Contour Acquisitions A Delaware Limited Liability Company Petitioner Vs. City Of Southfield Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

NOTICE OF SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

Contour Acquisitions a Delaware 

Limited Liability Company,

Petitioner,

v

 

 

City Of Southfield,

Respondent.

 MTT Docket No. 26-001220

Please be advised that 26-001220 has been placed on a two-week Prehearing General 

Call commencing September 16, 2027. Unless ordered otherwise, parties will be 

notified at least 28 days before they are scheduled to appear. Scheduling will not 

necessarily occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website.

Page 2

MTT Docket No. 26-001220

Page 2 of 3

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by May 20, 2027. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by May 20, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

May 20, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

September 16, 2027, which means all discovery has been requested, all Motions to 

Compel have been filed, and all requested or ordered discovery has been exchanged 

by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s 

valuation disclosure, the opposing party’s valuation expert, and the witnesses identified 

on the opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Page 3

MTT Docket No. 26-001220

Page 3 of 3

Entered: October 16, 2026 

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

NOTICE OF SEPTEMBER 16- 30, 2027

Page 5

MT

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Page 1

STATE OF MICHIGAN 

DEPARTMENTOF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CONTOUR ACQUISITIONS, 

 

 

 

Petitioner, 

 

v 

 

CITY OF SOUTHFIELD, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001220 

 

_____________________________________________________________________________/ 

 

C. DAVID BARGAMIAN (P43742) 

KERR, RUSSELL, & WEBER, PLC 

Attorneys for Petitioner 

500 Woodward Avenue, Suite 2500 

Detroit, MI 48226 

(313) 961-0200 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Southfield, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks knowledge or information regarding the truth of the allegations 

contained in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent denies the approximate square footage of each of the 4 parcels for the 

reason that they are untrue. As to the remaining allegations contained in Paragraph 3, Respondent 

admits. 

 

4. 

Respondent admits the allegations in Paragraph 4.

Page 2

2

5. 

Respondent admits Petitioner filed a protest with the March Board of Review but 

neither admits nor denies Petitioner’s authority to appeal directly to the Tribunal as the General 

Property Tax Act speaks for itself. 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent lacks knowledge or information regarding the truth of the allegations 

contained in Paragraph 7 and, therefore, leaves Petitioner to its proofs. 

 

8. 

Respondent lacks knowledge or information regarding the truth of the allegations 

contained in Paragraph 8, including subparagraphs (a) – (g) and, therefore, leaves Petitioner to its 

proofs. 

 

9. 

Respondent denies the allegations in Paragraph 9 for the reason that the same are 

untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed 

permitted amounts, do not exceed the percentage of true cash value permitted by law, were 

correctly determined and are based upon correct application of proper principles, and the values 

and Respondent’s mode of assessment are non-discriminatory and constitutional. 

 

10. 

Respondent acknowledges Petitioner’s contentions of value but denies that they 

reflect the properties fair market value as of December 31, 2025. In further answer, the assessed, 

state equalized and/or taxable values do not exceed permitted amounts, do not exceed the 

percentage of true cash value permitted by law, were correctly determined and are based upon 

correct application of proper principles, and the values and Respondent’s mode of assessment are 

non-discriminatory and constitutional. 

 

11. 

Respondent acknowledges Petitioner’s belief as to a dispute in the subject 

property’s valuation but denies Petitioner’s contentions of value have merit and further denies 

Petitioner is entitled to relief. 

 

12. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to said relief for the reasons set forth above. 

 

 

WHEREFORE, Respondent, City of Southfield, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees.

Page 3

3

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 26, 2026 

 

 

 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Southfield, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the

Page 4

4

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a

Page 5

5

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001220

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Southfield (OAKLAND)

First Name

M.I.

Last Name

Home Address (No., Street, P.O. Box or Rural Route)

City or Town

State

ZIP Code

Telephone Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

Address (No., Street, P.O. Box or Rural Route)

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

mtt@hallahanlaw.com

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

/s/Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CONTOUR ACQUISITIONS, a 

Delaware limited liability company 

Petitioner 

M.T.T. Docket 

V. 

