Ghafari Properties LLC Petitioner Vs. City Of Birmingham Respondent
- Petitioner
- Ghafari Properties LLC
- Respondent
- City Of Birmingham
Case overview
- Docket number
- 26-001459-TT
- Status
- Ready Schedule
- CaseType
- ET Property
- Division
- ET
- County
- Oakland
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 9 | Motion for Costs was received. | RESP | Not recorded | 10/23/2026 | $0.00 | Download |
| 8 | Motion to Compel was received. | RESP | Not recorded | 10/23/2026 | $0.00 | Download |
| 7 | Documentation | RESP | Not recorded | 10/23/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 6 | Motion for Immediate Consideration was received. | RESP | Not recorded | 10/23/2026 | $100.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 5 | Answer was received | RESP | Not recorded | 09/03/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Petition has been verified | PET | 1 | 08/13/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 08/13/2026 | Not recorded | Download |
| 2 | Proof of service of petition was received. | Not recorded | Not recorded | 08/06/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/26/2026 | $600.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Ghafari Properties LLC, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 26-001459 Parcel No. 08-19-25-178-001 _____________________________________________________________________________/ MOTION TO COMPEL PETITIONER’S DISCOVERY RESPONSES, SCHEDULE A HEARING OR IN THE ALTERNATIVE ISSUE AN ORDER TO COMPEL, AND FOR FEES AND SANCTIONS FOR IMMEDIATE CONSIDERATION NOW COMES Respondent, City of Birmingham, through its attorneys, Beier Howlett, P.C., brings this motion under TTR 247 and MCR 2.313(A), and submits the following Motion: 1. Petitioner initiated the case and served its Notice of docket number on September 13, 2025. 2. Respondent answered the petition on October 7, 2025. 3. Respondent served its Request for Production of Documents to Petitioner (“Discovery Requests”) on September 18, 2026. See Exhibit A. 4. Specifically, Respondent served the following Discovery Requests:
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(a) REQUEST FOR PRODUCTION NO. 1: Produce all income/expense statements and Rent rolls for 2023, 2024, and 2025 for the subject property. (b) REQUEST FOR PRODUCTION NO. 2: Produce all lease rental and occupancy agreements for all tenants at the subject property during 2023, 2024 and 2025, and all formal and informal lease offers submitted by or to Petitioner during those years. (c) REQUEST FOR PRODUCTION NO. 3: Produce all marketing materials utilized during the years 2023, 2024, and 2025 including listed lease rates and lease terms. (d) REQUEST FOR PRODUCTION NO. 4: Produce all sale listing information from the past 5 years for the subject property, including documents with marketing details as to the listing, sale price and days on market; formal or informal purchase offers; and any appraisals, broker opinions of value, or other valuation reports related to the property. (e) REQUEST FOR PRODUCTION NO. 5: All agreement(s) for the sale or other transfer in ownership of the subject property, or any portion thereof, together with all settlement statements, transfer affidavits, and other documents delivered in connection with the closing on the sale. (f) REQUEST FOR PRODUCTION NO. 6: Produce any and all deeds and other transfer documents from the past 5 years for the subject property. (g) REQUEST FOR PRODUCTION NO. 7: With respect to the condition of the building constructed on the property, for the past 5 years to the present, produce the following: a. Property condition/inspection reports;
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b. Details of any renovations, capital improvements, or repairs, and remediation; c. Actual costs or quotes for any construction, renovations, capital improvements, or repairs and remediation; and d. Insurance policies and/or similar documents reflecting replacement cost estimates. 5. Petitioner has not submitted any response or documents responsive to the Discovery Requests, which were due on October 16, 2026. 6. It is now past the due date for Petitioner’s responses, and Petitioner has failed to respond and produce responsive documents. 7. On October 19, 2026, forwarded this Motion to Petitioner and inquired as to whether Petitioner intended to respond, per TTR 231. See Exhibit B. No response was provided. 8. The Discovery Requests are limited in scope and required for Respondent to prepare for trial of this case. WHEREFORE, Respondent respectfully requests this Tribunal to: A. Take immediate consideration of this Motion. B. Set an oral hearing on the Motion or to issue an order to compel discovery responses. C. Award costs, attorney fees, and any other sanctions or relief that this Tribunal deems necessary.
