20261011_PropertyTax_MIStateTribunal_VS5_wt.pdf
Toni Zhang, Petitioner V City Of Ann Arbor, Respondent · 25-002568-TT
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Michigan Tax Tribunal Appeal Tax Year 2025 Tongxiao (Toni) Zhang & Tong Wang Parcel Number: 09-09-10-402-133 3071 N. Spurway Drive, Ann Arbor, MI 48105 Michigan Tax Tribunal Hearing: October 15, 2026 MTT Case No. 25-002568 2024 Sales of the Community Subject Property: 3071 N. Spurway Dr. Ann Arbor, MI 48105
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Table of Contents • I. Executive Summary & Requested Relief • II. Market Evidence • III. Subject Property — Location & Proximity Impairment • IV. Comparable Sales Analysis • V. Reconciliation & Requested Valuation • Attachments / Supporting Evidence 2
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Executive Summary / Requested Relief Basis for Appeal Under Michigan Constitution, Article IX, Section 3, and MCL 211.27a(1), real property is generally assessed at 50% of its True Cash Value (TCV)*. Petitioner contends that the 2025 SEV of $398,600 exceeds 50% of the subject property's True Cash Value as of December 31, 2024. Petitioner's Position • North Oaks resale evidence shows that property values have not uniformly appreciated since the subject's purchase on July 22, 2021 (cross-sectional data analysis for 40+ condo units sales that closed in 2024 in the subject community) • A review of all identified repeat sales within North Oaks since July 2021 shows that 11 of 15 properties (73.33%) subsequently sold below their prior purchase prices.** (FHFA repeat sales in the subject community) • The subject property has an unusual and permanent proximity/privacy impairment that is not adequately reflected in Respondent's comparable sales. • Model/floor plan and lot/location characteristics materially affect market value within the community and should be considered when selecting and adjusting comparable sales (Data support in Attachments ~ Model & Lot Locations.) • Each of Respondent's three comparable sales has materially superior characteristics that require appropriate adjustments when estimating the subject property's value. • Based on the market evidence, data analysis, and valuation adjustments presented in this appeal, Petitioner respectfully requests a True Cash Value of $605,431 and a corresponding SEV of $302,716. 3 *Under MCL 211.27(1), True Cash Value is defined as the property's usual selling price in the market at the time of assessment. For the 2025 tax year, the relevant valuation date is December 31, 2024. **Source from public records (Please See References and Acknowledgements)
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Market Evidence: North Oaks Villa Repeat Sales Since July 2021 • The table identifies 16 North Oaks Villa repeat-sale properties purchased in or after July 2021. Excluding *3079 N. Spurway Dr., 15 observations remain for trend analysis. • Eleven of the 15 properties (73.33%) resold below their prior purchase prices. • The observations show a purchase-price-weighted average annual price change of approximately −2.07% over their respective holding periods. The largest price drop observed is over $90,000 and the largest percentage drop is over 10%. Methodology: This analysis adapts the repeat-sales approach underlying the FHFA House Price Index (HPI), using purchase-price-weighted annualized changes from North Oaks Villa repeat sales. Transactions after December 31, 2024 are used solely to estimate the historical market trend. The resulting annual rate is applied over 3.45 years, from July 22, 2021 to December 31, 2024, to estimate the subject’s True Cash Value. Note: *3079 N. Spurway Dr is excluded because property remodeling and basement finishing occurred between the two sales (Permit BLDG21-1693). Its price change may reflect both market movement and the improvement. 