No. 26-001220 

CITY OF SOUTHFIELD, a 

Michigan public body corporate, 

Respondent 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

COUNTY OF WAYNE 

) 

KIMBERLY A. GLYNN, being duly sworn, deposes and says that she is 

employed at the law offices of Kerr, Russell and Weber, PLC, attorneys for Petitioner in 

the above-entitled cause, and that on July 29, 2026 she served a Petition, Notice of 

Docket Number and this Proof of Service as follows: 

Mailed by certified mail, return receipt requested and depositing into the US mail, 

to the following officials: 

Justin Prybylski, Assessor 

Gabi Grossbard, City Clerk 

City of Southfield 

City of Southfield 

26000 Evergreen Road 

26000 Evergreen Road 

Southfield, MI 48037 

Southfield, MI 48037 

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 

1

Page 2

And, mailed by certified mail, return receipt requested and depositing into the US 

mail to the following officials: 

Michael Lohmeier 

Lisa Brown 

Oakland County Director 

Oakland County Clerk 

Oakland County Equalization Division 

Oakland County Building 

Oakland Pointe Office Building 

1200 N. Telegraph Road, Bldg. 12 East 

250 Elizabeth Lake Road, Ste. 1000W 

Pontiac, MI 48341 

Pontiac, MI 48341-0431 

Rachael Eubanks, State Treasurer 

Aisha Tyler 

Michigan Department of Treasury 

Secretary, Board of Education 

State of Michigan 

Oak Park Schools 

430 W. Allegan Street 

13900 Granzon 

Lansing, MI 48933 

Oak Park, MI 48237 

I declare that the statements above are true to the best of my information, 

knowledge and belief. 

By: Kind 

Hg 

Kimberly AY Glynn 

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 

1

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001220

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Proof of Service

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CONTOUR ACQUISITIONS, a 

Delaware limited liability company 

 

Petitioner 

 

 

 

 

M.T.T. Docket 

V. 

 

 

 

 

 

 

 

No. 26-________ 

 

CITY OF SOUTHFIELD, a 

Michigan public body corporate, 

 

Respondent 

 

_______________________________________________________________________/ 

 

PETITION 

 

PETITIONER, by its attorneys, Kerr, Russell & Weber, PLC, hereby petitions the 

entire tribunal against the above-named Respondent, and states as follows: 

1. 

Petitioner is a duly organized and existing Delaware limited liability company 

with its principal office located at 40950 Woodward Avenue, Suite 300, Bloomfield 

Hills, MI 48304. 

2. 

Respondent is a Michigan public body corporate. 

3. 

The parcels of land at issue are contiguous parcels of commercial real estate 

improved with 4 office buildings (collectively, the “Property”), more particularly 

described as: 

Parcel No. 

Address 

Approximate Square Footage 

76-24-36-477-002 

15565 Northland Drive 

111,600 Square Feet 

76-24-36-477-003 

15530 Northland Drive 

113,625 Square Feet 

76-24-36-477-004 

20905 Greenfield Road 

63,220 Square Feet 

76-24-36-477-005 

20755 Greenfield Road 

140,778 Square Feet

Page 2

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

4. 

The Property is classified as commercial and is located in Oakland County and the 

Oak Park Public School District. 

5. 

Because the Property is classified as commercial real estate, appeal directly to the 

Tax Tribunal is authorized by Act 174 of Public Acts of 2006. Nonetheless, Petitioner 

appeared before Respondent’s Board of Review on March 5, 2026 to protest the 

Property’s assessed and taxable values. 

6. 

The values of the Property as established by the Respondent's Board of Review 

following Petitioner’s appeal to the Board of Review are: 

Tax Year 

Parcel Nos. 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

76-24-36-477-002 

$1,291,160.00 

$645,580.00 

$645,580.00 

2026 

76-24-36-477-003 

$1,268,300.00 

$634,150.00 

$634,150.00 

2026 

76-24-36-477-004 

$2,257,780.00 

$1,128,890.00 

$1,128,890.00 

2026 

76-24-36-477-005 

$1,533,760.00 

$766,880.00 

$766,880.00 

Totals 

 

$6,351,000.00 

$3,175,500.00 

$3,175,500.00 

 

7. 

