25-002950.pdf

Lake Forest Trail Holdings LLC, Petitioner Vs. Township Of Green Oak, Respondent · 25-002950-TT

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RECEIVED 

0CT 24 2025 

MICHIG 

STATE OF MICHIGAN 

AN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Docket No. 25-008. 50 

Petitioner, 

Parcel No. 4716-03-105-028 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

880 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Entire Tribunal Property Tax Petition 

Petitioner Lake Forest Trail Holdings, 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 Lake Forest Trail Holdings, LLC, 

is 

a Michigan limited 

liability company, with its registered offices located at 801 W. Big Beaver Road, Suite

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 4716-03-105-028 and 

commonly known 

as 11395 Izik's Way, Brighton, Michigan 48116 (the “Subject 

Property”). 

4, 

The Subject Property is located in Livingston County and is within the 

Brighton Area School District. 

5. 

The Subject Property was designed for and is used for multi-family 

housing purposes. 

6. 

Respondent possesses jurisdiction to assess and collect property taxes for 

the Subject Property. 

The 2024 and 2025 Property Tax Assessments 

7. 

For tax years 2024 and 2025, Respondent classified the Subject Property 

as commercial real property. 

8. 

For tax years 2024 and 2025, Respondent initially established the 

Subject Property's assessment in the following amounts: 

Year 

TCV 

AV 

TV 

2024 

1,403,000 

701,500 

605,893 

2025 

5,472,400 

| 

2,736,200 

2,464,830 

9. 

On June 30, 2025, Respondent uncapped the Subject Property's 2024 

taxable value to equal its 2024 assessed value on the basis that the Subject Property

Year 

TCV 

AV 

TV 

2024 

1,403,000 

701,500 

701,500 

20256 

5,472,400 

2,736,200 

2,663,401 

10. 

This Petition presents issues involving whether the Subject Property 

experienced a “transfer of ownership” as the General Property Tax Act, MCL 211.1 et 

seq. (the “GPTA”), defines that term. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as 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 tax year 2024 and 2025 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 Petitioners rights. 

Count I: Erroneous Uncapping 

12. 

For tax year 2024, Respondent uncapped the Subject Property's taxable 

value to equal its 2024 assessed value, then carried that uncapping forward to tax 

year 2025 (Notice of Uncapping attached as Exhibit A). 

13. 

The Subject Property did not experience a transaction that qualifies as a 

“transfer of ownership” during calendar year 2023 as that term is defined in the 

GPTA.

for tax years 2024 and 2025, as provided under Const 1963, art 9, § 3, the GPTA, and 

other law. 

15. 

Respondent's uncapping of the Subject Property’s taxable value for tax 

year 2024, which was then carried to tax year 2025, is therefore an error. 

16. 

The amount of taxable value in dispute based on Respondent’s erroneous 

increase in the Subject Property's taxable value for tax years 2024 and 2025 are as 

follows: 

Year | TV in Dispute 

2024 

95,607 

2025 

98,571 

Count IT: Overestimation of Value 

17. 

Alternatively, 

Petitioner contends that 

a lawful assessment 

of the 

Subject Property for tax years 2024 and 2025 cannot exceed the following amounts:! 

Year 

TCV 

AV 

TV 

2024 

780,000 

390,000 

390,000 

20251 

2,000,000 

1,000,000 

1,000,000 

18. 

The amounts in dispute based on Respondent's overestimation of value 

for the Subject Property for tax years 2024 and 2025 are therefore as follows: 

Year 

TCV 

AV 

TV 

2024 

623,000 

311,500 

311,600 

2025 | 

3,472,400 

1,736,200 

1,663,401

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property's 2024 and 2025 assessment to limit the 

increase in the Subject Property's taxable value as set forth in §14, or alternatively 

revising the assessment to be consistent with the values set forth in §17, and granting 

Petitioner all other relief to which it is entitled under Michigan law. 

Respectfully Submitted, 

WILLIAMS WILLIAMS RATTNER 

& PLUNKETT, PC 

By: /o/ Jevome 

P. Pesick 

Jerome P. Pesick (| 

Dated: July 30, 2025 

Attorneys for Petitioner

Exhibit A

EN OAK CHARTER TOWgy;p 

G 

71 SILVER LAKE ROAD, BRIGHTON, Mi 4g) 

wn uote: 810-231-1333 + FAX 810-231 

50 

is 

June 30, 2025 

Lake Forest Trail Holdings, LLC 

1700 W Big Beaver Rd, Suite 120 

Troy, MI 48084-3523 

RE: Parcels 4716-03-105-028 

2024 Taxable Value Uncapping 

2025 Taxable Value Revised for Uncapping 

This letter is being sent in accordance with the authority identified in Section 27b of the General Property 

Tax Act (P.A. 206 of 1893, as amended). A correction has been made in the Taxable Value of the subject 

real property parcel for the 2024 and 2025 tax years. These changes are due to failure on the part of the 

transferee (grantee) to timely 

file the Property Transfer Affidavit (form L-4260), along with other 

requested documents. 