4 Address Purchase Date Sale Date Years Between Sales Purchase Price ($) Sale Price ($) Price Change ($) Price Change (%) Annual % Change 1 3077 N SPURWAY DR 2021-07-12 2026-06-10 4.91 624,995 610,000 -14,995 -2.40% -0.49% 2 *3079 N SPURWAY DR 2021-07-16 2024-07-17 3.00 690,000 758,000 68,000 9.86% 3.18% 3 3106 MILLBURY LN 2021-09-10 2024-04-22 2.61 838,801 799,000 -39,801 -4.74% -1.84% 4 3083 N SPURWAY DR 2022-01-27 2024-04-17 2.22 615,000 660,000 45,000 7.32% 3.23% 5 3095 MILLBURY LN 2022-04-22 2026-02-20 3.83 965,471 875,000 -90,471 -9.37% -2.53% 6 3097 MILLBURY LN 2022-04-28 2023-10-11 1.45 677,593 699,000 21,407 3.16% 2.16% 7 3099 MILLBURY LN 2022-05-24 2025-08-01 3.19 653,674 600,000 -53,674 -8.21% -2.65% 8 3101 MILLBURY LN 2022-05-25 2022-12-16 0.56 926,928 850,000 -76,928 -8.30% -14.30% 9 3111 MILLBURY LN 2022-09-07 2024-03-29 1.56 714,367 667,000 -47,367 -6.63% -4.31% 10 3312 SUNTON RD 2022-10-20 2026-04-08 3.47 799,846 740,000 -59,846 -7.48% -2.22% 11 3302 SUNTON RD 2023-01-24 2025-06-20 2.40 819,119 735,000 -84,119 -10.27% -4.41% 12 3306 SUNTON RD 2023-02-28 2025-10-10 2.61 705,000 700,000 -5,000 -0.71% -0.27% 13 3370 ROSEFORD BLVD 2023-03-21 2026-08-31 3.45 574,995 525,000 -49,995 -8.69% -2.60% 14 3372 ROSEFORD BLVD 2023-03-28 2025-01-23 1.83 626,175 679,000 52,825 8.44% 4.53% 15 3020 N SPURWAY DR 2023-05-23 2026-07-28 3.18 845,000 800,000 -45,000 -5.33% -1.71% 16 3334 ROSEFORD BLVD 2024-05-17 2025-04-18 0.92 680,000 695,000 15,000 2.21% 2.40%
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The subject's July 2021 purchase price predates the material site changes in 2024 and therefore should not be relied upon without consideration of those subsequent changes. Based on our review of North Oaks, the subject property's rear building separation appears to be among the closest in the community. Typical wider separation between other condominium buildings within the community Versus Smaller trees were planted near the neighboring deck to provide screening. One tree died in 2025, and others have shown limited health due to space issue, according to comments received from the community's landscaping contractor. Unique Adverse Situation 5
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6 Market Evidence of Proximity and Privacy Impairment: 11.8% Price Differential Between Comparable Units (Brandeis Models) A 3 2 1 Market Evidence : The 11.8% observed price differential between similar Brandeis models provides market evidence of the combined influence of lot location, building proximity, and privacy. This differential is used as a reasonable market-based indicator of the subject property's permanent location disadvantage. Property Comparison Base Model (Premium Lot) Clustered Model (Proximity Penalty) Price Impact ($) Value Variance (%) A vs. 1 Property A Property 1 -$122,046 -11.80% 3277 Hayster Ln 3269 Hayster Ln $1,030,612 $908,566 1 A Property Address Sale Date Sale Price Model Floor Area # Bedroom # Full Bath # 1/2 Bath 3277 HAYSTER Dr 10/21/2024 $1,030,612Brandeis 2,620 4 4 1 3269 HAYSTER 10/09/2024 $908,566Brandeis 2,685 4 4 1 • Property 1 is currently listed on Zillow for sale and had a recent (09/10) price cut that brought the list price down to $865,000, over $43,000 lower than its purchase price. • It has been listed for 83 days already as of 09/25. • Property 3 is the subject property, back-to-back with property 2, which has the closest proximity in the entire community, only 10 ft apart.
