Petition - Amended -POS.pdf
Bond At Novi LLC Petitioner Vs. City Of Novi Respondent · 26-001140-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Bond at Novi, LLC, Petitioner, vs. City of Novi, Respondent. MTT Docket No. 26-001140 _____________________________________________________________________________/ PROOF OF SERVICE (Amended Property Tax Petition) On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: City Assessor City of Novi 45175 W. Ten Mile Rd Novi, MI 48375 City Clerk City of Novi 45175 W. Ten Mile Rd Novi, MI 48375 On the date below I sent by first class mail a copy of the Petition to: Equalization Director Oakland County 250 Elizabeth Lake Rd, Ste 1000W Pontiac, MI 48341 County Clerk Oakland County 1200 N Telegraph Rd, Bldg 12E Pontiac, MI 48341 Secretary, Board of Education Novi Community School District 25345 Taft Rd Novi, MI 48374 State Treasurer Department of Treasury 430 W Allegan Street Lansing, MI 48922 I declare that the statements above are true to the best of my information, knowledge and belief. /s/ Laura M. Hallahan Dated: September 3, 2026
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS Bond at Novi LLC , Petitioner, v City of Novi, Respondent. MICHIGAN TAX TRIBUNAL Docket No. 26-001140 Parcel No.: 50-22-22-226-009, and additional parcels _____________________________________________________________________________/ AMENDED PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) This Amended Property Tax Petition is being filed as the Petition filed May 19, 2026, incorrectly identified the County as Livingston. The County of Oakland is correctly identified below. Furthermore the original petition incorrectly identified the School District as Brighton Area Schools. The School District is Novi Community Schools and is correctly identified below. Petitioner, by and through its attorneys, Hallahan & Associates, P.C., contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use 50-22-22-226-009 Bond Street 202 Comm Vacant 50-22-22-226-008 43443 Bond Street 202 Comm Vacant 2. ☒ N/A. If the assessment at issue was protested, the protest was made to Respondent’s: ☐ March, ☐ July, ☐ December Board of Review. 3. Respondent, identified above, assesses and collects taxes on the subject property. 4. The subject property is located in the County of Oakland and school district of Novi Community Schools. 5. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property.
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2 6. The Petitioner’s principal office/legal residence address is: 2502 Lake Lansing Road, Suite C, Lansing, MI 48912. 7. This appeal involves issues related to: ☒ the subject property’s true cash and taxable values ☐ the subject property’s taxable value only there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No ☐ uniformity of the subject property’s assessment ☐ the subject property’s exemption from ad valorem taxation under MCL ______ 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values are based upon an erroneous determination of the true cash value of that portion of Petitioner’s property that is taxable under Michigan law and are based upon the application of wrong principles; and d. The assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection and due process of law.
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3 Petitioner requests that the Tribunal enter an order reducing the 2026 values from those established by Respondent’s Board of Review to those contended by Petitioner, and order refunds attributable to the reductions, with interest, as provided by the Tax Tribunal Act. HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.com Dated: August 18, 2026 Filing Fee: $625
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4 ATTACHMENT TO PETITION (Subject Property) VALUES Respondent’s Board of Review -and- Petitioner’s Contention Parcel Number Respondent Petitioner TCV SEV TV TCV SEV TV 50-22-22-226-009 433,460 216,730 216,600 200,000 100,000 100,000 50-22-22-226-008 2,699,600 1,349,800 1,348,970 1,400,000 700,000 700,000 Totals 3,133,060 1,566,530 1,565,570 1,600,000 800,000 800,000 VALUES IN DISPUTE Parcel Number TCV SEV TV 50-22-22-226-009 233,460 116,730 116,600 50-22-22-226-008 1,299,600 649,800 648,970 Totals 1,533,060 766,530 765,570