PETITION FINAL w. EXHIBITS.pdf

John Ziraldo, Monica Ziraldo Petitioners Vs. City Of Detroit Respondent · 26-001565-TT

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v

STATE OF MICHIGAN

GRETCHEN WHITMER

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARLON I. BROWN, DPA

GOVERNOR

DIRECTOR

LANSING

_____________________________,

MICHIGAN TAX TRIBUNAL

Petitioner(s)

MTT Docket No.

_____________________________,

Respondent(s)

ENTIRE TRIBUNAL PROPERTY TAX PETITION

1.

Property Parcel No: _____________________________________________

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition

Form addressing all other parcels at issue.)

2.

The property identified above is ___real ___personal.

3.

If more than one parcel of real property is under appeal, are the properties

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.)

4.

Are all of the parcels of personal property located on a parcel of real property

under appeal? ___Yes ___No. (If no, separate Petitions are required for each

parcel of personal property not located on a parcel of real property under

appeal.)

5.

If parcels of personal property are under appeal, when were the personal

property statements filed by parcel number (attach additional page if necessary):

6.

The property identified above is classified as _________________________

7.

If the assessment or assessments at issue were protested, the protest was made

to Respondent’s ___ March ___ July ___December Board of Review.

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

John Ziraldo and Monica Ziraldo

City of Detroit

06000002.050 and 06000002.053

XX

XX

N/A

RESIDENTIAL CONDOMINIUM

XX

MTT Docket No. _________________

Page 2 of 4

8.

If a protest was required and no protest was made, list the separate and specific

facts upon which Petitioner relies to invoke the Tribunal’s authority over the

assessment or assessments at issue (attach additional page if necessary):

9.

If the appeal was not submitted by the deadline for the filing of an appeal for the

classification or classifications of the properties at issue (i.e., May 31 or July 31

of the tax year involved), list the separate and specific facts upon which

Petitioner relies to invoke the Tribunal’s authority over the assessment or

assessments at issue (attach additional page if necessary):

10.

The property or properties at issue are located in _______________County. The

property or properties’ address is:

11.

The assessment or assessments at issue were established by the (applicable

local governmental unit): ________________________________________

12.

Petitioner’s legal residence or principal office address is:

13.

This appeal involves issues relating to the (check all that are applicable):

________the property or properties’ true cash and taxable values

________the property or properties’ taxable value only

If the property or properties’ taxable value is at issue, is there a

dispute as to the value of an addition or loss? ___ Yes ___No

________uniformity of the property or properties’ assessment

________the property or the properties’ exemption from ad valorem taxation

under MCL ______

14.

The tax year(s) at issue are: _______________________________________

A formal protest was made to the City od Detroit Board of Review. See

attached.

N/A

WAYNE

1001 W JEFFERSON 300/6A

1001 W JEFFERSON 300/6D

CITY OF DETROIT ASSESSOR'S OFFICE

300 RIVERFRONT DRIVE, UNIT 6A

DETROIT, MI 48226

XXX

2026

MTT Docket No. _________________

Page 3 of 4

15.

If more than the current tax year is being appealed, list the separate and specific

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior

tax year or years (attach additional page if necessary):

16.

The values for the property identified above as established by Respondent’s

Board of Review are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

17.

Petitioner contends that the values for the property identified above are:

Tax Year

True Cash Value

State Equalized Value

Taxable Value

18.

The values in dispute for the property identified above are:

Tax Year

True Cash Value

State Equalized Value

Taxable Value

19.

Petitioner requests the following relief (attach additional page if necessary):

20.

List the separate and specific facts upon which Petitioner relies to support the

relief requested (attach additional page if necessary):

N/A

2026

173500

173500

133690

2026

105900

105900

95137

2026

8000

8000

4350

2026

7700

7700

4094

2026

8000

8000

4350

2026

7700

7700

4094

That the Tribunal find that there was no uncapping event as required by MCL 211.27a

and restore each property's taxable value to the properly capped amount that would

have applied absent any independent transfer-of-ownership event.

SEE ATTACHED.

MTT Docket No. 

Page 4 of 4 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

rd 

Printed Name 

titioner’s 

orized Representative or, if none, Petitioner: 

hoo ph A 

Fetrson 

Email Address: 

Mailing Address: 

38505 Woodward Ave., Suite 100 

Bloomfield Hills, MI 48304 

Telephone Number: (248) 433-7158 

Date: 5/26/2026

v

STATE OF MICHIGAN

GRETCHEN WHITMER

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARLON I. BROWN, DPA

GOVERNOR

DIRECTOR

LANSING

______________________,

MICHIGAN TAX TRIBUNAL

Petitioner,

MTT Docket No. ___________

______________________,

Respondent.