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Estimated Value of the Subject Property • Petitioner’s condo was purchased on July 22nd, 2021 at a price of $737,797. • The period from July 22, 2021 to December 31, 2024 is 3.45 year. Applying the estimated annual price change of −2.07% over the 3.45 years gives the following market-trend estimate: 𝑽𝒂𝒍𝒖𝒆𝑀𝑎𝑟𝑘𝑒𝑡 𝑇𝑟𝑒𝑛𝑑= 737,797× 1 −0.0207 3.45 = 686,429 • Note2: the −2.07% annual price change is a purchase-price-weighted average of the 15 repeat-sale observations. Weighting by purchase price gives equal weight to each dollar of transaction value, rather than equal weight to each property. • The two-property comparison on Page 6 informs the proposed 11.8% adjustment for the subject’s unusually close building proximity and reduced privacy. 𝑽𝒂𝒍𝒖𝒆𝑇𝐶𝑉= 686,429× 1 −0.118 = 605,431 𝑽𝒂𝒍𝒖𝒆𝑆𝐸𝑉= 605,431 ÷ 2 = 302,716 7
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Market Evidence: 2024 North Oaks Sales by Model and Lot Location Petitioner agrees that the Sales Comparison Approach is an appropriate method of valuation. The principal disagreement is whether Respondent’s selected comparable sales and adjustments adequately reflect the subject property’s model/floor plan, location characteristics, and unique proximity/privacy impairment as of December 31, 2024. 8 • 2024 North Oaks sales demonstrate substantial differences in average sale price per square foot across model and lot-location categories. • Lot Location: Among non-Brandeis properties, non-premium lots averaged $244/sq. ft., compared with $303–$308/sq. ft. for open- meadow and premium lots, approximately 19%–21% lower. • Model and Location: Non-Brandeis properties on non-premium lots averaged $244/sq. ft., compared with $325/sq. ft. for the Brandeis group, approximately 25% lower. • Assessment Comparison: The City's assessed values averaged approximately 18% above one- half of recorded sale prices for the 10 non- Brandeis, non-premium-lot sales, compared with approximately 7% for the nine Brandeis sales, subject to verification of the applicable assessment year and valuation date. For more details , please refer to the Attachment: 2024 Sales — Model (Brandeis Vs. Non- Brandeis) & Lot Locations (Premium Vs Non-Premium) Source: Sales of North Oaks community in 2024 (exclusion of 2 model units)
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To evaluate the market influence of lot/location, Petitioner compared four pairs of 2024 North Oaks sales with the same model and generally similar physical characteristics, including year built, bedroom/bath count, floor area, basement, and garage. Within each pair, the property on the less favorable/non-premium lot sold for approximately 16%–24% less than its paired counterpart, averaging approximately 20%. Data of these paired sales tend to establish that lot location alone caused the entire price difference; The consistent direction and magnitude of the differences provide market evidence that lot/location is a material value factor and should not be ignored when selecting or adjusting comparable sales. Note: All four ROSEFORD sales are on non-premium lots (tighter separations, no view, white wall divider). The 16%–24% discounts (avg. –20%) isolate this lot location effect. 9 Source: Sales of North Oaks community in 2024 (exclusion of 2 model units) For more details , please refer to the Attachment: 2024 Sales — Model (Brandeis Vs. Non-Brandeis) & Lot Locations (Premium Vs Non-Premium) Market Evidence: Paired Sales Analysis of Lot/Location Influence
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Respondent’s Comparable Sale #1 — Adjustment Analysis • Close size match: Comp #1 contains 2,716 sq. ft., compared with 2,735 sq. ft. for the subject—a difference of only 19 sq. ft. • Different model and lot: Comp #1 is a Brandeis model with an open- meadow setting, while the subject is a non-Brandeis model with less favorable building proximity and privacy conditions. • Supporting market evidence: Petitioner's Page 8 analysis shows that non- Brandeis, non-premium-lot properties averaged approximately 25% less per square foot than the Brandeis group in 2024. This is an observed group difference, not an automatic adjustment to Comp #1. • Repeat-sale evidence: Comp #1 resold for $765,000 in January 2024, approximately 3.5% below its September 2020 purchase price of $793,012. This provides a property-specific resale observation, subject to any changes in condition or improvements. • Conclusion: Comp #1 is highly comparable in size, but its model and favorable lot location require consideration before its $765,000 sale price can be used to estimate the subject's value. • Respondent’s value indication derived from this comparable does not identify an adjustment for the subject property’s unusually close building proximity and permanent loss of privacy. 10 Comparables Sales Analysis Complete price difference by unit features such as model plan and lot location is in Page 8 and attachment. Indicated TCV = Comp Sale Price Comp Floor Area ×2,735× $244 Comp Group Average $/sf = $578,356 Equivalent SEV= $289,178
