Lake Forest Trail Holdings LLC, Petitioner Vs. Township Of Green Oak, Respondent

Page 1

RECEIVED 

0CT 24 2025 

MICHIG 

STATE OF MICHIGAN 

AN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Docket No. 25-008. 50 

Petitioner, 

Parcel No. 4716-03-105-028 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

880 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Entire Tribunal Property Tax Petition 

Petitioner Lake Forest Trail Holdings, 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 Lake Forest Trail Holdings, LLC, 

is 

a Michigan limited 

liability company, with its registered offices located at 801 W. Big Beaver Road, Suite

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 4716-03-105-028 and 

commonly known 

as 11395 Izik's Way, Brighton, Michigan 48116 (the “Subject 

Property”). 

4, 

The Subject Property is located in Livingston County and is within the 

Brighton Area School District. 

5. 

The Subject Property was designed for and is used for multi-family 

housing purposes. 

6. 

Respondent possesses jurisdiction to assess and collect property taxes for 

the Subject Property. 

The 2024 and 2025 Property Tax Assessments 

7. 

For tax years 2024 and 2025, Respondent classified the Subject Property 

as commercial real property. 

8. 

For tax years 2024 and 2025, Respondent initially established the 

Subject Property's assessment in the following amounts: 

Year 

TCV 

AV 

TV 

2024 

1,403,000 

701,500 

605,893 

2025 

5,472,400 

| 

2,736,200 

2,464,830 

9. 

On June 30, 2025, Respondent uncapped the Subject Property's 2024 

taxable value to equal its 2024 assessed value on the basis that the Subject Property

Page 3

Year 

TCV 

AV 

TV 

2024 

1,403,000 

701,500 

701,500 

20256 

5,472,400 

2,736,200 

2,663,401 

10. 

This Petition presents issues involving whether the Subject Property 

experienced a “transfer of ownership” as the General Property Tax Act, MCL 211.1 et 

seq. (the “GPTA”), defines that term. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as 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 tax year 2024 and 2025 assessments (a) violate 

the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on 

erroneous principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioners rights. 

Count I: Erroneous Uncapping 

12. 

For tax year 2024, Respondent uncapped the Subject Property's taxable 

value to equal its 2024 assessed value, then carried that uncapping forward to tax 

year 2025 (Notice of Uncapping attached as Exhibit A). 

13. 

The Subject Property did not experience a transaction that qualifies as a 

“transfer of ownership” during calendar year 2023 as that term is defined in the 

GPTA.

Page 4

for tax years 2024 and 2025, as provided under Const 1963, art 9, § 3, the GPTA, and 

other law. 

15. 

Respondent's uncapping of the Subject Property’s taxable value for tax 

year 2024, which was then carried to tax year 2025, is therefore an error. 

16. 

The amount of taxable value in dispute based on Respondent’s erroneous 

increase in the Subject Property's taxable value for tax years 2024 and 2025 are as 

follows: 

Year | TV in Dispute 

2024 

95,607 

2025 

98,571 

Count IT: Overestimation of Value 

17. 

Alternatively, 

Petitioner contends that 

a lawful assessment 

of the 

Subject Property for tax years 2024 and 2025 cannot exceed the following amounts:! 

Year 

TCV 

AV 

TV 

2024 

780,000 

390,000 

390,000 

20251 

2,000,000 

1,000,000 

1,000,000 

18. 

The amounts in dispute based on Respondent's overestimation of value 

for the Subject Property for tax years 2024 and 2025 are therefore as follows: 

Year 

TCV 

AV 

TV 

2024 

623,000 

311,500 

311,600 

2025 | 

3,472,400 

1,736,200 

1,663,401

Page 5

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property's 2024 and 2025 assessment to limit the 

increase in the Subject Property's taxable value as set forth in §14, or alternatively 

revising the assessment to be consistent with the values set forth in §17, and granting 

Petitioner all other relief to which it is

Page 6

E

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lake Forest Trail Holdings, LLC, 

Docket No. 25-002950 

(Consolidated into Docket No. 

Petitioner, 

25-001257) 

Parcel No. 4716-03-105-028 

v. 

Charter Township of Green Oak, 

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 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas 

states 

that 

she 

personally 

served 

copies 

of the 

Entire 

Tribunal Property Tax Petition, Notice of Docket Number, and this Proof of Service, 

on the persons listed below, by the means identified, by placing those documents in 

a duly stamped, addressed envelopes and placing the envelopes in the United States 

mail on September 26, 2025. 