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Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 23, 2026 248-282-1069/
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STATE OF
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Ghafari Properties LLC, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 26-001459 Parcel No. 08-19-25-178-001 _____________________________________________________________________________/ MOTION TO COMPEL PETITIONER’S DISCOVERY RESPONSES, SCHEDULE A HEARING OR IN THE ALTERNATIVE ISSUE AN ORDER TO COMPEL, AND FOR FEES AND SANCTIONS FOR IMMEDIATE CONSIDERATION NOW COMES Respondent, City of Birmingham, through its attorneys, Beier Howlett, P.C., brings this motion under TTR 247 and MCR 2.313(A), and submits the following Motion: 1. Petitioner initiated the case and served its Notice of docket number on September 13, 2025. 2. Respondent answered the petition on October 7, 2025. 3. Respondent served its Request for Production of Documents to Petitioner (“Discovery Requests”) on September 18, 2026. See Exhibit A. 4. Specifically, Respondent served the following Discovery Requests:
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(a) REQUEST FOR PRODUCTION NO. 1: Produce all income/expense statements and Rent rolls for 2023, 2024, and 2025 for the subject property. (b) REQUEST FOR PRODUCTION NO. 2: Produce all lease rental and occupancy agreements for all tenants at the subject property during 2023, 2024 and 2025, and all formal and informal lease offers submitted by or to Petitioner during those years. (c) REQUEST FOR PRODUCTION NO. 3: Produce all marketing materials utilized during the years 2023, 2024, and 2025 including listed lease rates and lease terms. (d) REQUEST FOR PRODUCTION NO. 4: Produce all sale listing information from the past 5 years for the subject property, including documents with marketing details as to the listing, sale price and days on market; formal or informal purchase offers; and any appraisals, broker opinions of value, or other valuation reports related to the property. (e) REQUEST FOR PRODUCTION NO. 5: All agreement(s) for the sale or other transfer in ownership of the subject property, or any portion thereof, together with all settlement statements, transfer affidavits, and other documents delivered in connection with the closing on the sale. (f) REQUEST FOR PRODUCTION NO. 6: Produce any and all deeds and other transfer documents from the past 5 years for the subject property. (g) REQUEST FOR PRODUCTION NO. 7: With respect to the condition of the building constructed on the property, for the past 5 years to the present, produce the following: a. Property condition/inspection reports;
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b. Details of any renovations, capital improvements, or repairs, and remediation; c. Actual costs or quotes for any construction, renovations, capital improvements, or repairs and remediation; and d. Insurance policies and/or similar documents reflecting replacement cost estimates. 5. Petitioner has not submitted any response or documents responsive to the Discovery Requests, which were due on October 16, 2026. 6. It is now past the due date for Petitioner’s responses, and Petitioner has failed to respond and produce responsive documents. 7. On October 19, 2026, forwarded this Motion to Petitioner and inquired as to whether Petitioner intended to respond, per TTR 231. See Exhibit B. No response was provided. 8. The Discovery Requests are limited in scope and required for Respondent to prepare for trial of this case. WHEREFORE, Respondent respectfully requests this Tribunal to: A. Take immediate consideration of this Motion. B. Set an oral hearing on the Motion or to issue an order to compel discovery responses. C. Award costs, attorney fees, and any other sanctions or relief that this Tribunal deems necessary.