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Respondent’s Comparable Sale #2 — Adjustment Analysis • Respondent recognizes the differences in gross living area and bathroom count, which further limits the weight that Comp #2 should receive as direct evidence of the subject’s value. • Size and feature differences: Comp #2 has 2,403 sq. ft., compared with the subject's 2,735 sq. ft., and one fewer full bathroom. These differences generally favor upward adjustments to Comp #2. • Superior lot setting: Comp #2 benefits from an open-meadow location, while the subject is affected by unusually close building proximity, diminished screening, and reduced privacy. • Market support for location differences: Petitioner's Page 8 analysis shows that non-Brandeis non-premium properties averaged $244/sq. ft., compared with $303/sq. ft. for non-Brandeis open-meadow properties— approximately 19% lower. • Conclusion: Comp #2 provides useful nearby market evidence. Its favorable location warrants consideration of a downward adjustment, while its smaller floor area and fewer bathrooms warrant consideration of upward adjustments. Its unadjusted $758,000 price should not be adopted directly as the subject's value. • Respondent’s value indication derived from this comparable does not identify an adjustment for the subject property’s unusually close building proximity and permanent loss of privacy. 11 Comparables Sales Analysis Complete price difference by unit features such as model plan and lot location is in Page 8 and attachment. Indicated TCV = Comp Sale Price Comp Floor Area ×2,735× $244 Comp Group Average $/sf = $694,736 Equivalent SEV= $347,368
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Respondent’s Comparable Sale #3 — Adjustment Analysis • Similar physical features: Comp #3 contains 2,620 sq. ft., compared with 2,735 sq. ft. for the subject, and has the same reported bedroom/bathroom configuration. • Superior model: Comp #3 is a Brandeis model, while the subject is non- Brandeis. Petitioner's community sales analysis demonstrates meaningful differences in average resale prices across model and lot categories. • Superior lot location: Comp #3 backs to woods, providing screening and separation that differ materially from the subject's close building exposure and diminished privacy. • Supporting market evidence: Petitioner's Page 8 analysis shows that non-Brandeis properties on non-premium lots averaged approximately 25% less per square foot than the Brandeis group. The comparison supports consideration of model and location differences, subject to other physical and transaction characteristics. • Conclusion: Comp #3's $799,000 sale price reflects a property with a different model and a more favorable rear setting. Model and lot-location differences should be evaluated, along with the subject's larger floor area, before applying this sale to the subject's valuation. • Respondent’s value indication derived from this comparable does not identify an adjustment for the subject property’s unusually close building proximity and permanent loss of privacy. 12 Comparables Sales Analysis Complete price difference by unit features such as model plan and lot location is in Page 8 and attachment. Indicated TCV = Comp Sale Price Comp Floor Area ×2,735× $244 Comp Group Average $/sf = $626,195 Equivalent SEV= $313,097
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Reconciliation & Requested Valuation Tax Year 2025 | Valuation Date: December 31, 2024 13 Valuation Component Amount July 22, 2021 purchase price $737,797 Estimated value after market adjustment of approximately −2.07% annually over 3.45 years Approximately $686,429 Proposed location/privacy adjustment of approximately 11.8% Approximately −$80,998 Requested True Cash Value, rounded $605,431 Requested SEV at 50% of True Cash Value $302,716 Basis for the Requested Value The subject’s July 2021 purchase price provides a property-specific starting point. North Oaks repeat-sale evidence informs the proposed market adjustment, while the October 2024 Hayster sales comparison supports consideration of the subject’s unusually close building proximity and permanent privacy impairment. Requested Relief Petitioner respectfully requests that the Tribunal determine the subject’s 2025 True Cash Value at $605,431, with a corresponding SEV of $302,716, reflecting its location and physical conditions as of December 31, 2024.
