Petition - Urbcam Michigan.pdf
Urbcam Michigan, LLC & Urbcam Dearborn, LLC Petitioner Vs. City Of Dearborn Respondent · 26-000999-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
Petition Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Urbcam Michigan, LLC, and Docket No. 26- Urbcam Dearborn, LLC, Parcel Nos. 82-09-143-01-022 82-43-143-01-023 Petitioners, 82-09-143-01-023 82-42-143-01-023 v. 82-09-143-01-024 City of Dearborn, 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 Petitioners Entire Tribunal Property Tax Petition Petitioner Urbcam Michigan, LLC and Urbcam Dearborn, 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 Urbcam Michigan, LLC, is a Michigan limited liability company with its registered office located at 209 Norcliff Drive, Bloomfield Hills, Michigan 48302. Petitioner Urbcam Dearborn, LLC is a Michigan limited liability company with its principal place of business in Michigan located at 209 Norcliff Drive,
Page 2
Petition Page 2 Bloomfield Hills, Michigan 48302. Urbcam Michigan, LLC and Urbcam Dearborn, LLC (collectively, “Petitioners”) are related entities that have the same principal ownership. 2. Respondent City of Dearborn is a Michigan city with its primary offices located at 16901 Michigan Avenue, Dearborn, Michigan 48126. The Subject Properties 3. Petitioners own properties identified as follows: Parcel No. Address 82-09-143-01-022 780 Town Center Dr 82-43-143-01-023 780 Town Center Dr 82-09-143-01-023 760 Town Center Dr 82-42-143-01-023 760 Town Center Dr 82-09-143-01-024 740 Town Center Dr They are referred to collectively in this Petition as the “Subject Properties.” 4. The Subject Properties are located in Wayne County and are within the Dearborn City 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.
Page 3
Petition Page 3 8. Petitioners contend 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. 10. This Petition presents issues involving the Subject Properties’ valuation for assessment purposes. Petitioners do 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 their 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 Petitioners’ rights. 12. Petitioners do 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, Petitioners respectfully request that this honorable Tribunal enter judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed Petitioners’ contentions of value set forth in paragraph 2 of the attached Multiple Parcel Form and granting Petitioners all other relief to which they are entitled under Michigan law.
Page 4
Petition Page 4 Respectfully Submitted, WILLIAMS WILLIAMS RATTNER & PLUNKETT PC By: /s/ Jerome P. Pesick Jerome P. Pesick (P29039) Jason C. Long (P59244) Dated: May 15, 2026 Attorneys for Petitioners
Page 5
Multiple Parcel Form Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Urbcam Michigan, LLC, and Docket No. 26- Urbcam Dearborn, LLC, Parcel Nos. 82-09-143-01-022 82-43-143-01-023 Petitioners, 82-09-143-01-023 82-42-143-01-023 v. 82-09-143-01-024 City of Dearborn, 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 Petitioners 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 82-09-143-01-022 29,026,800 14,513,400 14,053,904 82-43-143-01-023 10,653,400 5,326,700 2,739,964 82-09-143-01-023 1,060,600 530,300 441,445 82-42-143-01-023 821,800 410,900 325,000 82-09-143-01-024 624,400 312,200 231,859 Totals: 42,187,000 21,093,500 17,792,172
Page 6
Multiple Parcel Form Page 2 2. Petitioners contend that lawful 2026 assessments for the Subject Properties cannot exceed the following amounts: Parcel No. TCV AV TV 82-09-143-01-022 17,900,000 8,950,000 8,950,000 82-43-143-01-023 5,000,000 2,500,000 2,500,000 82-09-143-01-023 650,000 325,000 325,000 82-42-143-01-023 500,000 250,000 250,000 82-09-143-01-024 350,000 175,000 175,000 Totals: 24,400,000 12,200,000 12,200,000 3. The amounts in dispute for the 2026 tax year are therefore as follows: Parcel No. TCV AV TV 82-09-143-01-022 11,126,800 5,563,400 5,103,904 82-43-143-01-023 5,653,400 2,826,700 239,964 82-09-143-01-023 410,600 205,300 116,445 82-42-143-01-023 321,800 160,900 75,000 82-09-143-01-024 274,400 137,200 56,859 Totals: 17,787,000 8,893,500 5,592,172