ET-Petition-Prop-fillable.pdf
Fh Hotels Inc Petitioner Vs. City Of Farmington Hills Respondent · 26-000571-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 FH HOTELS INC. THE CITY OF FARMINGTON HILLS 22-23-14-101-039 X 201 Commercial
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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: _______________________________________ Pursuant to MCL 205.735a(4)(a), a protest of the assessment of Commercial Real Property is not required to be made before the local Board of Review to invoke the Tribunal’s jurisdiction. Petitioner is invoking jurisdiction directly. Furthermore, the Petitioner’s authorized representative (General Manager) was physically out of the country during the Board of Review sessions and did not review the notice until March 14, 2026. Upon review, Petitioner noted an increase in taxable value of $935,380, which uncapped the property to an SEV that implies a market value significantly exceeding the actual arm's-length purchase price of $3.3 Million paid on Nov 20, 2025. Petitioner appeals both the SEV and Taxable Value to ensure the assessment reflects the property's True Cash Value as evidenced by the recent sale. Oakland 30715 W.12 Mile Road, Farmington hills, MI 48334 The City of Farmington hills 994 Saint James Park Ave, Monroe, MI 48161 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 $5,120,780 $2,560,390 $2,560,390 2026 $3,300,000 $1,650,000 $1,650,000 2026 $1,820,780 $910,390 $910,390 Petitioner respectfully requests that the Tribunal: Grant jurisdiction over this appeal pursuant to MCL 205.735a(4)(a) for Commercial Real Property. Correct the 2026 True Cash Value to reflect the actual arm’s-length purchase price of $3,300,000. Reduce the 2026 State Equalized Value (SEV) and Taxable Value to $1,650,000 (50% of the purchase price), effectively correcting the uncapping error. Order the City of Farmington Hills to adjust the 2026 tax rolls to reflect these corrected values prior to the issuance of the Summer and Winter tax bills. Order a refund (plus interest) of any 2026 taxes that may be paid at the current erroneous assessment level during the pendency of this appeal. 1. Arm’s-Length Transaction: The subject property was purchased by Petitioner in November 2025 for $3,300,000. This was an arm’s-length transaction between unrelated parties on the open market. 2. Professional Representation: Both Buyer and Seller were represented by licensed real estate sales agents and legal counsel, ensuring the price was negotiated at fair market value. 3. Proximity to Tax Status Date: The November 2025 sale occurred less than 60 days prior to the December 31, 2025, tax status date, making the purchase price the most reliable evidence of True Cash Value for 2026. 4. Physical & Functional Obsolescence: The property is 40 years old (built circa 1986) and suffers from significant physical depreciation and functional obsolescence. The City’s assessment fails to account for the heavy capital expenditure required for a building of this age. 5. Economic Income & Profitability: The property has demonstrated a lack of profitability for several years. Pursuant to MCL 211.27(1), the assessment must consider "present economic income." The current assessment reflects a theoretical value that the actual income stream cannot support. 6. Erroneous Uncapping: While the transfer "uncapped" the property, Michigan law (MCL 211.27a) requires the new Taxable Value to be established at 50% of the actual True Cash Value ($1,650,000), not the City's inflated estimate.
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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: _________________________________________________________________ Balaji Joshi FHHOTELSINC@gmail.com 30715 W 12 mile Road, Farmington hills, MI 48334 248 660 6488 3/31/2026