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References and Acknowledgments • Data, maps and pictures used in this analysis are taken and/or from public ready resouce, including government website • https://www.a2gov.org/finance-and-administrative-services/assessing/online-assessment-and-property-tax-data/ • https://experience.arcgis.com/experience/c81b35e965eb4f28a71689c43650368f • BS&A Online — City of Ann Arbor • Ann Arbor Assessing Department • Washtenaw County — Property & Taxes • https://secure.a2gov.org/A2Trak • stream.a2gov.org • https://www.realtor.com/ • https://www.redfin.com/neighborhood/ • (FHFA) https://www.fhfa.gov/document/d/hpi/hpi-faqs • Market and comparable-sales information was compiled with assistance and input from members of the North Oaks community and real estate professionals affiliated with Reinhart Realtors and Keller Williams. • Property characteristics, location, condition, model differences, and other relevant factors were considered in selecting and analyzing comparable sales. • Public property records, listing information, community information, photographs, maps, and other supporting materials are included or referenced where applicable. • The petitioners are responsible for the analysis, calculations, and conclusions presented in this appeal. 14
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Thank You! • We respectfully request that the Tribunal consider the actual 2024 market evidence together with the subject property's permanent and unique location disadvantages, including unusually close building proximity, loss of screening and privacy, and reduced open-space exposure. • We appreciate the City's September 16, 2026 site inspection and respectfully request that the observed site conditions be considered in this appeal. 15
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Attachment: Market Evidence Vs. City’s Assessment • Brandeis Model is significantly higher in total value (28%) and unit value (14%) for the same features and space • Overall, City Assessment value is 7-8% higher than market sales. Source of condos were sold in the community in 2024 (exclusion of 2 model townhouses) 16
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Attachment: 2024 Sales — Model (Brandeis Vs. Non-Brandeis) & Lot Locations (Premium Vs Non-Premium) • Lot Location Has a Material Impact on Market Value • Among Non-Brandeis 2024 sales, premium-lot properties averaged $308/SF, compared with $244/SF for non-premium lots — approximately 20% in difference of price per SF. • Differenciation of City’s assessments among the lot and models show less distinction. Non-premium lots were assessed, on average, 18% above 50% of actual sale price, compared with only 4% for premium lots. Source of condos were sold in the community in 2024 (exclusion of 2 model houses) 17
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• Lot Location Has a Material Impact on Market Value • Among Brandeis 2024 sales, Brandeis lot properties averaged $325/SF, while Non- Brandeis & Open Meadow lot is $303/SF • The City’s assessments is higher in general compare to the SEV/TMV Source of condos were sold in the community in 2024 (exclusion of 2 model houses) 18 Attachment: 2024 Sales (Cont’) — Model (Brandeis Vs. Non-Brandeis) & Lot Locations (Premium Vs Non-Premium)
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Attachment: The Brandeis Model’s Award-Winning Design Enhances Its Market Appeal Example: The Brandeis model commands a significantly higher price—approximately 20%—despite having comparable features and a similar exterior appearance. Source of condos sold in the North Oaks Villa community 19
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Attachment: Sample of Brandeis Model 20 Source: Noth Oaks condos sold in the North Oaks Villa community
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Attachment: Respondent’s List of 2024 Sales 21 Petitioner appreciates Respondent's effort in identifying a list of North Oaks Sales in 2024 (Attached list). However, our review of the available 2024 North Oaks sales records indicates that certain sales and property characteristics require updating or clarification. Petitioner reviewed Respondent’s 2024 North Oaks sales list alongside available property records and identified several items for clarification: • The October 2024 sale of 3277 Hayster for $1,030,612, used in Petitioner’s location comparison, does not appear in the list. • Certain reported half-bath counts differ from the property information compiled by Petitioner. • The subject property is a Vanleer model. Any identification of the subject as a Brandeis model should be corrected. These clarifications may assist in comparing properties with similar floor plans and physical characteristics.
