2025 Petition - Broadway - Uncapping.pdf

Broadway Detroit Development II LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002384-TT

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STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

BROADWAY DETROIT DEVELOPMENT II LLC,

Petitioner, 

vs. 

CITY OF DETROIT, 

Respondent. 

/

 

 

 

MTT Docket #25- 

Parcel No. 01004005. 

 

 

 

PETITION 

 

 

BROADWAY DETROIT DEVELOPMENT II LLC (“Petitioner”), through its 

attorneys, Law Office of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 1300 Broadway, Suite 600, 

Detroit, MI 48226. Petitioner is a party in interest with respect to property taxes 

on real property tax parcel nos. 01004005. ("Petitioner's Property"), at 1322 

Broadway, Detroit, MI, 48226. 

 

2. 

Respondent, City of Detroit assesses and collects property taxes on 

Petitioner's Property. 

 

3. 

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

Parcel # 01004005. to be $184,490 and assessed Petitioner's Property at $411,700 

resulting in a state equalized value of the same amount based on the tenative 

equalization factor.

4. 

At the March Board of Review, Respondent erroneosly uncapped 

Petitioner’s Taxable Value and Adjusted it up to $411,700. 

 

5. 

Th Notice giving rise to this change was dated May 17, 2025 and is 

attached hereto. This Notice is what Petiiton is timely and lawfully appealing 

from. 

 

6. 

Petitioner's Property is classified as Commercial Real Property. 

Petitioner's Property is commercial property. Petitioner believes that Petitioner's 

Property was designed to be used as a commercial 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 an erroneous uncapping. 

 

7. 

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 and operate as a fraud upon the 

taxpayer 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, are at higher percentages of true cash value than permissible 

under the Michigan Constitution and applicable statutes;

(c) 

The assessment, including taxable value and/or state 

equalized value, 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; 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 reducing and recapping the 2025 taxable value of Petitioner's Parcel # 

01004005. from $411,700 to $184,490, and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: June 12, 2025 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste 350 

 Birmingham, MI 48009 

 (248) 767-9840

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