Petition - Arbor Lofts Southfield.pdf
Civic Plaza Associates, LLC, Arbor Town II, LLC, & 20300 Civic Center Dr, LLC Petitioner Vs. City Of Southfield Respondent · 26-001279-TT
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Petition Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26- Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 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 Petitioners Entire Tribunal Property Tax Petition Petitioners Civic Plaza Associates, LLC, Arbor Town II, LLC and 20300 Civic Center Dr., LLC, by and through their attorneys, Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal Property Tax Petition. The Parties 1. Petitioners Civic Plaza Associates, LLC, Arbor Town II, LLC and 20300 Civic Center Dr., LLC (collectively, “Petitioners”) are Michigan limited liability companies with their registered office located at 480 Pierce St Ste 200, Birmingham,
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Petition Page 2 MI 48009. Petitioners are related entities that have the same principal ownership. 2. Respondent City of Southfield is a Michigan city with its primary offices located at 26000 Evergreen Road, Southfield, MI 48076. The Subject Properties 3. Petitioners own properties identified as follows: Parcel No. Street Address 76-24-22-276-020 20300 Civic Center Drive 76-CF-22-100-001 20300 Civic Center Drive 76-24-22-276-019 20300 Civic Center Drive 76-24-22-276-021 Civic Center Drive They are referred to collectively in this Petition as the “Subject Properties.” 4. The Subject Properties are located in Oakland County and are within the Southfield Public 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. 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.
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Petition Page 3 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.
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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 22, 2026 Attorneys for Petitioners
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Multiple Parcel Form Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26- Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 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 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 76-24-22-276-020 6,703,960 3,351,980 2,876,157 76-CF-22-100-001 473,940 236,970 169,685 76-24-22-276-019 337,600 168,800 164,678 76-24-22-276-021 208,340 104,170 44,540 Totals: 7,723,840 3,861,920 3,255,060
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Multiple Parcel Form Page 2 2. Petitioners contend that lawful 2026 assessments for the Subject Properties cannot exceed the following amounts: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020 4,340,000 2,170,000 2,170,000 76-CF-22-100-001 330,000 165,000 165,000 76-24-22-276-019 250,000 125,000 125,000 76-24-22-276-021 80,000 40,000 40,000 Totals: 5,000,000 2,500,000 2,500,000 3. The amounts in dispute for the 2026 tax year are therefore as follows: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020 2,363,960 1,181,980 706,157 76-CF-22-100-001 143,940 71,970 4,685 76-24-22-276-019 87,600 43,800 39,678 76-24-22-276-021 128,340 64,170 4,540 Totals: 2,723,840 1,361,920 755,060