Certified Mail 

Clerk 

Green Oak Township 

10001 Silver Lake Road 

Brighton, MI 48116 

Assessor 

Green Oak Township 

10001 Silver Lake Road 

Brighton, MI 48116 

First-Class Mail 

Clerk 

Livingston County 

200 E. Grand River 

Howell, MI 48843 

Director of Equalization 

Livingston County 

304 E Grand River Ave 

Howell, MI 48843 

Secretary of School Board 

Brighton Area Schools 

125 South Church Street 

Brighton, MI 48116 

State Treasurer 

Michigan Dep't of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 48922 

Vopscotbhoncd 

Monica Athanas

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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 

Lake Forest Trail Holdings LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket Nos. 25-001257 & 

 

 

 

 

 

 

 

 25-002950 

 

Green Oak Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION FOR RECONSIDERATION 

 

ORDER REINSTATING CASE 

 

ORDER OF CONSOLIDATION 

 

ORDER REMOVING MTT DOCKET NO. 25-001257 FROM JUNE 16 – 30, 2026 

PREHEARING GENERAL CALL 

 

On August 22, 2025, Petitioner filed a motion requesting that the Tribunal reconsider the 

Order of Dismissal entered in MTT Docket No. 25-002950 on August 20, 2025. In the 

motion, Petitioner states it filed a petition in MTT Docket No. 25-001257 on May 22, 

2025, challenging the subject property’s true cash, assessed, and taxable values for tax 

year 2025. However, on June 30, 2025, Petitioner received a notice of uncapping from 

Respondent stating that the subject property’s taxable value uncapped for tax year 2024 

due to an alleged transfer of ownership. As a result, Petitioner filed the subject appeal 

on July 30, 2025, to appeal the uncapping within 35 days of the notice.1 Thus, 

Petitioner asserts that the Tribunal made a palpable error by dismissing this appeal as a 

duplicative matter to MTT Docket No. 25-001257 since each docket pertains to a 

separate issue, despite regarding the same subject parcel. 

 

The Tribunal has considered the motion and the case file and finds that Petitioner has 

demonstrated a palpable error relative to the Order of Dismissal that misled the Tribunal 

and the parties and that would have resulted in a different disposition if the error was 

corrected.2 Specifically, while valuation appeals typically encompass both taxable value 

and uncapping claims, Petitioner did not have the opportunity to plead and address the 

notice of uncapping issued by Respondent in MTT Docket No. 25-001257 since the 

petition had already been filed at the time the notice of uncapping was received. As a 

result, the Tribunal erred by dismissing Petitioner’s claims regarding the uncapping of 

 

1 See, MCL 211.27b(6). 

2 See MCR 2.119(F)(3). A palpable error is one that is “easily perceptible, plain, obvious, readily visible, 

noticeable, patent, distinct, or manifest.” Luckow v Luckow, 291 Mich App 417, 426 (2011) (quotation 

marks and citation omitted).

Page 2

MTT Docket Nos. 25-001257 & 25-002950 

Page 2 of 3 

 

the taxable value of the subject parcel as they were timely filed in MTT Docket No. 25-

002950. Thus, the appeals are not duplicative in nature, and MTT 25-002950 should 

not have been dismissed as such. 

 

Further, the Tribunal has reviewed the files in MTT Docket Nos. 25-001257 and 25-

002950 and finds that it may order a consolidation of cases upon a finding of substantial 

and controlling common questions of fact or law.3 The noted dockets present common 

questions of fact and law and the parties in each of the cases are the same. As such, 

the Tribunal finds that consolidation is appropriate and will facilitate the efficient 

administration of justice. 

 

Therefore, 

 

IT IS ORDERED that Petitioner’s Motion for Reconsideration is GRANTED. 

 

IT IS FURTHER ORDERED that the MTT Docket No. 25-002950 is REINSTATED. 

 

IT IS FURTHER ORDERED that MTT Docket Nos. 25-001257 and 25-002950 are 

CONSOLIDATED. 

 

IT IS FURTHER ORDERED that all future pleadings and documents filed in these 

dockets shall refer to the consolidated case as MTT Docket No. 25-001257. 

 

IT IS FURTHER ORDERED that Petitioner shall file proof the petition filed in MTT 

Docket No. 25-002950 was served on all parties-in-interest within 28 days of the date of 

this order. 

 

IT IS FURTHER ORDERED that after Petitioner has completed service of the 

uncapping petition, Respondent shall file an amended answer addressing the claims 

from both petitions within 28 days after service of the petition for MTT Docket No. 25-

002950. 

 

IT IS FURTHER ORDERED that MTT Docket No. 25-001257 is REMOVED from the 

June 16 – 30, 2026 Prehearing General Call. 

 

The consolidated matter shall be placed on a Prehearing General Call in the normal 

course of scheduling after proof of service of the petition and amended answer are filed. 

