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Motion to Amend Petition re Collins Sandra and Tim.pdf

Sanda F Collins Trust, Petitioner Vs. City Of Birmingham, Respondent · 25-002867-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

SANDRA F. COLLINS TRUST, 

 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. 25-002867 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No. 08-19-25-151-070 

CITY OF BIRMINGHAM, 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

Michael C. Gibbons (P51304) 

BEIER HOWLETT, P.C. 

Attorneys for Respondent 

3001 W. Big Beaver Rd., Ste 600 

Troy, MI 48084 

(248) 282-1069 

mgibbons@bhlaw.us.com 

_____________________________________ 

 

 

MOTION TO AMEND PETITION TO ADD TAX YEAR 2026 

 

Petitioner Sandra F. Collins Trust, by and through its attorneys, Varnum LLP, state the 

following for its Motion to Amend Petition: 

1. 

Petitioner, Sandra F. Collins Trust, is the owner of and/or the party in interest with 

respect to the real property (the "Property") which is in the City of Birmingham, Oakland County, 

Michigan, and is more particularly described as: 

Parcel No. 

 

 

Property Address 

 

 

08-19-25-151-070 

 

1100 Lakeside Rd., Birmingham, Michigan 48009 

 

2. 

Respondent, City of Birmingham, assesses, levies, and collects the property taxes 

on this Property.

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2 

 

3. 

The Property is in the Birmingham Public School District (63010). 

4. 

The property is classified as Residential vacant real property. 

5. 

Petitioner appealed its tax year 2026 assessment to the Board of Review, and 

Respondent denied Petitioner's appeal. See Exhibit A. 

6. 

The matter involves issues relating to (1) true cash value, (2) assessment, and (3) 

taxable value. 

7. 

The tax year currently pending in this appeal is 2025. Through this Motion, 

Petitioners are seeking to add tax year 2026 to this appeal. 

8. 

The Tax Year 2026 values for the Property are established by the Respondent are: 

Parcel 

True Cash Value 

Assessed/State 

Equalized Value 

Taxable Value 

08-19-25-151-070

$1,107,580 

$553,790 

$411,290 

 

9. 

Petitioner contends the correct values for the Property are: 

 Parcel 

True Cash Value 

Assessed/State 

Equalized Value 

Taxable Value 

08-19-25-151-070

$500,000 

$250,000 

$250,000 

 

10. 

The Value in dispute for the property are: 

Parcel 

True Cash Value 

Assessed/State 

Equalized Value 

Taxable Value 

08-19-25-151-070

$607,580 

$303,790 

$161,290 

 

11. 

 Petitioner requests the reduction of the Property's true cash value, assessed, state 

equalized, and taxable value as outlined in the above paragraph 9. Petitioner further requests a 

refund with interest of taxes paid due to the original, incorrect assessment and any other relief this 

Tribunal deems appropriate.

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12. 

The 2026 values imposed on the subject Property and the taxes to be levied and 

collected thereon, are invalid and unlawful and operate as fraud upon the taxpayers for the reasons 

that: 

a. The assessment, state equalized value, and/or taxable value exceed the amounts 

permitted by the Michigan Constitution and applicable statutes and do not reflect 

the sales of similar properties. 

b. The assessment, state equalized value, and/or taxable values are at higher 

percentages of true cash value than permissible under the Michigan Constitution 

and applicable statutes. 

c. The assessment, state equalized value, and/or taxable value, and the mode of 

assessment adopted by Respondent discriminate against Petitioners, their 

constitutional rights of uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner prays that the Tribunal will grant Petitioner’s Motion to Amend 

the Petition and add the 2026 tax year to this appeal. Petitioner also seeks the following relief: 

A. Correct and/or reduce the tax year 2026 assessed and state equalized values from 

$553,790 to $250,000, and correct the tax year 2026 taxable value from $411,290 

to $250,000 pursuant to Michigan law, and, if applicable, order a refund with 

interest; and

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4 

 

B. That Respondent be ordered to pay costs, attorneys' fees and interest at statutory 

rate, and to provide such additional relief to Petitioners as this Tribunal shall deem 

appropriate. 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

Dated: July 30, 2026 

 

 

By:____/s/ Deborah I. Ondersma _________ 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

Business Address/Telephone: 

 

 

 

 

 

 

 

333 Bridge Street, N.W. 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

 

ajbrody@varnumlaw.com 

 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

29506533.1

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EXHIBIT A

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** Notice of March Board of Review Change ** 

FROM 

CITY OF BIRMINGHAM 

MICHEAL R. LOHMEIER, ASSESSOR 

PO BOX 3001 

BIRMINGHAM MI 48012-3001 

NAME AND ADDRESS OF OWNER OR PERSON NAMED ON ASSESSMENT ROLL: 

SANDRA F COLLINS TRUST 

PROPERTY IDENTIFICATION: 

COLLINS TRUSTEE, SANDRA F 

08-19-25-151-070 

1114 LAKESIDE DR 

BIRMINGHAM MI 48009-1381 

SCHOOL DISTRICT: 63010 

PROPERTY ADDRESS 

1100 LAKESIDE RD 

THIS PROPERTY IS CLASSIFIED AS: 

402 

Residential 

PRINCIPAL RESIDENCE/QUALIFIED AG EXEMPTION: 

100.00% 

MICHIGAN BUSINESS EXEMPTION: 

0.00% 

PRIOR YEAR'S CLASSIFICATION IF DIFFERENT: 

~~ 402 

Residential 

The Board of Review has Examined your 2026 Assessed Value and/or Capped Value and has made the following decision: 

PETITION NUMBER 

145 

DATE: 

03/13/2026 

VALUE PRIOR MBOR | VALUE AFTER MBOR 

CHANGE 

1. ASSESSED VALUE 

553,790 

553,790 

0 

2. CAPPED VALUE 

411,290 

411,290 

3. TAXABLE VALUE 

411,290 

411,290 

0 

4. TENTATIVE EQUALIZATION FACTOR: 

1.000 

5. STATE EQUALIZED VALUE: 

553,790 

553,790 

| 

0 

6. There WAS/WAS NOT a transfer of ownership on this property in 2025. 

WAS NOT 

The 2026 Capped Value Formula is the 2025 Taxable Value, minus losses, increased by the Inflation Rate Multiplier of 3.1%, 

plus Additions. Taxable Value is the lower of Assessed Value or Capped Value unless an Ownership Transfer occurred. Your: 

Taxes are Levied on the Taxable Amount. 

Further appeal of valuation may be made to the Michigan Tax Tribunal by filing a petition that can be obtained 

at 

www.michigan.gov/taxtrib (click Small Claims Tab) and mailed to PO Box 30232, Lansing, MI 48909 by May 31st for 

Commercial Real, Industrial Real, Developmental Real, Commercial Personal, Industrial Personal, and Utility Personal Property. 

The final date for further appeal of valuation for Agricultural Real, Residential Real, Timber Cut-over Real, and Agricultural 

Personal Property is July 31st. All other matters have 35 days to appeal. 

Michigan Tax Tribunal Decisions received February through May are not reflected in this March Board of Review 

Change Notice. 

A COPY OF THIS NOTICE MUST ACCOMPANY ANY PETITION TO THE MICHIGAN TAX TRIBUNAL OR YOUR APPEAL 

WILL DEFAULT. 

CITY OF BIRMINGHAM 

BOARD OF REVIEW 

If you disagree with the decision of the Board of Review regarding classification, appeal is made by sending Form 

2167 to the State Tax Commission, PO Box 30471 Lansing MI 48909 by June 30th.

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