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Petition to Tax Tribunal.pdf

Contour Acquisitions A Delaware Limited Liability Company Petitioner Vs. City Of Southfield Respondent · 26-001220-TT

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Page 1

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CONTOUR ACQUISITIONS, a 

Delaware limited liability company 

 

Petitioner 

 

 

 

 

M.T.T. Docket 

V. 

 

 

 

 

 

 

 

No. 26-________ 

 

CITY OF SOUTHFIELD, a 

Michigan public body corporate, 

 

Respondent 

 

_______________________________________________________________________/ 

 

PETITION 

 

PETITIONER, by its attorneys, Kerr, Russell & Weber, PLC, hereby petitions the 

entire tribunal against the above-named Respondent, and states as follows: 

1. 

Petitioner is a duly organized and existing Delaware limited liability company 

with its principal office located at 40950 Woodward Avenue, Suite 300, Bloomfield 

Hills, MI 48304. 

2. 

Respondent is a Michigan public body corporate. 

3. 

The parcels of land at issue are contiguous parcels of commercial real estate 

improved with 4 office buildings (collectively, the “Property”), more particularly 

described as: 

Parcel No. 

Address 

Approximate Square Footage 

76-24-36-477-002 

15565 Northland Drive 

111,600 Square Feet 

76-24-36-477-003 

15530 Northland Drive 

113,625 Square Feet 

76-24-36-477-004 

20905 Greenfield Road 

63,220 Square Feet 

76-24-36-477-005 

20755 Greenfield Road 

140,778 Square Feet

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Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

4. 

The Property is classified as commercial and is located in Oakland County and the 

Oak Park Public School District. 

5. 

Because the Property is classified as commercial real estate, appeal directly to the 

Tax Tribunal is authorized by Act 174 of Public Acts of 2006. Nonetheless, Petitioner 

appeared before Respondent’s Board of Review on March 5, 2026 to protest the 

Property’s assessed and taxable values. 

6. 

The values of the Property as established by the Respondent's Board of Review 

following Petitioner’s appeal to the Board of Review are: 

Tax Year 

Parcel Nos. 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

76-24-36-477-002 

$1,291,160.00 

$645,580.00 

$645,580.00 

2026 

76-24-36-477-003 

$1,268,300.00 

$634,150.00 

$634,150.00 

2026 

76-24-36-477-004 

$2,257,780.00 

$1,128,890.00 

$1,128,890.00 

2026 

76-24-36-477-005 

$1,533,760.00 

$766,880.00 

$766,880.00 

Totals 

 

$6,351,000.00 

$3,175,500.00 

$3,175,500.00 

 

7. 

Petitioner acquired the Property from the prior owner, Northland Towers 

Associates Limited Partnership, in an arms-length transaction on December 17, 2025, for 

the full consideration of $3,400,000.00. As part of normal closing prorations, Petitioner 

reimbursed Northland Towers Associates for a portion of the December 2024 tax bill and 

the July 2025 tax bill and is responsible for payment of all tax bills rendered by the taxing 

authorities thereafter. 

8. 

In preparation for redevelopment of the Property and possible application for 

incentives under the Brownfield Redevelopment Financing Act, Act 381 of 1996, 

Petitioner obtained an Obsolescence Study of the Property prepared by Matthew J. 

Schmidt, a Michigan Master Assessing Officer (4). Mr Schmidt concluded that the

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Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

Property is functionally obsolete and subject to significant impairment of functional 

capacity due to: 

a. 

the buildings are subject to substantial deferred maintenance; 

b. 

elevators in the building are old, several are inoperable, and replacement 

parts are no longer being manufactured for the units; 

 

c. 

the elevator sizes are not compliant with the Americans with Disabilities 

Act. Any renovation of the buildings would require increasing the size and 

configuration of the elevator shafts to accommodate ADA compliant 

elevators; 

 

d. 

the existing heating and cooling systems are between 50 and 60 years old 

and need to be replaced. The manufacturers no longer maintain a 

replacement parts inventory. Repairs will require salvaging parts from 

other inoperable units; 

 

e. 

bathroom doors are not ADA compliant; 

f. 

the roofs require complete recovering and structural repairs to prevent 

water leaks in the upper floors of the building; and 

 

g. 

these deficiencies make it difficult to attract tenants and is a reason that 

occupancy is only between 30% and 40%. 

