Petition 2026 - Napior Leasing (RP) Adrian.pdf
Napior Leasing, LLC Petitioner Vs. City Of Adrian Respondent · 26-000636-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
25-0028 75204532.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Napior Leasing, LLC, Petitioner, v City of Adrian, Respondent. MTT Docket No. ____________ Parcel No. XA0-109-1150-02 Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7270 jcook@honigman.com Entire Tribunal Property Tax Petition Petitioner, Napior Leasing, LLC, by and through its attorneys, Honigman LLP, for its Petition against Respondent, City of Adrian, states as follows: 1. Petitioner, Napior Leasing, LLC (“Napior”), is a Michigan limited liability company. 2. Napior’s principal place of business is located at 2051 Traversefield Dr., Traverse City, MI 49686. 3. Napior owns and/or leases the real property assessed under tax parcel no. XA0- 109-1150-02, located at 1751 W. Beecher St. in Adrian, Lenawee County, Michigan (“the subject property”). 4. Napior is the taxpayer on the assessment roll for the subject property.
Page 2
2 75204532.1 5. For tax year 2026, the subject property parcel was classified “Commercial- Improved.” 6. Napior is a party in interest with respect to the subject property’s taxable status and property tax assessment for the subject property under MCL 205.735a. 7. The subject property was designed and is presently used for agricultural purposes. 8. Respondent, City of Adrian (“City”), is a city located in Lenawee County, Michigan. 9. The Tax Tribunal has jurisdiction under MCL 205.735a. 10. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 11. For tax year 2026, the City and its board of review determined a taxable value of $5,590,000 and assessed value of $5,590,000 for the subject real property, reported under parcel no. XA0-109-1150-02, which will result in a state equalized value in the same amount based on the tentative equalization factor. 12. At this time, Napior believes that the assessed value is more than 50% of the subject real property’s true cash value and, thus, the taxable value is also improper. 13. Napior asserts the true cash value of the subject real property is $3,837,000, resulting in an assessed and taxable value of $1,918,500. 14. The value in contention, equal to the difference between the values on the tax roll and Napior’s contended value is $3,671,500 (assessed and taxable value). 15. The 2026 assessment, including state equalized value, and taxable value, on the subject real property, and the taxes to be levied and collected, are invalid, unlawful, and operate as a fraud on Napior as: a. The assessment, including state equalized value and/or taxable value, exceeds the
Page 3
3 75204532.1 amount permitted by the Michigan Constitution and applicable statutes; b. The assessment, including state equalized value and/or taxable value, is at a higher percentage of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessment, including state equalized value and/or taxable value, is based on an erroneous determination of the true cash value of that portion of the subject real property that is taxable under Michigan law and based on the application of wrong principles; and d. The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by the City, discriminate against Napior and deny Napior its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Napior respectfully requests that the Tax Tribunal enter an Order reducing the 2026 assessed value, state equalized value, and taxable value of the subject real property, reported under tax parcel no. XA0-109-1150-02, to $1,918,500, and requiring the City to pay Napior the refunds attributable to such reductions, plus interest, attorneys’ fees and costs. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By Jackie J. Cook (P68781) 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7270 jcook@honigman.com Dated: April 17, 2026