Petitioner acquired the Property from the prior owner, Northland Towers 

Associates Limited Partnership, in an arms-length transaction on December 17, 2025, for 

the full consideration of $3,400,000.00. As part of normal closing prorations, Petitioner 

reimbursed Northland Towers Associates for a portion of the December 2024 tax bill and 

the July 2025 tax bill and is responsible for payment of all tax bills rendered by the taxing 

authorities thereafter. 

8. 

In preparation for redevelopment of the Property and possible application for 

incentives under the Brownfield Redevelopment Financing Act, Act 381 of 1996, 

Petitioner obtained an Obsolescence Study of the Property prepared by Matthew J. 

Schmidt, a Michigan Master Assessing Officer (4). Mr Schmidt concluded that the

Page 3

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

Property is functionally obsolete and subject to significant impairment of functional 

capacity due to: 

a. 

the buildings are subject to substantial deferred maintenance; 

b. 

elevators in the building are old, several are inoperable, and replacement 

parts are no longer being manufactured for the units; 

 

c. 

the elevator sizes are not compliant with the Americans with Disabilities 

Act. Any renovation of the buildings would require increasing the size and 

configuration of the elevator shafts to accommodate ADA compliant 

elevators; 

 

d. 

the existing heating and cooling systems are between 50 and 60 years old 

and need to be replaced. The manufacturers no longer maintain a 

replacement parts inventory. Repairs will require salvaging parts from 

other inoperable units; 

 

e. 

bathroom doors are not ADA compliant; 

f. 

the roofs require complete recovering and structural repairs to prevent 

water leaks in the upper floors of the building; and 

 

g. 

these deficiencies make it difficult to attract tenants and is a reason that 

occupancy is only between 30% and 40%. 

 

9. 

Respondent's 2026 real property assessment and taxable value fail to take into 

consideration the following: 

a. 

The age of the subject Property; 

 

b. 

existing and projected vacancies and the length of existing vacancies; 

 

c. 

projected costs of leasehold improvements that will have to be expended in 

order to attract new tenants to the Property; 

 

d. 

the lack of current income generated by subject Property; 

 

e. 

deferred maintenance items; 

 

f. 

existing market and mortgage conditions;

Page 4

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

g. 

overall physical, economic and functional obsolescence factors; 

 

h. 

increased costs in maintaining and operating subject Property; 

 

i. 

proper depreciation factors; 

 

j. 

the marketing and sales history of this Property and sales of comparable 

properties; and 

 

k. 

adequate reserves for replacement; 

 

and, therefore, said assessment and taxable values are in excess of fifty (50%) percent of 

the true cash value of the Property on December 31, 2025, contrary to Article 9, Section 

3, of the Michigan Constitution and MCL §211.27. 

10. 

Based upon the foregoing, the Petition contends that the values of the Property 

identified above should not exceed: 

Tax Year 

Parcel Nos. 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

76-24-36-477-002 

$691,220.00 

$345,610.00 

$345,610.00 

2026 

76-24-36-477-003 

$678,980.00 

$339,490.00 

$339,490.00 

2026 

76-24-36-477-004 

$1,208,700.00 

$604,350.00 

$604,350.00 

2026 

76-24-36-477-005 

$821,100.00 

$410,550.00 

$410,550.00 

 

11. 

The total state equalized value amount in controversy is, therefore, Four Million 

Six Hundred Fifty-One Thousand and 00/100

Page 5

Petition

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Contour Acquisitions, a Delaware limited liability company

Home Address (No., Street, P.O. Box or Rural Route)

40950 Woodward Avenue

Suite 300

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

(248) 530-9600

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

paul@contourcompanies.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

C

M.I.

David

Last Name

Bargamian

Firm Name (if any)

Kerr, Russell and Weber, PLC

Address (No., Street, P.O. Box or Rural Route)

500 Woodward Ave

Suite 2500

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-961-0200

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

dbargamian@kerr-russell.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

4

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

15565 Northland Drive; 15530 Northland Drive; 20905 Greenfield Road; 20755 Greenfield Road

Southfield

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48075

Taxing Authority (City or Township)

City Of Southfield (OAKLAND) 

County

Oakland

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Yes

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-002

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

645580.00

Current Taxable Value as established by the Board of Review:

645580.00

What do you believe is the fair market value (also known as True Cash Value)?