 

9. 

Respondent's 2026 real property assessment and taxable value fail to take into 

consideration the following: 

a. 

The age of the subject Property; 

 

b. 

existing and projected vacancies and the length of existing vacancies; 

 

c. 

projected costs of leasehold improvements that will have to be expended in 

order to attract new tenants to the Property; 

 

d. 

the lack of current income generated by subject Property; 

 

e. 

deferred maintenance items; 

 

f. 

existing market and mortgage conditions;

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Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

g. 

overall physical, economic and functional obsolescence factors; 

 

h. 

increased costs in maintaining and operating subject Property; 

 

i. 

proper depreciation factors; 

 

j. 

the marketing and sales history of this Property and sales of comparable 

properties; and 

 

k. 

adequate reserves for replacement; 

 

and, therefore, said assessment and taxable values are in excess of fifty (50%) percent of 

the true cash value of the Property on December 31, 2025, contrary to Article 9, Section 

3, of the Michigan Constitution and MCL §211.27. 

10. 

Based upon the foregoing, the Petition contends that the values of the Property 

identified above should not exceed: 

Tax Year 

Parcel Nos. 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

76-24-36-477-002 

$691,220.00 

$345,610.00 

$345,610.00 

2026 

76-24-36-477-003 

$678,980.00 

$339,490.00 

$339,490.00 

2026 

76-24-36-477-004 

$1,208,700.00 

$604,350.00 

$604,350.00 

2026 

76-24-36-477-005 

$821,100.00 

$410,550.00 

$410,550.00 

 

11. 

The total state equalized value amount in controversy is, therefore, Four Million 

Six Hundred Fifty-One Thousand and 00/100 ($4,651,000) Dollars. 

WHEREFORE, Petitioner requests that Respondent be ordered to: (i) reduce the 

2026 Original Assessed and State Equalized Values on the Property detailed in the chart 

below to the Revised Assessed and State Equalized Values detailed in the chart below, 

(ii) reduce the 2026 Original Taxable Value on the Property detailed in chart below to the 

Revised Taxable Value detailed in the chart below; and (iii) that Petitioner be refunded 

any and all real estate taxes that it may be required to pay to Respondent based upon any

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Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

assessment, state equalized value and taxable value on the Property for tax year 2026 in 

excess of Revised Assessed, State Equalized and Revised Taxable Values on the 

Property, plus interest on said taxes from the date of payment to the date of refund, 

together with whatever costs Petitioners may herein incur. 

Tax 

Year 

Parcel Nos. 

Original Assessed 

and State Equalized 

Values 

Original Taxable 

Values 

Revised Assessed 

and State 

Equalized Values 

Revised 

Taxable 

Values 

2026 

76-24-36-477-002 

$645,580.00 

$645,580.00 

$345,610.00 

$345,610.00 

2026 

76-24-36-477-003 

$634,150.00 

$634,150.00 

$339,490.00 

$339,490.00 

2026 

76-24-36-477-004 

$1,128,890.00 

$1,128,890.00 

$604,350.00 

$604,350.00 

2026 

76-24-36-477-005 

$766,880.00 

$766,880.00 

$410,550.00 

$410,550.00 

 

Dated: May 21, 2026 

 

Kerr, Russell, & Weber, PLC 

 

 

By: 

/s/ C. David Bargamian 

 

 

C. David Bargamian (P43742) 

Attorneys for Petitioner 

500 Woodward Avenue, Suite 2500 

Detroit, MI 48226 

(313) 961-0200

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