On September 25, 2024, 

| sent you an email regarding a deed 

i received from the Register of Deeds 

recorded under document number 2023R-016657. See enclosed email and recorded deed. 

(n this email 

| requested a copy of your Schedule-C tax filing and immediately received a response from you by phone 

to discuss this matter. 

After that conversation 

| expected to receive your Schedule-C document, along 

with operating statements and a Property Transfer Affidavit, form L-4260. While 

| received a copy of your 

operating statements, 

| have not received the Property Transfer Affidavit or Schedule-C filing requested. 

Therefore, according to the statute your property is being uncapped. See enclosed form 3214, Assessor 

Affidavit Regarding “Uncapping” of Taxable Value for the 2024 and 2025 tax years for the correction of 

the taxable value. 

You may appeal this decision to the Michigan Tax Tribunal (MTT) within 35 days of receiving this notice of 

the increase in the Property's taxable value. Please contact the MTT at https://www.michigan.gov/taxtrib 

or by calling 517-335-9760 for further guidance. 

If 

| can be of assistance, please email me directly at christina.yaeger@greenoaktwp.com. 

Regards, 

Che shio\| 

x

Michigan Department of Treasury 

3214 (Rev, 8-08) 

Assessor Affidavit Regarding "Uncapping” of Taxable Value 

The changes in Taxable Value recorded on this affidavit are related to the "Uncapping” of Taxable Value due to a failure on the part of the 

transferee (buyer) to timely file the Property Transfer Affidavit (form L-4260). 

In accordance with the authority identified in Section 27b of the General Property Tax Act (P.A. 206 of 1893, as amended), a correction 

has been made in the Taxable Value of the following described Real/Personal property: 

4716-03-105-028 

{Parcel Identification Number) 

located in the City of/ Township of/Village of 

Green Oak Township 

County 

Livingston 

’ 

. 

This is a correction to the 

2024 pAssessment/Tax Roll. 

{Tax Year) 

Correction of Taxable Value Due to Transfer of Ownership 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL | 

School Code 

47010 

- 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

State Equalized Valuation 

. 

701,500 

Taxable Valuation 

605893 

Correction of Taxing Unit Levy 

Taxing Unit 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

County 

Intermediate School District 

Community College 

State Education Tax 

Loca! School Operating 

Local Schoo! Supplemental (<=18) 

Local School Supplemental (>=18) 

Local Schoo! Enhancement 

Local School Debt 

City/Township/Village 

Other 

Total 

“ 

NOTE: The levy section of this affidavit does not include collections fees, penalties, and interest. These must be added to the bill, when applicable, by the treasurer. 

| 

Christina Yaeger 

the above information is true, to the best of my knowledge. 

being the certified assessor for the City/Twp of 

Green Oak Township 

, do hereby swear or affirm that 

Ne. wT Certified Assessor 

hes oN Na 

Date 

Ore 

=o 2025 

Certification -L3 

Copies to: Property Owner, Equalization Department, County Treasurer, and the Treasurers of all other affected Taxing Units.

Michigan Department of Treasu: 

3214 (Rev. 8-09) 

id 

Assessor Affidavit Regarding 

The changes in Taxable Value recorded on this affidavit are related to the 

"Uncapping’ 

transferee (buyer) to timely file the Property Transfer Affidavit (form L-4260). 

In accordance with the authority identified in Section 27b of the General Property 

* of Taxable Value 

has been made in the Taxable Value of the following described Real/Personal property. 

4716-03-105-028 

{Parcel Identification Number) 

located in the City of Township offVillage of 

"Uncapping" of Taxable Value due to a failure on the part of the 

Green Ozk Township 

County 

Livingston 

’ 

Tax Act (P.A. 208 of 1893, as amended), a correction 

. 

This is a correction to the 

2025 Assessment/Tax Roll. 

(Tax Year) 

Correction of Taxable Value Due to Transfer of Ownership 

School Code 

27010 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

State Equalized Valuation 

2,736,200 

Taxable Valuation 

2,464,830 

98,571 

2,563,401 

Correction of Taxi ng Unit Levy 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

Taxing Unit 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

County 

Intermediate School District 

Community College 

State Education Tax 

Local School Operating 

Local School Supplemental (<=18) 

Local School Supplemental (>=18) 

Local School Enhancement 

Local School Debt 

City/Township/Village 

Other 

Total 

NOTE: The levy section of this affidavit does not include collections fees, penalties, and interest. These 

L 

Christina Yaeger 

the above information is true, to the best of my knowledge. 

