Petition - TSFR Dundee.pdf
Tsfr Apple Venture, LLC Petitioner Vs. Township Of Dundee Respondent · 26-000745-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL TSFR Apple Venture, LLC, Docket No. 26- Petitioner, Parcel No. 42-014-002-06 v. Village of Dundee, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioner Entire Tribunal Property Tax Petition Petitioner TSFR Apple Venture, LLC and Dundee 119, 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 TSFR Apple Venture, LLC is a Michigan limited liability company with its principal place of business located in Michigan at 17800 Laurel Park Drive North, Suite 200c, Livonia, MI 48152. 2. Respondent Village of Dundee is a Michigan village with its principal
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offices located at 179 Main Street, Dundee, MI 48131. The Subject Property 3. Petitioner owns property identified as Parcel No. 42-014-002-06 and commonly known as 119 Whitetail Drive, Dundee, Michigan 48131 (the “Subject Property”). 4. The Subject Property is located in Monroe County and is within the Dundee Community School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Property. The 2026 Assessment 6. For the 2026 tax year, Respondent classified the Subject Property as commercial real property. 7. For the 2026 tax year, Respondent established the Subject Property’s assessment for property taxes as follows: True Cash Value Assessed Value Taxable Value 1,762,140 881,070 869,040 8. Petitioner contends that a lawful assessment of the Subject Property for the 2026 tax year cannot exceed the following amounts: True Cash Value Assessed Value Taxable Value 1,100,000 550,000 550,000 9. The amounts in dispute therefore are as follows: True Cash Value Assessed Value Taxable Value 662,140 331,070 319,040
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10. This Petition presents issues involving the Subject Property’s 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. 11. The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 12. Petitioner does not assert that the Subject Property’s 2026 assessment is not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Property’s values. Conclusion and Request for Relief WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under Michigan law. Respectfully Submitted, WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC By: /s/ Jerome P. Pesick Jerome P. Pesick (P29039) Dated: May 6, 2026 Attorneys for Petitioner