 

 

Entered: September 10, 2025 

 

 

By _____________________________ 

cs/jc 

 

 

 

 

 

3 See MCR 2.505(A).

Page 3

MTT Docket Nos.

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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 

Lake Forest Trail Holdings LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket Nos. 25-001257 & 

 

 

 

 

 

 

 

 25-002950 

 

Green Oak Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION FOR RECONSIDERATION 

 

ORDER REINSTATING CASE 

 

ORDER OF CONSOLIDATION 

 

ORDER REMOVING MTT DOCKET NO. 25-001257 FROM JUNE 16 – 30, 2026 

PREHEARING GENERAL CALL 

 

On August 22, 2025, Petitioner filed a motion requesting that the Tribunal reconsider the 

Order of Dismissal entered in MTT Docket No. 25-002950 on August 20, 2025. In the 

motion, Petitioner states it filed a petition in MTT Docket No. 25-001257 on May 22, 

2025, challenging the subject property’s true cash, assessed, and taxable values for tax 

year 2025. However, on June 30, 2025, Petitioner received a notice of uncapping from 

Respondent stating that the subject property’s taxable value uncapped for tax year 2024 

due to an alleged transfer of ownership. As a result, Petitioner filed the subject appeal 

on July 30, 2025, to appeal the uncapping within 35 days of the notice.1 Thus, 

Petitioner asserts that the Tribunal made a palpable error by dismissing this appeal as a 

duplicative matter to MTT Docket No. 25-001257 since each docket pertains to a 

separate issue, despite regarding the same subject parcel. 

 

The Tribunal has considered the motion and the case file and finds that Petitioner has 

demonstrated a palpable error relative to the Order of Dismissal that misled the Tribunal 

and the parties and that would have resulted in a different disposition if the error was 

corrected.2 Specifically, while valuation appeals typically encompass both taxable value 

and uncapping claims, Petitioner did not have the opportunity to plead and address the 

notice of uncapping issued by Respondent in MTT Docket No. 25-001257 since the 

petition had already been filed at the time the notice of uncapping was received. As a 

result, the Tribunal erred by dismissing Petitioner’s claims regarding the uncapping of 

 

1 See, MCL 211.27b(6). 

2 See MCR 2.119(F)(3). A palpable error is one that is “easily perceptible, plain, obvious, readily visible, 

noticeable, patent, distinct, or manifest.” Luckow v Luckow, 291 Mich App 417, 426 (2011) (quotation 

marks and citation omitted).

Page 2

MTT Docket Nos. 25-001257 & 25-002950 

Page 2 of 3 

 

the taxable value of the subject parcel as they were timely filed in MTT Docket No. 25-

002950. Thus, the appeals are not duplicative in nature, and MTT 25-002950 should 

not have been dismissed as such. 

 

Further, the Tribunal has reviewed the files in MTT Docket Nos. 25-001257 and 25-

002950 and finds that it may order a consolidation of cases upon a finding of substantial 

and controlling common questions of fact or law.3 The noted dockets present common 

questions of fact and law and the parties in each of the cases are the same. As such, 

the Tribunal finds that consolidation is appropriate and will facilitate the efficient 

administration of justice. 

 

Therefore, 

 

IT IS ORDERED that Petitioner’s Motion for Reconsideration is GRANTED. 

 

IT IS FURTHER ORDERED that the MTT Docket No. 25-002950 is REINSTATED. 

 

IT IS FURTHER ORDERED that MTT Docket Nos. 25-001257 and 25-002950 are 

CONSOLIDATED. 

 

IT IS FURTHER ORDERED that all future pleadings and documents filed in these 

dockets shall refer to the consolidated case as MTT Docket No. 25-001257. 

 

IT IS FURTHER ORDERED that Petitioner shall file proof the petition filed in MTT 

Docket No. 25-002950 was served on all parties-in-interest within 28 days of the date of 

this order. 

 

IT IS FURTHER ORDERED that after Petitioner has completed service of the 

uncapping petition, Respondent shall file an amended answer addressing the claims 

from both petitions within 28 days after service of the petition for MTT Docket No. 25-

002950. 

 

IT IS FURTHER ORDERED that MTT Docket No. 25-001257 is REMOVED from the 

June 16 – 30, 2026 Prehearing General Call. 

 

The consolidated matter shall be placed on a Prehearing General Call in the normal 

course of scheduling after proof of service of the petition and amended answer are filed. 

 

 

Entered: September 10, 2025 

 

 

By _____________________________ 

cs/jc 

 

 

 

 

 

3 See MCR 2.505(A).

Page 3

MTT Docket Nos.

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Page 1

RECEIVED 

Since 1973 

WERT aos\wIWIR| P 

MICHIGAN Tax TRIB yy, Wise Willams Rtrer & Plurk, BC. 

