Rebbutal to Respondents Answer 10:14:26.pdf
David Jonathan Siik Petitioner V Township Of Negaunee Respondent · 26-002351-TT
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Petitioners' Rebuttal to Respondent's Answer Oct 15, 2026 Docket No.26-002351-TT. David Siik v. Negaunee Township · Parcel 52-10-460-031-00 (101 Nardi Dr) Summary The statements in the answer are not consistent with, and in several places directly contradict, the very property records and sales study filed with it: 1. My sale: The property record card codes my purchase "03-ARM'S LENGTH." The price was set by a certified, independent third party, fair market appraisal with no preferential price amount ever discussed or arranged. It was handled independently by a bank trust. 2. Land: An included property referenced by respondent includes better and larger water frontage but is charged about half my rate per foot. 3. The $850,000+ sales: The sales study shows those prices came mainly from their newer, premium houses, not the land. 1. My Sale Was Arm's Length, according to the Property Record Card The property record card shows my purchase as $349,000 on 08/08/2024, coded "03-ARM'S LENGTH," verified by deed. Statement in the answer The facts "Family sale" I am not related to the seller. "Distressed sale" No foreclosure, bank repossession or short sale. It was a standard right of first refusal handled by a bank trustee. The answer itself states the property was not abandoned. Not on the open market; "far below market value" The price was set by a third party, independent fair market appraisal required by the bank trustee (included in prior evidence). Without preference, sale price was entirely based on certified independent Fair Market Value. • Half the sales in the same study sold for $275,000 to $450,000. My price fits that range. Yet my sale does not appear among them, though it is newer than every sale listed. 2. My Land Is Charged About Double the Rate of a Better Waterfront Property 101 Nardi Dr (mine) 273 N Basin Dr Water frontage 472 ft 616 ft
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101 Nardi Dr (mine) 273 N Basin Dr Shoreline Two springs, erosion, swampy sections Pristine beach and boat landing included Land value $429,300 $247,468 Rate per front foot $750 (frontage only) $402 at most (all land included) • Both are in the same neighborhood (0404). The longer, better frontage is charged about half my rate. • Acreage does not explain it. 83% of my land value ($354,300) comes from the frontage rate (stated on card). My extra 5 acres are valued separately at $75,000. • My card also applies 100% of the frontage rate, with no reduction for the springs, erosion or unusable swampy areas. See shoreline photographs, Exhibit A (attached). • At 273 N Basin's rate, my land would be about $264,900, not $429,300. 3. The $850,000+ Referenced Sales Came from the Houses, Not the Land Property Sale price Land value Land as % of price 113 Nardi Dr $975,000 $188,723 19% 125 Lake Breeze Ln $960,000 $123,600 13% 273 N Basin Dr $950,000 $247,468 26% 233 N Basin Dr $855,000 $166,328 19% 101 Nardi Dr (mine) $349,000 $429,300 123% • According to the sales study, 74% to 87% of those prices were for the houses. They do not support a high value for my land. • In those sales, land was 13% to 26% of the price. My land value is 123% of my purchase price, more than the entire property sold for. What I Am Asking For 1. Give weight to my $349,000 purchase, set by certified independent appraisal and coded arm's length on the property record card. 2. Reduce my land true cash value from $429,300 to about $264,900. 3. Reduce my assessed and taxable values based on this evidence and prior evidence.
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Exhibit A: Shoreline Photographs These photographs support Section 2. Photos A-1 to A-3 show the Petitioners' shoreline at 101 Nardi Dr. Photos A-4 to A-6 show the comparison property, 273 N Basin Dr. 101 Nardi Dr (Petitioners' property): 472 ft of frontage, charged $750 per foot Photos A-1 to A-3 taken by Petitioners on October 14, 2026. Photo A-1 (10/14/2026). Spring water channel running across the property to the shoreline. Photo A-2 (10/14/2026). Spring channel cutting through the soil toward the water. Photo A-3 (10/14/2026). Spring water eroding channels across the beach at the water's edge. Two natural springs run across this shoreline year- round, eroding the beach and leaving sections swampy and partly unusable. The property record card applies 100% of the frontage rate, with no reduction for these conditions.
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Exhibit A (continued) 273 N Basin Dr (comparison property): 616 ft of frontage, $402 per foot at most Photo A-4. Wide, clean sandy beach with a boat launch at the water's edge. Photo A-5. Gravel drive to the beach and dock. Photo A-6. Maintained lawn along the fenced waterfront. Source of Photos A-4 to A-6: public UPMLS listing photographs of 273 N Basin Dr. These are the most recent publicly available photographs of this shoreline.