Petition - Moceri Bloomfield Hills (Dittrich).pdf
Moceri/Dm Investments, LLC Petitioner Vs. City Of Bloomfield Hills Respondent · 26-001625-TT
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Petition Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Moceri/DM Investments, LLC, Docket No. 26- Parcel Nos. 12-19-14-152-005 Petitioner, 12-19-14-152-007 v. City of Bloomfield Hills, Respondent. Jerome P. Pesick (P29039) Richard E Rassel, III (P57540) 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 Moceri/DM Investments, LLC, by and through their attorneys, Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal Property Tax Petition. The Parties 1. Petitioner Moceri/DM Investments, LLC, is a Michigan limited liability company with its registered office located at 3005 University Dr, Auburn Hills, MI 48326.
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Petition Page 2 2. Respondent City of Bloomfield Hills is a Michigan city with its primary offices located at 45 E Long Lake Road, Bloomfield Hills, MI 48304. The Subject Properties 3. Petitioner owns properties identified as follows: Parcel No. Property Address 12-19-14-152-005 39515 Woodward Ave 12-19-14-152-007 39515 Woodward Ave They are referred to collectively in this Petition as the “Subject Properties.” 4. The Subject Properties are located in Oakland County and are within the Bloomfield Hills school district. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Properties. The 2026 Assessments 6. For the 2026 tax year, Respondent classified the Subject Properties as commercial real property. 7. For the 2026 tax year, Respondent established the Subject Properties’ assessments for property taxes in the amounts set forth in paragraph 1 of the attached Multiple Parcel Form. 8. Petitioner contends that lawful assessments of the Subject Properties for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the attached Multiple Parcel Form. 9. The amounts in dispute therefore equal the amounts identified in paragraph 3 of the attached Multiple Parcel Form.
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Petition Page 3 10. This Petition presents issues involving the Subject Properties’ valuation for 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 reserve its right to assert issues involving losses should information supporting such issues become available. 11. The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are based on the misapplication of valuation principles, and (d) otherwise violate Petitioner’s rights. 12. Petitioner does not assert that the Subject Properties’ 2026 assessments are not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Properties’ values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed Petitioner’s contentions of value set forth in paragraph 2 of the attached Multiple Parcel Form 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 Petitioners
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Multiple Parcel Form Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Moceri/DM Investments, LLC, Docket No. 26- Parcel Nos. 12-19-14-152-005 Petitioner, 12-19-14-152-007 v. City of Bloomfield Hills, Respondent. Jerome P. Pesick (P29039) Richard E Rassel, III (P57540) 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 Petition Multiple Parcel Form 1. The values established for the Subject Properties by Respondent’s March 2026 Board of Review are as follows: Parcel No. True Cash Value Assessed Value Taxable Value 12-19-14-152-005 1,333,260 666,630 664,410 12-19-14-152-007 326,020 163,010 163,010 Totals: 1,659,280 829,640 827,420 2. Petitioner contends that lawful 2026 assessments for the Subject Properties cannot exceed the following amounts:
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Multiple Parcel Form Page 2 Parcel No. True Cash Value Assessed Value Taxable Value 12-19-14-152-005 640,000 320,000 320,000 12-19-14-152-007 160,000 80,000 80,000 Totals: 800,000 400,000 400,000 3. The amounts in dispute for the 2026 tax year are therefore as follows: Parcel No. True Cash Value Assessed Value Taxable Value 12-19-14-152-005 693,260 346,630 344,410 12-19-14-152-007 166,020 83,010 83,010 Totals: 859,280 429,640 427,420