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Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 23, 2026 248-282-1069/
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STATE OF
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Ghafari Properties LLC, Petitioner, vs. City of Birmingham, MTT Docket No. 26-001459 Parcel No. 08-19-25-178-001 Respondent. _____________________________________________________________________________/ MOTION TO COMPEL PETITIONER’S DISCOVERY RESPONSES, SCHEDULE A HEARING OR IN THE ALTERNATIVE ISSUE AN ORDER TO COMPEL, AND FOR FEES AND SANCTIONS FOR IMMEDIATE CONSIDERATION Corrected Exhibit B
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Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 23, 2026 248-282-1069/ mgibbons@bhlaw.us.com
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EXHIBIT B
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October 19, 2026 VIA EMAIL Joshua T. Shillair, Esq Colliers International 400 W 4th St., Suite 350 Royal Oak, MI 48067 tax.efile@colliers.com Re: Ghafari Properties, LLC v City of Birmingham MTT Docket No. 26-001459 Dear Mr. Shillair: We served our Request for Production on September 18, 2026. We still have not received any responses which were due on October 16, 2026. Enclosed is the Motion to Compel Discovery Responses and Brief in support that we intend to file with the Tax Tribunal. In accordance with TTR 231, please advise immediately whether Petitioner will be filing a response to the Motion to Compel. Sincerely, BEIER HOWLETT, P.C. Michael C. Gibbons Michael C. Gibbons MCG/em
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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: 26-001459 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Documentation Attachment File Name: Corrected ex Motion to Compel Discovery Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Ghafari Properties LLC, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 26-001459 Parcel No. 08-19-25-178-001 _____________________________________________________________________________/ MOTION TO COMPEL PETITIONER’S DISCOVERY RESPONSES, SCHEDULE A HEARING OR IN THE ALTERNATIVE ISSUE AN ORDER TO COMPEL, AND FOR FEES AND SANCTIONS FOR IMMEDIATE CONSIDERATION NOW COMES Respondent, City of Birmingham, through its attorneys, Beier Howlett, P.C., brings this motion under TTR 247 and MCR 2.313(A), and submits the following Motion: 1. Petitioner initiated the case and served its Notice of docket number on September 13, 2025. 2. Respondent answered the petition on October 7, 2025. 3. Respondent served its Request for Production of Documents to Petitioner (“Discovery Requests”) on September 18, 2026. See Exhibit A. 4. Specifically, Respondent served the following Discovery Requests:
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(a) REQUEST FOR PRODUCTION NO. 1: Produce all income/expense statements and Rent rolls for 2023, 2024, and 2025 for the subject property. (b) REQUEST FOR PRODUCTION NO. 2: Produce all lease rental and occupancy agreements for all tenants at the subject property during 2023, 2024 and 2025, and all formal and informal lease offers submitted by or to Petitioner during those years. (c) REQUEST FOR PRODUCTION NO. 3: Produce all marketing materials utilized during the years 2023, 2024, and 2025 including listed lease rates and lease terms. (d) REQUEST FOR PRODUCTION NO. 4: Produce all sale listing information from the past 5 years for the subject property, including documents with marketing details as to the listing, sale price and days on market; formal or informal purchase offers; and any appraisals, broker opinions of value, or other valuation reports related to the property. (e) REQUEST FOR PRODUCTION NO. 5: All agreement(s) for the sale or other transfer in ownership of the subject property, or any portion thereof, together with all settlement statements, transfer affidavits, and other documents delivered in connection with the closing on the sale. (f) REQUEST FOR PRODUCTION NO. 6: Produce any and all deeds and other transfer documents from the past 5 years for the subject property. (g) REQUEST FOR PRODUCTION NO. 7: With respect to the condition of the building constructed on the property, for the past 5 years to the present, produce the following: a. Property condition/inspection reports;
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b. Details of any renovations, capital improvements, or repairs, and remediation; c. Actual costs or quotes for any construction, renovations, capital improvements, or repairs and remediation; and d. Insurance policies and/or similar documents reflecting replacement cost estimates. 5. Petitioner has not submitted any response or documents responsive to the Discovery Requests, which were due on October 16, 2026. 6. It is now past the due date for Petitioner’s responses, and Petitioner has failed to respond and produce responsive documents. 7. On October 19, 2026, forwarded this Motion to Petitioner and inquired as to whether Petitioner intended to respond, per TTR 231. See Exhibit B. No response was provided. 8. The Discovery Requests are limited in scope and required for Respondent to prepare for trial of this case. WHEREFORE, Respondent respectfully requests this Tribunal to: A. Take immediate consideration of this Motion. B. Set an oral hearing on the Motion or to issue an order to compel discovery responses. C. Award costs, attorney fees, and any other sanctions or relief that this Tribunal deems necessary.
