Petition - BRE Nixon A2.pdf
Bre Nixon Road Associates, LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001611-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL BRE Nixon Road Associates, LLC, Docket No. 26- Petitioner, Parcel No. 09-09-10-401-002 v. City of Ann Arbor, 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 BRE Nixon Road Associates, 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 BRE Nixon Road Associates, LLC is a Michigan limited liability company with its principal place of business located in Michigan at 300 Eagle Pond Drive, 154, Walled Lake, MI 48390. 2. Respondent City of Ann Arbor is a Michigan city with its principal offices
Page 2
located at 301 E. Huron St., Ann Arbor, MI 48104. The Subject Property 3. Petitioner owns property identified as Parcel No. 09-09-10-401-002 and commonly known as 3380 Nixon Road, Ann Arbor, MI 48105 (the “Subject Property”). 4. The Subject Property is located in Washtenaw County and is within the Ann Arbor Public School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2026 Assessment 6. For the 2026 tax year, Respondent classified the Subject Property as commercial real property. 7. For the 2026 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value 64,889,800 32,444,900 19,892,833 8. Petitioner contends that a lawful assessment of the Subject Property for the 2026 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value 34,000,000 17,000,000 17,000,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value 30,889,800 15,444,900 2,892,833 10. This Petition presents issues involving the Subject Property’s valuation for assessment purposes. Petitioner does not believe that this Petition presents any
Page 3
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. 11. The Subject Property’s 2026 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. 12. Petitioner does not assert that the Subject Property’s 2026 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 2026 assessment to be consistent with the values set forth in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Jerome P. Pesick Jerome P. Pesick (P29039) Dated: May 27, 2026 Attorneys for Petitioner