Attorneys and Counselors 

380 North Old Woodward Avenue 

Suite 300 

August 21, 2025 

Birmingham, Michigan 48009 

Tel: (248) 642-0333 

Fax: (248) 642-0856 

Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

Lake Forest Trail Holdings, LLC v. Green Oak Twp. 

Michigan Tax Tribunal Docket No. 25-002950 

Dear Clerk: 

Enclosed with this letter for filing with the Tribunal are Petitioner's Motion 

for Reconsideration of Order of Dismissal dated August 20, 2025, and 

a Proof of 

Service. 

Also enclosed are a check for the motion fee and extra copies of the filings. 

Please time-stamp the extra copies and return them to me in the stamped, addressed 

envelope enclosed. 

Thank you and please contact me with any questions or concerns. 

» 

’ 

Sincerely, 

- 

<9 

= 

{ 

~~ 

£7 

{ 

= 

: 

) 

/ 

[ Jason C. Long ot 

ce! 

Jerome P. Pesick, Esq.

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

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 

Proof of Service

Page 3

Proof of Service 

Monica Athanas states that she personally served the Entire Tribunal Property 

Tax Petition, Notice of Docket Number, Order of Dismissal, and Petitioner's Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025, on the persons identified 

below, by the means specified, on August 21, 2025. 

Certified Mail 

First-Class Mail 

Clerk 

Clerk 

Secretary of School Board 

Green Oak Township 

Livingston County 

Brighton Area Schools 

10001 Silver Lake Road 

Brighton, MI 48116 

Assessor 

Green Oak Township 

10001 Silver Lake Road 

Brighton, MI 48116 

200 E. Grand River 

Howell, MI 48843 

Director of Equalization 

Livingston County 

304 E Grand River Ave 

Howell, MI 48843 

125 South Church Street 

Brighton, MI 48116 

State Treasurer 

Michigan Dep't of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 48922 

Stephanie Simon Morita, Esq. 

Rosati, Schultz, Joppich 

& Amtsbuechler, PC 

27555 Executive Dr., Ste. 250 

Farmington Hills, MI 48331 

A 

Mohica Athanas 

q 

This Proof of Service was signed and sworn before me on August 21, 2025. 

Su,

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

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 

Petitioner's Motion for Reconsideration 

of Order of Dismissal dated August 20, 2025 

Petitioner Lake Forest Trail Holdings, LLC, by and through its attorneys, 

Williams, Williams, Rattner & Plunkett PC, states as follows for its Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025: 

1. 

This is an appeal involving the unlawful “uncapping” of the 2024 taxable 

value of Petitioner's real property located in Green Oak Township, Livingston County 

(the “Subject Property”).

Page 5

year 2024 (the “2024 Valuation Appeal”). See Ex. A, Petitioner's “2024 Valuation 

Petition.” 

3. 

On May 22, 2025, Petitioner filed a Petition in Docket No. 25-001257 

challenging the Subject Property's true cash, assessed, and taxable values for tax 

year 2025 (the “2025 Valuation Appeal”). See Ex. B, Petitioner's “2025 Valuation 

Petition.” 

4. 

On June 30, 2025, Respondent issued a Notice of Uncapping explaining 

that Respondent had retroactively uncapped the Subject Property’s taxable value for 

tax year 2024 due to an alleged “transfer of ownership” that occurred in September 

2023. See Ex. C, Notice of Uncapping. Pursuant to MCL 211.27b(6), Petitioner had 

35 

days from 

the 

date 

of Respondent's 

Notice 

of Uncapping 

to challenge 

the 

uncapping by filing an appeal with the Tribunal. 

5. 

On July 30, 2025, Petitioner timely filed its Petition in this appeal 

challenging Respondent's unlawful uncapping of the Subject Property's taxable value 

for tax year 2024 on the grounds that the purported “transfer of ownership” was 

between commonly controlled entities under MCL 211.27a(7)(m), and therefore did 

not qualify as a “transfer of ownership” as that term is defined in MCL 211.27a(6). 

See Ex. D, Petitioner’s “2024 Uncapping Petition.” 

6.

