Petition - POS.pdf
Ferndale Avenue Shoppes Petitioner Vs. City Of Ferndale Respondent · 26-001387-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Ferndale Avenue Shoppes, Petitioner, vs. City of Ferndale, Respondent. MTT Docket No. 26-001387 _____________________________________________________________________________/ PROOF OF SERVICE (Property Tax Petition) On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: City Assessor City of Ferndale 300 E Nine Mile Rd Ferndale, MI 48220 City Clerk City of Ferndale 300 E Nine Mile Rd Ferndale, MI 48220 On the date below I sent by first class mail a copy of the Petition to: Equalization Director Oakland County 250 Elizabeth Lake Rd, Ste 1000W Pontiac, MI 48341 County Clerk Oakland County 1200 N Telegraph Rd, Bldg 12E Pontiac, MI 48341 Secretary, Board of Education Ferndale Schools 871 Pinecrest Ferndale, MI 48220 State Treasurer Department of Treasury 430 W. Allegan Street Lansing, MI 48922 I declare that the statements above are true to the best of my information, knowledge and belief. /s/ Laura M. Hallahan Dated: September 17, 2026
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS Ferndale Avenue Shoppes, Petitioner, v City of Ferndale, Respondent. MICHIGAN TAX TRIBUNAL Docket No. 26-001387______ Parcel No.: 24-25-27-352-027, and additional parcels _____________________________________________________________________________/ PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use 24-25-27-352-027 23157 Woodward Ave. 201-Commercial Retail 24-25-27-352-025 168 W. Cambourne St.. 202-Commercial Retail 24-25-27-352-007 23235 Woodward Ave. 201-Commercial Retail 24-25-27-352-008 23235 Woodward Ave. 201-Commercial Retail 24-25-27-352-024 158 W. Cambourne St.. 202-Commercial Retail 2. ☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: ☐March, ☐ July, ☐ December Board of Review. 3. Respondent, identified above, assesses and collects taxes on the subject property. 4. The subject property is located in the County of Oakland and school district of Ferndale School District. 5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. 6. The Petitioner’s principal office/legal residence address is: 4036 Telegraph Rd. Suite 201, Bloomfield Hills, MI 48302.
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2 7. This appeal involves issues related to: ☒ the subject property’s true cash and taxable values ☐ the subject property’s taxable value only there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No ☐ uniformity of the subject property’s assessment ☐ the subject property’s exemption from ad valorem taxation under MCL ______ 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values are based upon an erroneous determination of the true cash value of that portion of Petitioner’s property that is taxable under Michigan law and are based upon the application of wrong principles; d. The assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection and due process of law; and e. The taxable value of parcels 24-25-27-352-025 and 24-25-27-352-007 were unlawfully uncapped.
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3 Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable to the reductions, with interest, as provided by the Tax Tribunal Act. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.com Dated: May 25, 2026 Filing Fee: $700
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4 ATTACHMENT TO PETITION (Subject Property) VALUES Respondent’s Board of Review -and- Petitioner’s Contention Parcel Number Respondent Petitioner TCV SEV TV TCV SEV TV 24-25-27-352-027 3,589,420 1,794,710 1,145,570 1,600,000 800,000 800,000 24-25-27-352-025 94,520 47,260 47,260 40,000 20,000 20,000 24-25-27-352-007 120,520 60,260 60,260 50,000 25,000 25,000 24-25-27-352-008 69,500 34,750 18,230 30,000 15,000 15,000 24-25-27-352-024 81,640 40,820 20,280 30,000 15,000 15,000 Totals 3,955,600 1,977,800 1,291,600 1,750,000 875,000 875,000 VALUES IN DISPUTE Parcel Number TCV SEV TV 24-25-27-352-027 1,989,420 994,710 345,570 24-25-27-352-025 54,520 27,260 27,260 24-25-27-352-007 70,520 35,260 35,260 24-25-27-352-008 39,500 19,750 3,230 24-25-27-352-024 51,640 25,820 5,280 Totals 2,205,600 1,102,800 416,600