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Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 23, 2026 248-282-1069/
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STATE OF
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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: 26-001459 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Motion for Immediate Consideration Attachment File Name: Motion to Compel Discovery Fee Information Filing Fee: $ 100.00 Payment Information Payment: $ 100.00
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Ghafari Properties LLC, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 26-001459 Parcel No. 08-19-25-178-001 _____________________________________________________________________________/ ANSWER TO PETITION Respondent City of Birmingham, through its attorneys, Beier Howlett, P.C., responds to the allegations made in the Petition as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Neither admit nor deny as Respondent is without sufficient information and therefore, Respondent leaves Petitioner to its proofs. 8. Neither admit nor deny as Respondent is without sufficient information and therefore, Respondent leaves Petitioner to its proofs. 9. Admitted.
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10. Respondent denies all of the allegations in this paragraph. 11. It is admitted that Petitioner seeks the values stated in this paragraph. Respondent denies that the requested values are appropriate or accurate. 12. Respondent admits that the amounts recited reflect Petitioner’s position as to the values in dispute, but denies any valid amount in dispute. 13. Respondent denies that Petitioner is entitled to any relief as requested in this paragraph. WHEREFORE, Respondent City of Birmingham requests that 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. Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: September 1, 2026 248-282-1069/ mgibbons@bhlaw.us.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Ghafari Properties LLC, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 25-002107 Parcel No. 08-19-25-178-001 _____________________________________________________________________________/ PROOF OF SERVICE On the date below I sent a copy of this Answer to: Attn: Joshua T. Shillair, Esq Colliers International 400 W 4th St., Suite 350 Royal Oak, MI 48067 Joshua.Shillair@Colliers.com I declare that the statements above are true and to the best of my information, knowledge and belief. /s/ Erin Miller Erin Miller Dated: September 1, 2026
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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. 26-001459 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Birmingham (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 Michael M.I. C. Last Name Gibbons Firm Name (if any) Beier Howlett P.C. Address (No., Street, P.O. Box or Rural Route) 3001 W. Big Beaver Rd. Suite 600 City or Town Troy State Michigan ZIP Code 48084 Telephone Number 2482821069 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) mgibbons@bhlaw.us.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Michael C. Gibbons /s/
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v City of Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: Page 1 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL GHAFARI PROPERTIES LLC, Petitioner, v MTT Docket No. City of Birmingham, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com City of Birmingham Assessing Office 151 Martin Street P.O. Box 3001 Birmingham, Michigan 48012. (248) 530-1800 _____________________________________________________________________________/ 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. The Petitioner in this matter, GHAFARI PROPERTIES LLC, has the legal residence or principal office address of 36101 WOODWARD AVE,BIRMINGHAM, MI 48009-0941. Petitioner is a party in interest with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject Property) 08-19-25-178-001. If the Subject Property in this petition includes more than one (1) real property tax parcel, the Subject Property’s tax parcels are contiguous. 2. The Subject Property is located in Oakland County.
