JEB Property Tax Petition and POS.pdf
Jeb Land Development LLC Petitioner Vs. City Of Southfield Respondent · 26-002163-TT
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v STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR DIRECTOR LANSING _____________________________, MICHIGAN TAX TRIBUNAL Petitioner(s) MTT Docket No. _____________________________, Respondent(s) ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: _____________________________________________ (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) 2. The property identified above is ___real ___personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? ___Yes ___No. (If no, separate Petitions are required for each non contiguous parcel.) 4. Are all of the parcels of personal property located on a parcel of real property under appeal? ___Yes ___No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): 6. The property identified above is classified as _________________________ 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s ___ March ___ July ___December Board of Review. MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 JEB LAND DEVELOPMENT LLC CITY OF SOUTHFIELD 762432400027 X COMMERCIAL REAL
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MTT Docket No. _________________ Page 2 of 4 8. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): 9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): 10. The property or properties at issue are located in _______________County. The property or properties’ address is: 11. The assessment or assessments at issue were established by the (applicable local governmental unit): ________________________________________ 12. Petitioner’s legal residence or principal office address is: 13. This appeal involves issues relating to the (check all that are applicable): ________the property or properties’ true cash and taxable values ________the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or loss? ___ Yes ___No ________uniformity of the property or properties’ assessment ________the property or the properties’ exemption from ad valorem taxation under MCL ______ 14. The tax year(s) at issue are: _______________________________________ OAKLAND 21399 TELEGRAPH RD SOUTHFIELD, MI 48033 CITY OF SOUTHFIELD 26261 EVERGREEN RD SUITE 322 SOUTHFIELD MI X X 2026
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MTT Docket No. _________________ Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary): 16. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 19. Petitioner requests the following relief (attach additional page if necessary): 20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach additional page if necessary): 2026 $2,046,380 $1,023,190 $1,023,190 2026 $950,000 $475,000 $475,000 2026 $1,096,380 $548,190 $548,190 FOR THE 2026 TAX YEAR, PETITIONER REQUESTS THAT THIS TAX TRIBUNAL DETERMINE THE LAWFUL AND UNIFORM ASSESSMENT ON THE SUBJECT PROPERTY, REDUCE THE TRUE CASH VALUE FROM $2,046,380 TO $950,000, AND REDUCE THE STATE EQUALIZED, ASSESSED AND TAXABLE VALUES FROM $1,023,190 TO $475,000, ORDER REFUNDS OF THE TAX OVERPAYMENTS (including any administrative or other fees) WITH STATUTORY INTEREST, AND AWARD PETITIONER COSTS, INCLUDING ATTORNEY FEES. THE ASSESSMENT, INCLUDING STATE EQUALIZED VALUE AND/OR TAXABLE VALUE, EXCEED THE AMOUNTS PERMITTED BY THE MICHIGAN CONSTITUTION AND APPLICABLE STATUTES. THE ASSESSMENT, INCLUDING SEV AND/OR TV, ARE AT A HIGHER PERCENTAGE OF TRUE CASH VALUE THAN PERMISSIBLE UNDER THE MICHIGAN CONSTITUTION AND APPLICABLE STATUTES. THE ASSESSMENTS, INCLUDING SEV AND/OR TV, ARE BASED ON AN ERRONEOUS DETERMINATION OF TRUE CASH VALUE AND ON APPLICATION OF WRONG APPRAISAL PRINCIPLES. THE SUBJECT PROPERTY HAS NOT BEEN UNIFORMLY ASSESSED AS REQUIRED BY MICH CONST 1963 ART 9, SEC 3, AND THE ASSESSMENT IS AT A HIGHER LEVEL OF TCV THAN AVERAGE LEVEL OF ASSESSMENT FOR COMMERCIAL PROPERTIES IN ASSESSMENT DISTRICT IN VIOATION OF APPLICABLE STATUTE.
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______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ MTT Docket No. _________________ Page 4 of 4 Signature of Petitioner’s Authorized Representative or, if none, Petitioner: Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: Email Address: _________________________________________________________ Mailing Address: Telephone Number: _____________________________________________________ Date: _________________________________________________________________ /s/ Joanne Faycurry JOANNE FAYCURRY OF DICKINSON WRIGHT PLLC jfaycurry@dickinsonwright.com DICKINSON WRIGHT PLLC 2600 WEST BIG BEAVER RD, SUITE 300 TROY, MI 48084 (248) 4337200 June 1, 2026
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON |. BROWN, DPA GOVERNOR LANSING DIRECTOR JEB LAND DEVELOPMENT LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. CITY OF SOUTHFIELD , Respondent(s) PROOF OF SERVICE YULUNDER AMOS states that on 06/01/2026 he/she [Name of person serving/mailing petition] [date of service] served a copy of the Entire Tribunal Property Tax Petition relative to the above-captioned matter upon: [Provide name and address of the party/people being served] CITY OF SOUTHFIELD 2600 EVERGREEN RD. P.O. BOX 2055 SOUTHFIELD, MI 48037 /s/ YULUNDER AMOS [Signature of person who is serving/mailing copy] YULUNDER AMOS [Print/type name of person serving/mailing copy] MICHIGAN TAX TRIBUNAL - 611 W. OTTAWA ST., LANSING, MI 48933 - 517-335-9760 PO BOX 30232, LANSING, MI 48909 - Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906