MULTIPLE PARCEL PETITION FORM ___ OF ___

1. The classification of the property identified herein as established by

Respondent’s Board of Review is:

Tax Year

Parcel Number

Real/Personal

Classification

2. The values for the property identified herein as established by Respondent’s

Board of Review are:

Tax Year

Parcel Number

True Cash Value

Assessed Value

Taxable Value

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

John Ziraldo and Monica Ziraldo

City of Detroit

1

1

2026

06000002.050

Real

RESIDENTIAL CONDOMINIUM

2026

06000002.053

Real

RESIDENTIAL CONDOMINIUM

2026

06000002.050

173500

173500

133690

2026

06000002.053

105900

105900

95137

MTT Docket No._____________

Page 2 of 2

3. Petitioner contends that the values for the property identified herein are:

Tax Year

Parcel Number

True Cash Value

State Equalized Value

Taxable Value

4. The values in dispute for the property identified herein are:

Tax Year

Parcel Number

True Cash Value

State Equalized Value

Taxable Value

2026

06000002.050

8000

8000

4350

2026

06000002.053

7700

7700

4094

2026

06000002.050

8000

8000

4350

2026

06000002.053

7700

7700

4094

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

JOHN ZIRALDO AND MONICA ZIRALDO, 

 

Petitioner, 

 

 

 

 

 

 

 

 

MTT Docket No. ____________ 

v. 

 

CITY OF DETROIT, 

 

Respondent. 

 

SUPPLEMENT TO PETITION 

Petitioners, John Ziraldo and Monica Ziraldo, by and through their attorneys, Plunkett 

Cooney, hereby supplement their Petition and state as follows: 

1. 

Petitioners are the owners of real property commonly identified as 1001 W 

Jefferson Bldg. 300 Unit 6A and Unit 6D, located in a condominium development in the City of 

Detroit, Wayne County, Michigan. Petitioners have continuously owned both units since 2016. 

The two condominium units have been physically combined and function as Petitioners’ single 

principal residence. 

2. 

Both Unit 6A and Unit 6D were subject to Neighborhood Enterprise Zone 

Homestead (NEZ-H) certificates issued under the Neighborhood Enterprise Zone Act, MCL 

207.771 et seq. Under the NEZ-H certificates, the “house” portion of each unit received an 

abatement, while the land portion remained on the regular ad valorem tax roll. The NEZ-H 

certificates for both units expired at the end of 2025. 

3. 

On the 2026 assessment roll, the City of Detroit treated the expiration of the NEZ-

H certificates as an uncapping event and dramatically increased the taxable values of both units. 

Specifically, the taxable value of Unit 6A increased from approximately $4,200 in 2025 to 

approximately $133,000 in 2026 - an increase of more than 3,000%. The taxable value of Unit 

6D increased from approximately $4,000 in 2025 to approximately $95,000 in 2026 - an increase 

of more than 2,200%. These increases far exceed the constitutionally mandated cap on annual 

taxable value increases.

4. 

The City’s uncapping of taxable values was improper and contrary to law. Under 

Article IX, Section 3 of the Michigan Constitution and MCL 211.27a, a property’s taxable value 

may not increase by more than the lesser of 5% or the rate of inflation (the Consumer Price 

Index) from year to year, unless there has been a “transfer of ownership” as defined by MCL 

211.27a(6). A “transfer of ownership” is defined as the conveyance of title to or a present interest 

in property, including the beneficial use of the property, the value of which is substantially equal 

to the value of the fee interest. 

5. 

The expiration of an NEZ-H certificate does not constitute a “transfer of 

ownership” under MCL 211.27a. No conveyance of title occurred. No present interest in the 

property was transferred. Petitioners owned the subject properties before the NEZ-H certificates 

expired and continue to own them after expiration. The same owners hold identical title and 

beneficial use of the property. The expiration of a tax abatement certificate is not listed among 

the statutory uncapping triggers in MCL 211.27a. See also Klooster v City of Charlevoix, 488 

Mich 289 (2010) (strictly construing transfer-of-ownership provisions). 

6. 

The correct taxable values for 2026 should be calculated by applying the inflation 

rate multiplier (3.1% for 2026) to the 2025 capped taxable values. Accordingly, the correct 2026 

taxable value for Unit 6A is approximately $4,350 (i.e., $4,200 × 1.031), and the correct 2026 

taxable value for Unit 6D is approximately $4,094 (i.e., $4,000 × 1.031). 