691220.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

299970.00

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-003

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

634150.00

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

634150.00

What do you believe is the fair market value (also known as True Cash Value)?

678980.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

294660.00

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-004

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

1128890.00

Current Taxable Value as established by the Board of Review:

1128890.00

What do you believe is the fair market value (also known as True Cash Value)?

1208700.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

524539

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-005

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

766880.00

Current Taxable Value as established by the Board of Review:

766880.00

What do you believe is the fair market value (also known as True Cash Value)?

821100.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

356330.00

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Contour Acquisitions, a Delaware limited liability company, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001220

City Of Southfield, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 29, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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Page 1

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CONTOUR ACQUISITIONS, a 

Delaware limited liability company 

 

Petitioner 

 

 

 

 

M.T.T. Docket 

V. 

 

 

 

 

 

 

 

No. 26-________ 

 

CITY OF SOUTHFIELD, a 

Michigan public body corporate, 

 

Respondent 

 

_______________________________________________________________________/ 

 

PETITION 

 

PETITIONER, by its attorneys, Kerr, Russell & Weber, PLC, hereby petitions the 

entire tribunal against the above-named Respondent, and states as follows: 

1. 

Petitioner is a duly organized and existing Delaware limited liability company 

with its principal office located at 40950 Woodward Avenue, Suite 300, Bloomfield 

Hills, MI 48304. 

2. 

Respondent is a Michigan public body corporate. 

3. 

The parcels of land at issue are contiguous parcels of commercial real estate 

improved with 4 office buildings (collectively, the “Property”), more particularly 

described as: 

Parcel No. 

Address 

Approximate Square Footage 

76-24-36-477-002 

15565 Northland Drive 

111,600 Square Feet 

76-24-36-477-003 

15530 Northland Drive 

113,625 Square Feet 

76-24-36-477-004 

20905 Greenfield Road 

63,220 Square Feet 

76-24-36-477-005 

20755 Greenfield Road 

140,778 Square Feet

Page 2

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

4. 

The Property is classified as commercial and is located in Oakland County and the 

Oak Park Public School District. 

5. 

Because the Property is classified as commercial real estate, appeal directly to the 

Tax Tribunal is authorized by Act 174 of Public Acts of 2006. Nonetheless, Petitioner 

appeared before Respondent’s Board of Review on March 5, 2026 to protest the 

Property’s assessed and taxable values. 

6. 

The values of the Property as established by the Respondent's Board of Review 

following Petitioner’s appeal to the Board of Review are: 

Tax Year 

Parcel Nos. 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

76-24-36-477-002 

$1,291,160.00 

$645,580.00 

$645,580.00 

2026 

76-24-36-477-003 

$1,268,300.00 

$634,150.00 

$634,150.00 

2026 

76-24-36-477-004 

$2,257,780.00 

$1,128,890.00 

$1,128,890.00 

2026 

76-24-36-477-005 

$1,533,760.00 

$766,880.00 

$766,880.00 

Totals 

 

$6,351,000.00 

$3,175,500.00 

$3,175,500.00 

 

7. 

Petitioner acquired the Property from the prior owner, Northland Towers 

Associates Limited Partnership, in an arms-length transaction on December 17, 2025, for 

the full consideration of $3,400,000.00. As part of normal closing prorations, Petitioner 

reimbursed Northland Towers Associates for a portion of the December 2024 tax bill and 

the July 2025 tax bill and is responsible for payment of all tax bills rendered by the taxing 

authorities thereafter. 

8. 

In preparation for redevelopment of the Property and possible application for 

incentives under the Brownfield Redevelopment Financing Act, Act 381 of 1996, 

Petitioner obtained an Obsolescence Study of the Property prepared by Matthew J. 