Page 6

Petitioner

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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 

Lake Forest Trail Holdings LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket Nos. 25-001257 & 

 

 

 

 

 

 

 

 25-002950 

 

Green Oak Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION FOR RECONSIDERATION 

 

ORDER REINSTATING CASE 

 

ORDER OF CONSOLIDATION 

 

ORDER REMOVING MTT DOCKET NO. 25-001257 FROM JUNE 16 – 30, 2026 

PREHEARING GENERAL CALL 

 

On August 22, 2025, Petitioner filed a motion requesting that the Tribunal reconsider the 

Order of Dismissal entered in MTT Docket No. 25-002950 on August 20, 2025. In the 

motion, Petitioner states it filed a petition in MTT Docket No. 25-001257 on May 22, 

2025, challenging the subject property’s true cash, assessed, and taxable values for tax 

year 2025. However, on June 30, 2025, Petitioner received a notice of uncapping from 

Respondent stating that the subject property’s taxable value uncapped for tax year 2024 

due to an alleged transfer of ownership. As a result, Petitioner filed the subject appeal 

on July 30, 2025, to appeal the uncapping within 35 days of the notice.1 Thus, 

Petitioner asserts that the Tribunal made a palpable error by dismissing this appeal as a 

duplicative matter to MTT Docket No. 25-001257 since each docket pertains to a 

separate issue, despite regarding the same subject parcel. 

 

The Tribunal has considered the motion and the case file and finds that Petitioner has 

demonstrated a palpable error relative to the Order of Dismissal that misled the Tribunal 

and the parties and that would have resulted in a different disposition if the error was 

corrected.2 Specifically, while valuation appeals typically encompass both taxable value 

and uncapping claims, Petitioner did not have the opportunity to plead and address the 

notice of uncapping issued by Respondent in MTT Docket No. 25-001257 since the 

petition had already been filed at the time the notice of uncapping was received. As a 

result, the Tribunal erred by dismissing Petitioner’s claims regarding the uncapping of 

 

1 See, MCL 211.27b(6). 

2 See MCR 2.119(F)(3). A palpable error is one that is “easily perceptible, plain, obvious, readily visible, 

noticeable, patent, distinct, or manifest.” Luckow v Luckow, 291 Mich App 417, 426 (2011) (quotation 

marks and citation omitted).

Page 2

MTT Docket Nos. 25-001257 & 25-002950 

Page 2 of 3 

 

the taxable value of the subject parcel as they were timely filed in MTT Docket No. 25-

002950. Thus, the appeals are not duplicative in nature, and MTT 25-002950 should 

not have been dismissed as such. 

 

Further, the Tribunal has reviewed the files in MTT Docket Nos. 25-001257 and 25-

002950 and finds that it may order a consolidation of cases upon a finding of substantial 

and controlling common questions of fact or law.3 The noted dockets present common 

questions of fact and law and the parties in each of the cases are the same. As such, 

the Tribunal finds that consolidation is appropriate and will facilitate the efficient 

administration of justice. 

 

Therefore, 

 

IT IS ORDERED that Petitioner’s Motion for Reconsideration is GRANTED. 

 

IT IS FURTHER ORDERED that the MTT Docket No. 25-002950 is REINSTATED. 

 

IT IS FURTHER ORDERED that MTT Docket Nos. 25-001257 and 25-002950 are 

CONSOLIDATED. 

 

IT IS FURTHER ORDERED that all future pleadings and documents filed in these 

dockets shall refer to the consolidated case as MTT Docket No. 25-001257. 

 

IT IS FURTHER ORDERED that Petitioner shall file proof the petition filed in MTT 

Docket No. 25-002950 was served on all parties-in-interest within 28 days of the date of 

this order. 

 

IT IS FURTHER ORDERED that after Petitioner has completed service of the 

uncapping petition, Respondent shall file an amended answer addressing the claims 

from both petitions within 28 days after service of the petition for MTT Docket No. 25-

002950. 

 

IT IS FURTHER ORDERED that MTT Docket No. 25-001257 is REMOVED from the 

June 16 – 30, 2026 Prehearing General Call. 

 

The consolidated matter shall be placed on a Prehearing General Call in the normal 

course of scheduling after proof of service of the petition and amended answer are filed. 

 

 

Entered: September 10, 2025 

 

 

By _____________________________ 

cs/jc 

 

 

 

 

 

3 See MCR 2.505(A).

Page 3

MTT Docket Nos.

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Page 1

STEPHANIE SIMON MORITA 

smorita@rsjalaw.com 

 

27555 Executive Drive, Suite 250 

Farmington Hills, Michigan 48331 

P 248.489.4100 | F 248.489.1726 

rsjalaw.com 

 

 

 

 

 

 

 

 

September 5, 2025 

 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

 

 

Re: 

Lake Forest Trail Holdings, LLC v Township of Green Oak 

 

 

MTT Docket No. 25-002950 

 

Dear Clerk: 

 

 

Enclosed please find an Appearance of Counsel regarding the above-entitled matter. 

Please file this Appearance in your usual manner. 

 

 

Thank you for your attention to this matter. 

 

 

Very truly yours, 

 

 

ROSATI SCHULTZ JOPPICH 

 

& AMTSBUECHLER PC 

 

 

/s/ Stephanie S. Morita 

 

 

Stephanie Simon Morita 

 

 

SSM/dah 

Enclosure 

 

cc: 

Jerome P. Pesick, Esq. (by email jpesick@wwrplaw.com) 

 

Green Oak Township Officials

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Lake Forest Trail Holdings, LLC, 

 

 

Petitioner, 

v. 