7. 

In March 2026, Petitioners appeared before the City of Detroit Board of Review 

and requested correction of the improperly uncapped taxable values for both Unit 6A and Unit 

6D. The Board of Review denied relief for both properties. This Supplement supports 

Petitioners’ appeal to the Michigan Tax Tribunal. 

8. 

Petitioners respectfully request that the Michigan Tax Tribunal enter an order 

providing the following relief: 

a. 

Holding that the expiration of the NEZ-H certificates did not constitute a 

“transfer of ownership” under MCL 211.27a and did not authorize uncapping of the 

taxable values of Unit 6A or Unit 6D;

b. 

Reversing the Board of Review’s determinations for the tax years under 

appeal; 

(J 

Restoring the taxable values of Unit 6A and Unit 6D to their properly 

capped amounts (approximately $4,350 and $4,100, respectively); 

d. 

Ordering the City of Detroit to correct its assessment records and issue 

corrected tax bills and/or refunds of any overpayments, together with statutory interest 

thereon; and 

Bi 

Awarding Petitioners their costs and attorney fees as authorized by law. 

Respectfully submitted, 

PLUNKETT COONEY 

By: Sa A Blass 

/ 

/ oseph A. Peterson 

Dated: 5/27/2026

_________________________________________

_________________________________________

___________________________

______________________________________

STATE OF MICHIGAN

GRETCHEN WHITMER

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARLON I. BROWN, DPA

GOVERNOR

LANSING

DIRECTOR

_____________________________,

Petitioner(s)

MICHIGAN TAX TRIBUNAL

v

MTT Docket No.

_____________________________,

Respondent(s)

APPEARANCE

Please type or neatly print the name and contact information for the attorney or authorized

representative:

1. Full name (first, middle initial, last)

2. Bar License # (if applicable)

P

3. Firm Name (if applicable)

3. Address

4. Telephone No.

5. E-mail Address

1. I appear on behalf of ___________________________________________________ as

attorney or

authorized representative.

Attorney/Representative signature

[Print/type name of person signing]

I certify that on this date I served a copy of this appearance on the opposing party or their

representative.

Date

Signature

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

John Ziraldo and Monica Ziraldo

City of Detroit

Joseph A. Peterson

(248) 433-7158

jpeterson@plunkettcooney.com

Constellation Cat Cafe

Joseph A. Peterson

Plunkett Cooney

38505 Woodward Ave., Suite 100

Bloomfield Hills, MI 48304

77999799987998667799

Good morning, and thank you for your time today. 

My name is John Ziraldo, and my wife and I are the owners and occupants of two condominium 

units, Units 6A and 6D, which we have owned continuously since 2016. These units are 

physically combined and function as our single residence. 

We are here today because the 2026 taxable values for both parcels appear to have been 

improperly uncapped. 

To give you a sense of the magnitude: 

●​ For Unit 6A, the taxable value increased from about $4,200 in 2025 to approximately 

$133,000 in 2026.​

 

●​ For Unit 6D, it increased from about $4,000 to approximately $95,000. 

These are increases of more than twenty times the prior year values. 

We understand that our Neighborhood Enterprise Zone, or NEZ, certificate expired at the 

end of 2025, and we expected that our property taxes would increase as a result. 

However, under Michigan’s Proposal A and MCL 211.27a, taxable value may only increase by 

the lesser of 5% or the rate of inflation unless there has been a transfer of ownership. 

There has been no transfer of ownership of either unit since we purchased them in 2016. 

Our understanding is that expiration of an NEZ certificate does not constitute a transfer of 

ownership and therefore does not permit the taxable value to be uncapped. 

Based on that, the 2026 taxable values should be calculated by applying the inflation 

multiplier—approximately 3.1%—to the 2025 taxable values. 

That would result in taxable values of roughly: 

●​ $4,350 for Unit 6A​

 

●​ $4,100 for Unit 6D​

 

We are not here to dispute market value or assessed value. We are only asking that the taxable 

values be calculated in accordance with the capped value rules required by law. 

So respectfully, we are asking the Board to correct what appears to be an improper uncapping 

and to adjust the 2026 taxable values accordingly. 

Thank you again for your time and consideration.