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v City of Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: Page 2 of 5 3. Respondent, City of Birmingham of Oakland County, assesses and collects property taxes on the Subject Property. 4. The Subject Property is real property and is classified as Commercial. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. Protest to the 2026 Board of Review was not made and is not required by law for the Subject Property. 6. The Subject Property’s address is: 36101 WOODWARD AVE, BIRMINGHAM, MI 48009-0941 7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. 8. The tax year(s) at issue are: 2026 9. The values for the Subject Property as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 08-19-25-178- 001 $7,725,040.00 $3,862,520.00 $1,697,680.0 0 10. The 2026 assessment, assessed value, state equalized value and taxable value imposed upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: a. The assessment, assessed value, state equalized value and/or taxable value exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law;
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v City of Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: Page 3 of 5 b. The assessment, assessed value, state equalized value and/or taxable value are at higher percentages of true cash value than permissible under the Michigan Constitution, applicable statutes and case law; c. The assessment, assessed value, state equalized value and/or taxable value are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and d. The assessment, assessed value, state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and denies Petitioner its constitutional rights to uniformity, equal
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2026 Entire
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2
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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 GHAFARI PROPERTIES LLC Home Address (No., Street, P.O. Box or Rural Route) 36101 WOODWARD AVE City or Town BIRMINGHAM State California ZIP Code 48009-0941 Telephone Number 2482261632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Joshua M.I. Thomas Last Name Shillair Firm Name (if any) Colliers International Address (No., Street, P.O. Box or Rural Route) 400 W 4th Street, Suite 350 City or Town Royal Oak State Michigan ZIP Code 48067 Telephone Number 248-226-1632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 36101 WOODWARD AVE BIRMINGHAM
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48009-0941 Taxing Authority (City or Township) City Of Birmingham (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.) N/A 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: 08-19-25-178-001 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: 3862520 Current Taxable Value as established by the Board of Review: 1697680 What do you believe is the fair market value (also known as True Cash Value)? 2328800 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 1164399 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 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.
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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 will serve as your signature Petitioner or Attorney/Authorized Representative’s Signature: /s/ /s/Joshua T. Shillair Payment Information Amount: 600 Success: True Message: "" Waiver Code: Transaction Number: 26052686964711 Supporting Waiver Documents:
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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 Ghafari Properties LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001459 City Of Birmingham, 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: August 13, 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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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 Ghafari Properties LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001459 City Of Birmingham, 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: August 13, 2026 PROOF OF SERVICE I certify that
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: 26-001459 Page 1 of 2 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL GHAFARI PROPERTIES LLC, Petitioner, v MTT Docket No. 26-001459 BIRMINGHAM, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Senior Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com City of Birmingham Assessing Office 151 Martin Street P.O. Box 3001 Birmingham, Michigan 48012. (248) 530-1800 _____________________________________________________________________________/ PROOF OF SERVICE STATE OF MICHIGAN ) )ss COUNTY OF OAKLAND ) Jennifer Lunsford, states that on 8/6/2026, in compliance with TTR 221, she did place in the US mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number as well as this Proof of Service of Petition for the above captioned appeal to the units of government listed on the second page of this Proof of Service of Petition. /s/Jennifer Lunsford Jennifer Lunsford Karen Cameron states that she submitted electronically on 8/6/2026, to the Michigan Tax Tribunal a copy of this Proof of Service of Petition at eFile through www.etaxappeal.lara.state.mi.us. /s/Karen Cameron Karen Cameron
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: 26-001459 Page 2 of 2 By Certified Mail Assessor’s Office City of Birmingham Assessing Office P.O. Box 3001 Birmingham, Michigan 48012. Office of the City/Township Clerk Birmingham Clerk's Office 151 Martin Street Birmingham, MI 48009 By First Class Mail Director of Equalization Oakland County Equalization Director 250 Elizabeth Lake Road, Suite 1000W Pontiac, MI 48341 County Clerk’s Office Oakland County Clerk’s Office 1200 N Telegraph Road Pontiac, MI 48341 Secretary of the School Board Birmingham Public Schools 31301 Evergreen Road Beverly Hills, MI 48025 Treasurer for the State of Michigan Michigan Department of Treasury Lansing, MI 48922