 

MTT Docket No. 25-002950 

 

Township of Green Oak, 

 

 

Respondent. 

 

WILLIAMS, WILLIAMS, RATTNER & 

 PLUNKET, P.C. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

jpesick@wwrplaw.com 

ROSATI, SCHULTZ, JOPPICH 

 & AMTSBUECHLER, P.C. 

Stephanie Simon Morita (P53864) 

Matthew C. Wayne (P80542) 

Attorneys for Respondent 

27555 Executive Drive 

Suite 250 

Farmington Hills, MI 48331-3550 

(248) 489-4100 

smorita@rsjalaw.com 

mwayne@rsjalaw.com 

 

APPEARANCE OF COUNSEL 

 

The law firm of ROSATI, SCHULTZ, JOPPICH & AMTSBUECHLER, P.C., by and 

through STEPHANIE SIMON MORITA and MATTHEW C. WAYNE, hereby enters its 

Appearance as Attorneys on behalf of the Respondent, Township of Green Oak, with respect 

to the above-captioned matter. 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

ROSATI, SCHULTZ, JOPPICH 

& AMTSBUECHLER, P.C. 

 

 

 

 

 

 

 

/s/ Stephanie Simon Morita 

 

 

 

 

 

 

 

 

 

STEPHANIE SIMON MORITA (P53864) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

27555 Executive Drive, Suite 250 

 

 

 

 

 

 

Farmington Hills, MI 48331 

 

 

 

 

 

 

(248) 489-4100 

Dated: September 5, 2025

Page 3

2 

 

 

 

 

 

 

 

 

 

PROOF OF SERVICE 

 

The undersigned certified that a copy of the foregoing instrument was served 

upon all parties to the above cause to each of the attorneys and/or 

representatives of record herein by email on September 5, 2025. 

 

 

/s/ Dawn Hallman 

 

 

Dawn Hallman

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.

Page 1

RECEIVED 

Since 1973 

WERT aos\wIWIR| P 

MICHIGAN Tax TRIB yy, Wise Willams Rtrer & Plurk, BC. 

Attorneys and Counselors 

380 North Old Woodward Avenue 

Suite 300 

August 21, 2025 

Birmingham, Michigan 48009 

Tel: (248) 642-0333 

Fax: (248) 642-0856 

Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

Lake Forest Trail Holdings, LLC v. Green Oak Twp. 

Michigan Tax Tribunal Docket No. 25-002950 

Dear Clerk: 

Enclosed with this letter for filing with the Tribunal are Petitioner's Motion 

for Reconsideration of Order of Dismissal dated August 20, 2025, and 

a Proof of 

Service. 

Also enclosed are a check for the motion fee and extra copies of the filings. 

Please time-stamp the extra copies and return them to me in the stamped, addressed 

envelope enclosed. 

Thank you and please contact me with any questions or concerns. 

» 

’ 

Sincerely, 

- 

<9 

= 

{ 

~~ 

£7 

{ 

= 

: 

) 

/ 

[ Jason C. Long ot 

ce! 

Jerome P. Pesick, Esq.

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

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 

Proof of Service

Page 3

Proof of Service 

Monica Athanas states that she personally served the Entire Tribunal Property 

Tax Petition, Notice of Docket Number, Order of Dismissal, and Petitioner's Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025, on the persons identified 

below, by the means specified, on August 21, 2025. 

Certified Mail 

First-Class Mail 

Clerk 

Clerk 

Secretary of School Board 

Green Oak Township 

Livingston County 

Brighton Area Schools 

10001 Silver Lake Road 

Brighton, MI 48116 

Assessor 

Green Oak Township 

10001 Silver Lake Road 

Brighton, MI 48116 

200 E. Grand River 

Howell, MI 48843 

Director of Equalization 

Livingston County 

304 E Grand River Ave 

Howell, MI 48843 

125 South Church Street 

Brighton, MI 48116 

State Treasurer 

Michigan Dep't of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 48922 

Stephanie Simon Morita, Esq. 

Rosati, Schultz, Joppich 

& Amtsbuechler, PC 

27555 Executive Dr., Ste. 250 

Farmington Hills, MI 48331 

A 

Mohica Athanas 

q 

This Proof of Service was signed and sworn before me on August 21, 2025. 

Su,

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

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 

Petitioner's Motion for Reconsideration 

of Order of Dismissal dated August 20, 2025 

Petitioner Lake Forest Trail Holdings, LLC, by and through its attorneys, 

Williams, Williams, Rattner & Plunkett PC, states as follows for its Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025: 

1. 