E 

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Coleman A. Young Municipal Center 

oF Review 

2 Woodward Avenue, Suite 105 

Detroit, Michigan 48226 

Phone: (313) 628-0722 

Fax: (313) 224-4576 

SETROIT | 

> 

www detroitmi.gov 

04/06/2026 

HN & MONICA 

RALDO, JO 

500 RIVERFRONT DR., STE 6A 

ROIT MI 48226 

© 2026 

MARCH BOARD OF REVIEW PETITION NUMBER: 

M-003319 

March Board of Review has considered the appeal on the 2026 assessment for the below described property 

4 

concluded that: 

0 

06000002.050 

4. 

Parcel Number: 

1001 W JEFFERSON 300/6A 

2. Property Address: 

3. 

District: 

6 

{ 

k. Property Classification: 

407 

(RESIDENTIAL CONDOMINIUMS 

Ad Valorem 

6. 

Principle Residence Exemption: 

5. Property Legal Description: 

EEO 

Rory Larosa. £62 LEDS, Wr OE 

ren cert | 

| 

6. “Petitioner timely filed an appeal to the March Board of Review. 

The March Board of Review considered 

(if any) petitioner's and/or duly au 

and/or testimony. The March Board of Review considered facts presented as 0 

recommendations offered by the Office of the Assessor. 

SION: 

= Board of Revi 

thorized representative evidence 

n the assessment roll and/or any 

ew has considered the appeal filed and found there was no adjustment warranted. 

a 

Before Appeal 

After Appeal 

2026 

Assessed Value 

173,500 

173,500 

133,690 

133,690 

2026 

Taxable Value 

you are dissatisfied with the decision of the March Board of Rev 

all claims form to appeal to: 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing 

MI 48909 

igan Tax Tribunal appeal must be 

ercial 

Real, 

Industrial 

Real, Comm 

e made by July 31st of the cu 

iew, submit this notice and complete the enclosed 

for properties classified 

as: 

st 

of the current year 

d 

Utility 

Personal 

Property. 

made 

by May 

31 

Industrial 

Personal 

an 

ercial 

Personal, 

rrent year for Residential Real Property 

igan Tax Tribunal appeal must b 

ification. 

with the 

0 

: 

pe filed 

operty 

Classification appeal may 

only 

be made for the current year. Such appeal may 

i 

AH 

MI 48909-7971 

by June 30th 

of the current year. 

e Tax Commission, PO Box 30471, Lansing, 

De roit Board of Review 

3

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 105 

bio (EEL ge 

Fax: (313) 224-4576 

= 

ioF Review 

Detrolt, Michigan 48226 

www. detroitmi.gov 

04/06/2026 

0, JOHN & MONICA 

VERFRONT DR., STE 6A 

ROIT MI 48226 

MARCH BOARD OF REVIEW PETITION NUMBER: 

M-003331 

2026 

has considered the appeal on the 2026 assessment for the below described property 

March Board of Review 

concluded that: 

INC 

06000002.053 

. 

Parcel Number: 

property Address: 

1001 W JEFFERSON 300/6D 

3. District: 

6 

207 

(RESIDENTIAL CONDOMINIUMS 

Ad Valorem 

4. 

Property Classification: 

Principle Residence Exemption: 

. Property Legal Description: 

S JEFFERSON W UNIT 53 APT 300-60 WAYNE COUNTY CONDOMINIUM SUB PLAN NO 813 "RIVERFRONT TOWERS 

CONDOMINIUM” MASTER DEED RECORDED L41783 P152-262 DEEDS, WCR 06/207 690.35 SF 0.2535% NEZ REHAB p— 

Petitioner timely filed an appeal to the March Board of Review. 

The March Board of Review considered 

(if any) petitioner's and/or duly authorized representative evidence 

and/or testimony. The March Board of Review considered facts presented as on the assessment roll and/or any 

recommendations offered by the Office of the Assessor. 

AS 

ON: 

= Board of Review has Considered the appeal filed and found there was no adjustment warranted. 

ol 

Before Appeal 

After Appeal 

2026 

Assessed Value 

105,900 

105,900 

95,137 

95,137 

2026 

Taxable Value 

are dissatisfied with the decision of the March Board of Review, submit this notice and complete the enclosed 

Michigan Tax Tribunal 

P.O. Box 30232 

\ 

Lansing MI 48909 

\ 

gan Tax Tribunal appeal must be made by May 31st of the current year for properties classified o 

rcial 

Real, 

Industrial 

Real, 

Commercial 

Personal, 

Industrial 

Personal 

and 

Utility Personal Property. 

gan Tax Tribunal appeal must be made by July 31st of the current year for Residential Real Property 

tion. 

de for the current year. Such appeal may be filed with the 

Classificati 

be 

m 

en, MI 48909-7971 

by June 30th 

of the current year. 

Commission, PO Box 30471, Lansing,

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