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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: 26-001459 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: POS_GHAFARI_PROPERTIES_LLC_26-001459 Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v City of Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: Page 1 of 5 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL GHAFARI PROPERTIES LLC, Petitioner, v MTT Docket No. City of Birmingham, Respondent. _____________________________________________________________________________/ Colliers International By: Joshua T. Shillair, Esq. (P72674) Vice President | Tax Appeal Representative for Petitioner 400 W 4th Street, Suite 350 Royal Oak, MI 48067 O: 248-226-1632 F: 248-226-1633 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com City of Birmingham Assessing Office 151 Martin Street P.O. Box 3001 Birmingham, Michigan 48012. (248) 530-1800 _____________________________________________________________________________/ 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. The Petitioner in this matter, GHAFARI PROPERTIES LLC, has the legal residence or principal office address of 36101 WOODWARD AVE,BIRMINGHAM, MI 48009-0941. Petitioner is a party in interest with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject Property) 08-19-25-178-001. If the Subject Property in this petition includes more than one (1) real property tax parcel, the Subject Property’s tax parcels are contiguous. 2. The Subject Property is located in Oakland County.
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v City of Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: Page 2 of 5 3. Respondent, City of Birmingham of Oakland County, assesses and collects property taxes on the Subject Property. 4. The Subject Property is real property and is classified as Commercial. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. Protest to the 2026 Board of Review was not made and is not required by law for the Subject Property. 6. The Subject Property’s address is: 36101 WOODWARD AVE, BIRMINGHAM, MI 48009-0941 7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. 8. The tax year(s) at issue are: 2026 9. The values for the Subject Property as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 08-19-25-178- 001 $7,725,040.00 $3,862,520.00 $1,697,680.0 0 10. The 2026 assessment, assessed value, state equalized value and taxable value imposed upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: a. The assessment, assessed value, state equalized value and/or taxable value exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law;
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2026 Entire Tribunal Property Tax Petition & Proof of Service GHAFARI PROPERTIES LLC v City of Birmingham Parcel Number: 08-19-25-178-001 MTT Docket No.: Page 3 of 5 b. The assessment, assessed value, state equalized value and/or taxable value are at higher percentages of true cash value than permissible under the Michigan Constitution, applicable statutes and case law; c. The assessment, assessed value, state equalized value and/or taxable value are based upon an erroneous determination of the true cash value of that portion of the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and d. The assessment, assessed value, state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and denies Petitioner its constitutional rights to uniformity, equal
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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 GHAFARI PROPERTIES LLC Home Address (No., Street, P.O. Box or Rural Route) 36101 WOODWARD AVE City or Town BIRMINGHAM State California ZIP Code 48009-0941 Telephone Number 2482261632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Joshua M.I. Thomas Last Name Shillair Firm Name (if any) Colliers International Address (No., Street, P.O. Box or Rural Route) 400 W 4th Street, Suite 350 City or Town Royal Oak State Michigan ZIP Code 48067 Telephone Number 248-226-1632 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tax.efile@colliers.com Section 3: Issue Please designate one: Valuation Section 4: Subject Property Information How many parcels are you appealing? 1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 36101 WOODWARD AVE BIRMINGHAM
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 48009-0941 Taxing Authority (City or Township) City Of Birmingham (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.) N/A 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: 08-19-25-178-001 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: 3862520 Current Taxable Value as established by the Board of Review: 1697680 What do you believe is the fair market value (also known as True Cash Value)? 2328800 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 1164399 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 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.
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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 will serve as your signature Petitioner or Attorney/Authorized Representative’s Signature: /s/ /s/Joshua T. Shillair Payment Information Amount: 600 Success: True Message: "" Waiver Code: Transaction Number: 26052686964711 Supporting Waiver Documents:
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