This is an appeal involving the unlawful “uncapping” of the 2024 taxable 

value of Petitioner's real property located in Green Oak Township, Livingston County 

(the “Subject Property”).

Page 5

year 2024 (the “2024 Valuation Appeal”). See Ex. A, Petitioner's “2024 Valuation 

Petition.” 

3. 

On May 22, 2025, Petitioner filed a Petition in Docket No. 25-001257 

challenging the Subject Property's true cash, assessed, and taxable values for tax 

year 2025 (the “2025 Valuation Appeal”). See Ex. B, Petitioner's “2025 Valuation 

Petition.” 

4. 

On June 30, 2025, Respondent issued a Notice of Uncapping explaining 

that Respondent had retroactively uncapped the Subject Property’s taxable value for 

tax year 2024 due to an alleged “transfer of ownership” that occurred in September 

2023. See Ex. C, Notice of Uncapping. Pursuant to MCL 211.27b(6), Petitioner had 

35 

days from 

the 

date 

of Respondent's 

Notice 

of Uncapping 

to challenge 

the 

uncapping by filing an appeal with the Tribunal. 

5. 

On July 30, 2025, Petitioner timely filed its Petition in this appeal 

challenging Respondent's unlawful uncapping of the Subject Property's taxable value 

for tax year 2024 on the grounds that the purported “transfer of ownership” was 

between commonly controlled entities under MCL 211.27a(7)(m), and therefore did 

not qualify as a “transfer of ownership” as that term is defined in MCL 211.27a(6). 

See Ex. D, Petitioner’s “2024 Uncapping Petition.” 

6.

Page 6

Petitioner

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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

Lake Forest Trail Holdings LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002950

Township Of Green Oak,

Respondent.

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that:

The issue in this case is already pending in another case and, as such, this appeal is 

duplicative and shall be dismissed. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal.

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If

Page 2

MTT Docket No. 25-002950

Page 2 of 6

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

By:___________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 20, 2025

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

Page 3

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

Lake Forest Trail Holdings LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002950

Township Of Green Oak,

Respondent.

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that:

The issue in this case is already pending in another case and, as such, this appeal is 

duplicative and shall be dismissed. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled

Page 4

MTT

Page 5

STATE

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

LAKE FOREST TRAIL HOLDINGS, LLC, 

 

 

 

 

 

 

 

 

Docket No. 25- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 4716-03-105-028 

v. 

 

TOWNSHIP OF GREEN OAK, 

 

 

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 Lake Forest Trail Holdings, 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 Lake Forest Trail Holdings, LLC, is a Michigan limited 

liability company, with its registered offices located at 801 W. Big Beaver Road, Suite 

402, Troy, MI 48084. 

2. 

Respondent the Charter Township of Green Oak is a Michigan township 

with its principal offices located at 10001 Silver Lake Road, Brighton, MI 48116.

Page 2

2 

 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 4716-03-105-028 and 

commonly known as 11395 Izik's Way, Brighton, Michigan 48116 (the “Subject 

Property”). 

4. 

The Subject Property is located in Livingston County and is within the 

Brighton Area School District. 

5. 

The Subject Property was designed for and is used for multi-family 

housing purposes. 

6. 

Respondent possesses jurisdiction to assess and collect property taxes for 

the Subject Property. 

The 2024 and 2025 Property Tax Assessments 

7. 

For tax years 2024 and 2025, Respondent classified the Subject Property 

as commercial real property. 

8. 

For tax years 2024 and 2025, Respondent initially established the 

Subject Property’s assessment in the following amounts: 

Year 

TCV 

AV 

TV 

2024 

 1,403,000 

 701,500 

 605,893 

2025 

 5,472,400 

 2,736,200 

 2,464,830 

 

9. 

On June 30, 2025, Respondent uncapped the Subject Property’s 2024 

taxable value to equal its 2024 assessed value on the basis that the Subject Property 

had experienced a “transfer of ownership” during calendar year 2023 (See Exhibit A), 

then carried that uncapping forward to tax year 2025, thereby establishing the 

Subject Property’s 2024 and 2025 assessments in the following amounts:

Page 3

3 

 

Year 

TCV 

AV 

TV 

2024 

 1,403,000 

 701,500 

 701,500 

2025 

 5,472,400 

 2,736,200 

 2,563,401 

 

10. 

This Petition presents issues involving whether the Subject Property 

experienced a “transfer of ownership” as the General Property Tax Act, MCL 211.1 et 

seq. (the “GPTA”), defines that term. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as 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 tax year 2024 and 2025 assessments (a) violate 

the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on 

erroneous principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioner’s rights. 

Count I: Erroneous Uncapping 

 

12. 