Schmidt, a Michigan Master Assessing Officer (4). Mr Schmidt concluded that the

Page 3

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

Property is functionally obsolete and subject to significant impairment of functional 

capacity due to: 

a. 

the buildings are subject to substantial deferred maintenance; 

b. 

elevators in the building are old, several are inoperable, and replacement 

parts are no longer being manufactured for the units; 

 

c. 

the elevator sizes are not compliant with the Americans with Disabilities 

Act. Any renovation of the buildings would require increasing the size and 

configuration of the elevator shafts to accommodate ADA compliant 

elevators; 

 

d. 

the existing heating and cooling systems are between 50 and 60 years old 

and need to be replaced. The manufacturers no longer maintain a 

replacement parts inventory. Repairs will require salvaging parts from 

other inoperable units; 

 

e. 

bathroom doors are not ADA compliant; 

f. 

the roofs require complete recovering and structural repairs to prevent 

water leaks in the upper floors of the building; and 

 

g. 

these deficiencies make it difficult to attract tenants and is a reason that 

occupancy is only between 30% and 40%. 

 

9. 

Respondent's 2026 real property assessment and taxable value fail to take into 

consideration the following: 

a. 

The age of the subject Property; 

 

b. 

existing and projected vacancies and the length of existing vacancies; 

 

c. 

projected costs of leasehold improvements that will have to be expended in 

order to attract new tenants to the Property; 

 

d. 

the lack of current income generated by subject Property; 

 

e. 

deferred maintenance items; 

 

f. 

existing market and mortgage conditions;

Page 4

Petition to Tax Tribunal 4917-9208-7971 v.1 

4917-9208-7971, v. 1 

g. 

overall physical, economic and functional obsolescence factors; 

 

h. 

increased costs in maintaining and operating subject Property; 

 

i. 

proper depreciation factors; 

 

j. 

the marketing and sales history of this Property and sales of comparable 

properties; and 

 

k. 

adequate reserves for replacement; 

 

and, therefore, said assessment and taxable values are in excess of fifty (50%) percent of 

the true cash value of the Property on December 31, 2025, contrary to Article 9, Section 

3, of the Michigan Constitution and MCL §211.27. 

10. 

Based upon the foregoing, the Petition contends that the values of the Property 

identified above should not exceed: 

Tax Year 

Parcel Nos. 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

76-24-36-477-002 

$691,220.00 

$345,610.00 

$345,610.00 

2026 

76-24-36-477-003 

$678,980.00 

$339,490.00 

$339,490.00 

2026 

76-24-36-477-004 

$1,208,700.00 

$604,350.00 

$604,350.00 

2026 

76-24-36-477-005 

$821,100.00 

$410,550.00 

$410,550.00 

 

11. 

The total state equalized value amount in controversy is, therefore, Four Million 

Six Hundred Fifty-One Thousand and 00/100

Page 5

Petition

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Contour Acquisitions, a Delaware limited liability company

Home Address (No., Street, P.O. Box or Rural Route)

40950 Woodward Avenue

Suite 300

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

(248) 530-9600

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

paul@contourcompanies.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

C

M.I.

David

Last Name

Bargamian

Firm Name (if any)

Kerr, Russell and Weber, PLC

Address (No., Street, P.O. Box or Rural Route)

500 Woodward Ave

Suite 2500

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-961-0200

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

dbargamian@kerr-russell.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

4

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

15565 Northland Drive; 15530 Northland Drive; 20905 Greenfield Road; 20755 Greenfield Road

Southfield

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48075

Taxing Authority (City or Township)

City Of Southfield (OAKLAND) 

County

Oakland

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Yes

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-002

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

645580.00

Current Taxable Value as established by the Board of Review:

645580.00

What do you believe is the fair market value (also known as True Cash Value)?

691220.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

299970.00

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-003

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

634150.00

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

634150.00

What do you believe is the fair market value (also known as True Cash Value)?

678980.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

294660.00

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-004

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

1128890.00

Current Taxable Value as established by the Board of Review:

1128890.00

What do you believe is the fair market value (also known as True Cash Value)?

1208700.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

524539

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

76-24-36-477-005

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

766880.00

Current Taxable Value as established by the Board of Review:

766880.00

What do you believe is the fair market value (also known as True Cash Value)?

821100.00

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

356330.00

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.