Petition - Kaftan Uptown 11 (01991345x7AF06).pdf
Uptown 11 Townhouses LLC, Petitioner Vs. City Of Southfield, Respondent · 25-001853-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Uptown 11 Townhouses LLC, Docket No. 25- Petitioner, Parcel No. 76-24-19-100-002 v. City of Southfield, 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 Uptown 11 Townhouses, 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 Uptown 11 Townhouses, LLC is a Michigan limited liability company with its principal place of business in Michigan located at 29100 Northwestern Highway, Suite 260, Southfield, MI 48034. 2. Respondent City of Southfield is a Michigan city with its principal offices
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located at 26000 Evergreen Road, Southfield, MI 48076. The Subject Property 3. Petitioner owns property identified as Parcel No. 76-24-19-100-002 and commonly known as 26565 E Stanford Drive, Southfield, MI 48033 (the “Subject Property”). 4. The Subject Property is located in Oakland County and is within the Southfield Public School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2025 Assessment 6. For the 2025 tax year, Respondent classified the Subject Property as commercial real property. 7. For the 2025 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value 10,553,340 5,276,670 5,117,677 8. Petitioner contends that a lawful assessment of the Subject Property for the 2025 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value 8,500,000 4,250,000 4,250,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value 2,053,340 1,026,670 867,677
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10. This Petition presents issues involving the Subject Property’s 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 reserves its rights to assert issues involving losses should information supporting such issues become available. 11. The Subject Property’s 2025 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 2025 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 2025 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 30, 2025 Attorneys for Petitioner