Petition - Nizan Wyoming.pdf
Division Ave Self Storage LLC Petitioner Vs. City Of Wyoming Respondent · 26-001141-TT
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Petition Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL DIVISION AVE SELF STORAGE, LLC, Docket No. 26- Parcel Nos. 41-17-36-476-031 Petitioner, 41-17-36-476-043 41-17-36-476-007 v. CITY OF WYOMING, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com Entire Tribunal Property Tax Petition Petitioner Division Ave Self Storage, LLC, by and through its attorneys, Williams Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. The Parties 1. Petitioner Division Ave Self Storage, LLC, is a Michigan limited liability company with its registered office located at 1411 3rd Street, 4th Flr Ste F, Port Huron, MI 48060. 2. Respondent City of Wyoming is a Michigan city with its primary offices located at 1155 28th St SW, Wyoming, MI 49509. The Subject Properties 3. Petitioner owns properties identified as follows:
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Petition Page 2 Parcel Number Property Address 41-17-36-476-031 5633 S Division 41-17-36-476-043 5611 S Division 41-17-36-476-007 5625 S Division These parcels are physically contiguous to each other. They are referred to collectively in this Petition as the “Subject Properties.” 4. The Subject Properties are located in Kent County and are within the Kentwood 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. Petitioner contends 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. 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. Petitioner does 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 reserves its right to assert issues involving losses should information supporting such issues become available.
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Petition Page 3 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 Petitioner’s rights. 12. Petitioner does 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, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed Petitioner’s contentions of value set forth on the attached Multiple Parcel Form and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS WILLIAMS RATTNER & PLUNKETT PC By: /s/ Brian E. Etzel Brian E. Etzel (P54905) Dated: May 19, 2026 Attorneys for Petitioner
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Multiple Parcel Form Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL DIVISION AVE SELF STORAGE, LLC, Docket No. 26- Parcel Nos. 41-17-36-476-031 Petitioner, 41-17-36-476-043 41-17-36-476-007 v. CITY OF WYOMING, Respondent. Brian E. Etzel (P54905) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 bee@wwrplaw.com 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 41-17-36-476-031 5,099,000 2,549,500 1,894,152 41-17-36-476-043 298,400 149,200 102,283 41-17-36-476-007 71,000 35,500 33,564 Totals: 5,468,400 2,734,200 2,029,999
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Multiple Parcel Form Page 2 2. Petitioner contends that lawful 2026 assessments for the Subject Properties cannot exceed the following amounts: Parcel No. True Cash Value Assessed Value Taxable Value 41-17-36-476-031 2,800,000 1,400,000 1,400,000 41-17-36-476-043 160,000 80,000 80,000 41-17-36-476-007 40,000 20,000 20,000 Totals: 3,000,000 1,500,000 1,500,000 3. The amounts in dispute for the 2026 tax year are therefore as follows: Parcel No. True Cash Value Assessed Value Taxable Value 41-17-36-476-031 2,299,000 1,149,500 494,152 41-17-36-476-043 138,400 69,200 22,283 41-17-36-476-007 31,000 15,500 13,564 Totals: 2,468,400 1,234,200 529,999