, being the certified assessor for the City/Twp of 

must be added to the bill, when applicable, by the treasurer. 

Green Oak Township 

, do hereby swear or affirm that 

Signatur 

No. 

f Certified Assessor 

Ede anal 

Date 

Qe 20 2025 

Certification 

A-aal¥ 

Copies to: Property Owner] Equalidation Departm ent, County Treasurer, and the Treasurers of all other affected Taxing Units.

Yaeger, Christina 

From: 

Yaeger, Christina 

Sent: 

Wednesday, September 25, 2024 12:53 PM 

To: 

Michael Furnari 

Subject: 

Lake Forest Trails Name Change 

Hi Michael, 

| reviewed the documents you submitted for your tribunal case and noticed you changed the name of the 

ownership 3/20/2023. 

| found a deed 2023R-016657 dated 9/6/2023 transferring from JMF Properties, LLC to Lake 

Forest Trail Holdings, LLC. 

| need a copy of your schedule-C showing the relationship between these two 

entities. This request is not part of the tribunal case, and the requested information should be directed back to 

me. 

Please let me know if you have any questions. 

Thank you, 

Christina 

Christina L Yaeger, MAAO(3), MCPPE 

Township Assessor 

Assessing Dept, Green Oak Township 

10001 Silver Lake Rd 

Brighton, M! 48116 

810-231-1333 x105 

christina.yaeger@greenoaktwp.com 

www, greenoakiwp.com

2023R-016657 

RECORDED ON 

09/07/2023 08:30:29 AM 

BRANDON DENBY 

REGISTER OF DEEDS 

LIVINGSTON COUNTY, MI 48843 

RECORDING: 26.00 

REMON: 4.00 

PAGES: 5 

QUITCLAIM DEED 

TRANSFER 

~~ TAX EXEMPT 

207.505(a) and 207.526(a) 

Tax No. 

For One and 00/100 Dollar ($1.00), JMF Properties, LLC, 

a Michigan limited liability 

company (the “Grantor™), whose address is 30140 Orchard Lake Road, Farmington Hills, 

MI 48334, does hereby Remise, Release and Quitclaim to Lake Forest Trail Holdings, LLC 

a Michigan limited lability company (the “Grantee”), whose address is 1700 West Big 

Beaver Road, Sute 120, Troy, MI 48084, all its interest in and to the following described real 

property in the township of Green Oak, County of Livingston, State of Michigan: 

Parcel 1; 

Commencing at the Northwest corner of Section 3, Town 

1 North, Range 6 East, 

Green Oak Township, Livingston County, Michigan, thence South 01 degrees 56 

minutes 49 seconds West, 150.73 feet along the West line of said Section 3 (as 

monumented); thence South 80 degrees 27 minutes 46 seconds East, 574.87 feet 

along the North line (and its extension) of "SUPERVISOR'S PLAT OF 

RICHARD'S SUBDIVISION", as recorded in Liber 3 of Plats, Page 30, Livingston 

County Records to the Northeast corner of said Subdivision; thence North 13 

degrees 01 minutes 58 seconds East, 50.75 feet along the East line of said 

Subdivision extended Northerly to the centerline of Grand River Avenue; thence 

the following 2 courses along the centerline of Grand River Avenue; Easterly 

286.43 feet along the arc of a 28,647.90 foot radius curve to the left, through a 

central angle of 00 degrees 34 minutes 22 seconds and having a chord bearing of 

South 81 degrees 20 minutes 40 seconds East, 286.43 feet and South 81 degrees 37

thence South 08 degrees 35 minutes 38 seconds West, 58.14 feet; thence South 11 

degrees 33 minutes 36 seconds West, 29.99 feet; thence North 78 degrees 26 

minutes 24 seconds West, 20.26 feet; thence South 

11 degrees 31 minutes 03 

seconds West, 44.56 feet; thence South 78 degrees 26 minutes 24 seconds East, 

20.23 feet; thence South 11 degrees 33 minutes 36 seconds West, 16.60 feet; thence 

35.28 feet along the arc of a 43.02 foot radius curve to the right, through a central 

angle of 46 degrees 59 minutes 36 seconds and having a chord bearing South 38 

degrees 19 minutes 12 seconds West, 34.30 feet; thence 134.60 feet along the arc of 

a 51.25 foot radius curve to the left, through a central angle of 150 degrees 28 

minutes 22 seconds and having a chord beating South 09 degrees 40 minutes 41 

seconds East, 99.12 feet; thence South 40 degrees 13 minutes 07 seconds West, 

81.37 feet; thence South 22 degrees 45 minutes 11 seconds East, 472.33 feet; 

thence North 84 degrees 59 minutes 49 seconds West, 242.29 feet; thence North 18 

degrees 17 minutes 46 seconds West, 240,92 feet; thence North 71 degrees 42 

minutes 14 seconds East, 24.00 feet; thence North 18 degrees 17 minutes 46 seconds 

West, 259.06 feet; thence North 10 degrees 35 minutes 51 seconds East, 181.71 

feet; thence North 04 degrees 15 minutes 11 seconds East, 286.37 feet; thence South 

81 degrees 37 minutes 53 seconds East, 181.23 feet to the point of beginning. 

