OFFICE CENTRE IV, LLC, Docket No. 25- Petitioner, Parcel No. 50-22-12-400-060 v. CITY OF NOVI, 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 Haggerty Corridor Office Centre IV, 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 Haggerty Corridor Office Centre IV, LLC, is a Michigan limited liability company with its principal place of business in Michigan located at 39000 Country Club Drive, Farmington Hills, Michigan 48331. 2. Respondent the City of Novi is a Michigan city with its principal offices located at 45175 W. 10 Mile Rd, Novi, Michigan 48375.
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2 The Subject Property 3. Petitioner owns property identified as Parcel No. 50-22-12-400-060 and commonly known as 28175 Cabot Drive, Novi, Michigan 48377 (the “Subject Property”). 4. The Subject Property is located in Oakland County and is within the Novi Community School District, the Oakland County Community College District, and the Oakland Intermediate School District. 5. The Subject Property was designed for, and is presently used for, office purposes, though it suffers from significant office vacancy. The 2025 Assessment 6. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. 7. For the 2025 tax year, Respondent classified the Subject Property as commercial real property. 8. For the 2025 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value $4,144,720 $2,072,360 $2,058,430 A copy of the Subject Property’s Notice of Assessment is attached to this Petition as Exhibit A. 9. Petitioner contends that a lawful assessment of the Subject Property for the 2025 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value $3,200,000 $1,600,000 $1,600,000
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3 10. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value $944,720 $472,360 $458,430 11. This Petition presents issues involving the Subject Property’s valuation for property tax assessment purposes. Petitioner does not believe that this Petition presents any issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues involving losses should information supporting such issues become available. 12. The Subject Property’s 2025 assessment (a) violates the Michigan Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 13. Petitioner does not assert that the Subject Property’s 2025 assessment is not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Property’s values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Property’s 2025 assessment to be consistent with the values set forth in Paragraph 9 of this Petition and granting Petitioner all other
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4 relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Jason C. Long Jerome P. Pesick (P29039) Jason C. Long (P59244) Dated: May 30, 2025 Attorneys for Petitioner
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Exhibit A
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L-4400 Michigan Department of Treasury 1019 Rov. 1024) THIS IS NOT ATAX BILL Notice of Assessment, Taxable Valuation, and Property Classification Thie for ssed dor the aur of Pubic Act 208 of 1853, Sec. 211.24c and Sec21134c, 3 amended. This I 8 model assesment nofice 0 bo used by 1 ca 3569532" FROM: PARCEL IDENTIFICATION City of Nov) Assessing Dept PARCEL CODE NUMBER: 50-22-12-400-060 Novi, MI 48375 PROPERTY ADDRESS: 28175 CABOT DR TO: 0015377 me FET HRI 036*001*15377****SCH 5-DIGIT PRINCIPAL RESIDENCE EXEMPTION HAGGERTY CORRIDOR OFFICE CENTRE IV 9% Exempt As “Homeowners Principal Residence": 0.00% 39000 COUNTRY CLUB DR w . 200% FARMINGTON HILLS Mi 48331-3453 % Exempt As “Qualified Agricultural Property” - % Exempt As “MBT industrial Personal”: 0.00% % Exempt As “MBT Commercial Personal” 0.00% Exempt As “Qualified Forest property”:|_| Yes x No Exempt As “Development Property”: O Yes x] No Legal Description: TIN, REE, SEC 12 OAKLAND COUNTY CONDOMINIUM PLAN NO 1679 HAGGERTY CORRIDOR CORPORATE PARK CONDOMINIUM-PHASE 1 UNIT 41 34421 P 115 11-24-04 FR O50 ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 201 COMMERCIAL-IMPROVED CURRENT CHANGE FROM PRIOR AMOUNT | TENTATIVE AMOUNT PRIOR YEAR TO YEAR: 2024 YEAR: 2025 CURRENT YEAR 1,996,540 2,058,430 61,890 2. ASSESSED VALUE: 1,996,540 2,072,360 75,820 3. TENTATIVE EQUALIZATION FACTOR: 1.000 4. STATE EQUALIZED VALUE (SEV): 1,096,540 | 2,072,360 | 75,820 5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: Was Not 5. ASSESSOR CHANGE REASON:Market Adjustment The 2025 Inflation Rate Multiplier is: 1.031 Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the following: Name Telephone Number Email Address Janeene Ziozios (248) 347-0485 noviassessing@cityofnovi.org March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: Tuesday, March 04,2025 9:00 am. (Organizational Meeting only, Valuation Appeals begin March 10) Monday, March 10, 2025 9:00 a.m. to 6:00 pm. Tuesday, March 11,2025 1:00 p.m. to 9:00 pm. Wednesday, March 12,2025 9:00 am. to 6:00 pm. Contact the