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Attachment: Neighborhood Context and Subject Property Location 22 Respondent’s neighborhood description provides context for the North Oaks community. The reference to Rayfield Avenue as the southern boundary warrants clarification because the road runs generally north–south. For this appeal, Petitioner places greater emphasis on the subject’s immediate surroundings, including unusually close building proximity, limited screening, and reduced privacy. The report’s statement that “No adverse neighborhood conditions were observed” describes the broader neighborhood. Petitioner respectfully asks that the Tribunal also consider the subject’s specific location within that neighborhood. Photographs and maps illustrate these conditions. Evidence identifying the conditions present as of December 31, 2024 supports their consideration in the 2025 valuation. https://www.piperpartners.com/areas/ann- arbor/neighborhoods/north-oaks-of-ann-arbor/ The Townhome and Villa properties are divided by Dhu Varren Rd with Villas on the North and Townhomes on the south. The grounds can be accessed from Nixon Rd. which bounds the neighborhood to the East. M-14 provides the northern boundary and Logan Elementary School is directly South. Subject Property: 3071 N. Spurway Dr. Ann Arbor, MI 48105
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Attachment: Method of The FHFA House Price 23 The FHFA House Price Index provides useful context for broader housing-market trends, excluding condo/coop. Its relevance to this appeal depends on the specific index series, geographic coverage, and property types represented. The subject is a condominium within North Oaks. Petitioner therefore presents sales from the same development as additional evidence of local condominium market behavior. In his analysis, petitioner adapts the repeat-sales approach underlying the FHFA House Price Index (HPI), using purchase-price-weighted annualized changes from North Oaks Villa repeat sales. Petitioner’s repeat- sale analysis is an independent calculation using identified North Oaks transactions. It differs from the FHFA index methodology and should be considered with its stated assumptions and limitations. Source: FHFA-FAQs https://www.fhfa.gov/document/d/hpi/hpi-faqs
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Attachment: Supplemental Market Context: Condominium in Ann Arbor 24 The flagship FHFA Purchase-Only House Price Index provides useful context for broader housing-market trends, but its sample excludes condominiums and cooperatives. Petitioner therefore includes Redfin’s condominium and co-op statistics to complement that index with information specific to the subject’s property type in Ann Arbor location. These citywide statistics provide supplemental context. Condominium-specific market information provides additional context for evaluating the subject property. Note: The displayed data extend beyond December 31, 2024 and do not directly establish the subject’s value on that date. Source: Redfin.com
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25 Attachment: Supplemental Market Context — Condominiums in ZIP Code 48105 Redfin’s condominium and co-op data for ZIP Code 48105 provide a more localized comparison than citywide residential statistics. The displayed median sale prices fluctuate over time. Changes in the mix of properties sold may contribute to these movements, so the chart does not establish the change in value of an individual North Oaks condominium. Condominium-specific data complement broader housing-market indicators. As discussed in the preceding attachment, the FHFA Purchase-Only Index excludes condominiums and cooperatives. Note: Because the displayed data extend into 2026, Petitioner presents them as supplemental context rather than a direct measure of the subject’s value as of December 31, 2024. Source: Redfin.com (https://www.redfin.com/zipcode/48105/housing-market)