The ABOVE PARCEL was combined from the legal description below, which 

was formerly known as: 

Units 1,2,3,4,5,6,7,8,9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 

23, 24, 25, and 26 of LAKE FOREST TRAILS II, a Condominium according 

to the Master Deed recorded in Instrument No.2021R-023473, Livingston 

County 

Records, 

and 

designated 

as 

Livingston 

County 

Condominium 

Subdivision Plan No. 442, as amended, together with rights in the general 

common elements and the limited common elements as shown on the Master Deed 

and as described in Act 59 of the Public Acts of 1978, as amended. 

Parcel 2: 

Perpetual, non-exclusive access easement reserved in First Amendment to the

Commonly known as: Izik’s Way and Langfeld Spur, Brighton, MI 48116 

Parcel 1.D.: 

4716-03-105-028 which is part of the original parent parcel numbers: 

4716-03-105-001, 4716-03-105-002, 4716-03-105-003, 4716-03-105-004, 4716-03-105-005, 

4716-03-105-006, 4716-03-105-007, 4716-03-105-008, 4716-03-105-009, 4716-03-105-010, 

4716-03-105-011, 4716-03-105-012, 4716-03-105-013, 4716-03-105-014, 4716-03-105-015, 

4716-03-105-016, 4716-03-105-017, 4716-03-105-018, 4716-03-105-019, 4716-03-105-020, 

4716-03-105-021, 4716-03-105-022, 4716-03-105-023, 4716-03-105-024, 4716-03-105-025, 

4716-03-105-026, and 4716-03-105-027. 

Date: September 6, 2023 

GRANTOR: 

JMF 

Properties, 

LLC, 

a 

Michigan 

limited 

liability company 

MICHAEL S. FURNARI LIVING TRUST 

Dated October 7,2021 

Byy — 

A 

Michael S, Furnari 

It’s: Trustee 

CAROLINA 

FURNARI LIVING TRUST 

Dated 

Qcto 

2021 

\ 

By: 

(Lan 

Carolina Furnart_ 

It’s: Trustee 

[Notary signature on following page]

STATE OF MICHIGAN 

) 

\ 

COUNTY 

OF MANY, 

) 

Os 

doas ls dh peloe me, a Notary Public in and for said State, personally appeared 

MICHAEL S. FURNARI, Trustee of MICHAEL S. FURNARI LIVING TRUST, and CAROLINA 

FURNARI, Trustee, of CAROLINA FURNARI LIVING TRUST, Members on behalf of JMF 

PROPERTIES LLC (or proved to me on the basis of satisfactory evidence) to be the persons whose 

names are subscribed to the within instrument and acknowledged to me that they executed the 

same in their authorized capacities, and that by their signatures on the instrument, the persons, or 

the entity upon behalf of which the persons acted, executed the instrument. 

Witness my hand and official seal. 

Notary 

Public 

County, Michigan 

Acting in 

County 

My commission expires 

MELISSA SPRANGER 

Notary Public, Genesee County, MI 

My Commission Expires 

07) 

20 

Acting in the county ETN

RECEIVED 

OCT 24 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Lake Forest Trail Holdings LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 25-002950 

Township Of Green Oak, 

Respondent. 

NOTICE OF DOCKET NUMBER 

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case. 

Under TTR 235(1), “[t}he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default. 

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal's rules. 

By: __ Tribunal Clerk 

Entered: August 19, 2025 

PROOF OF SERVICE 

| certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing

UNITED STATES 

B 

POSTAL SERVICE 

Dear Postal Customer, 

The enclosed was found loose in the mail and/or was damaged in handling by the 

United States Postal Service. 

Due to our large daily volume of mail, we have automated most of our mail processing 

operations, and occasionally, damage will occur and/or an item will become loose in 

the mail. 

Your mail is very important to us. You have every right to expect it to be delivered 

intact and in good condition. We make every effort to properly handle the mail 

entrusted to us. We are constantly striving to improve our processing methods and 

maintenance to minimize such occurrences. 

We appreciate your business and sincerely regret any inconvenience you may have 

experienced. 

Sincerely, 

United States Postal Service

= UNITED STATES 

POSTAL SERVICE 

MICHIGAN METROPLEX P&DC 

711 N. GLENWOOD AVE. 

PONTIAC MI 48340-9997

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