For tax year 2024, Respondent uncapped the Subject Property’s taxable 

value to equal its 2024 assessed value, then carried that uncapping forward to tax 

year 2025 (Notice of Uncapping attached as Exhibit A). 

13. 

The Subject Property did not experience a transaction that qualifies as a 

“transfer of ownership” during calendar year 2023 as that term is defined in the 

GPTA. 

14. 

Accordingly, the Subject Property’s 2024 and 2025 taxable values cannot 

exceed $605,893 and $2,464,830, respectively, based on the inflation rate multipliers

Page 4

4 

 

for tax years 2024 and 2025, as provided under Const 1963, art 9, § 3, the GPTA, and 

other law. 

15. 

Respondent’s uncapping of the Subject Property’s taxable value for tax 

year 2024, which was then carried to tax year 2025, is therefore an error. 

16. 

The amount of taxable value in dispute based on Respondent’s erroneous 

increase in the Subject Property’s taxable value for tax years 2024 and 2025 are as 

follows: 

Year 

TV in Dispute 

2024 

95,607 

2025 

98,571 

 

Count II: Overestimation of Value 

17. 

Alternatively, Petitioner contends that a lawful assessment of the 

Subject Property for tax years 2024 and 2025 cannot exceed the following amounts:1 

Year 

TCV 

AV 

TV 

2024 

 780,000 

 390,000 

 390,000 

2025 

 2,000,000 

 1,000,000

Page 5

5

Page 6

Exhibit A

Page 7

EN

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.

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

Lake Forest Trail Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002950

Township Of Green Oak, 

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 19, 2025

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

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.

Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

LAKE FOREST TRAIL HOLDINGS, LLC, 

 

 

 

 

 

 

 

 

Docket No. 25- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 4716-03-105-028 

v. 

 

TOWNSHIP OF GREEN OAK, 

 

 

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 Lake Forest Trail Holdings, 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 Lake Forest Trail Holdings, LLC, is a Michigan limited 

liability company, with its registered offices located at 801 W. Big Beaver Road, Suite 

402, Troy, MI 48084. 

2. 

Respondent the Charter Township of Green Oak is a Michigan township 

with its principal offices located at 10001 Silver Lake Road, Brighton, MI 48116.

Page 2

2 

 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 4716-03-105-028 and 

commonly known as 11395 Izik's Way, Brighton, Michigan 48116 (the “Subject 

Property”). 

4. 

The Subject Property is located in Livingston County and is within the 

Brighton Area School District. 

5. 

The Subject Property was designed for and is used for multi-family 

housing purposes. 

6. 

Respondent possesses jurisdiction to assess and collect property taxes for 

the Subject Property. 

The 2024 and 2025 Property Tax Assessments 

7. 

For tax years 2024 and 2025, Respondent classified the Subject Property 

as commercial real property. 

8. 

For tax years 2024 and 2025, Respondent initially established the 

Subject Property’s assessment in the following amounts: 

Year 

TCV 

AV 

TV 

2024 

 1,403,000 

 701,500 

 605,893 

2025 

 5,472,400 

 2,736,200 

 2,464,830 

 

9. 

On June 30, 2025, Respondent uncapped the Subject Property’s 2024 

taxable value to equal its 2024 assessed value on the basis that the Subject Property 

had experienced a “transfer of ownership” during calendar year 2023 (See Exhibit A), 

then carried that uncapping forward to tax year 2025, thereby establishing the 

Subject Property’s 2024 and 2025 assessments in the following amounts:

Page 3

3 

 

Year 

TCV 

AV 

TV 

2024 

 1,403,000 

 701,500 

 701,500 

2025 

 5,472,400 

 2,736,200 

 2,563,401 

 

10. 

This Petition presents issues involving whether the Subject Property 

experienced a “transfer of ownership” as the General Property Tax Act, MCL 211.1 et 

seq. (the “GPTA”), defines that term. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as 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 tax year 2024 and 2025 assessments (a) violate 

the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on 

erroneous principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioner’s rights. 

Count I: Erroneous Uncapping 

 

12. 

For tax year 2024, Respondent uncapped the Subject Property’s taxable 

value to equal its 2024 assessed value, then carried that uncapping forward to tax 

year 2025 (Notice of Uncapping attached as Exhibit A). 

13. 

The Subject Property did not experience a transaction that qualifies as a 

“transfer of ownership” during calendar year 2023 as that term is defined in the 

GPTA. 

14. 

Accordingly, the Subject Property’s 2024 and 2025 taxable values cannot 

exceed $605,893 and $2,464,830, respectively, based on the inflation rate multipliers

Page 4

4 

 

for tax years 2024 and 2025, as provided under Const 1963, art 9, § 3, the GPTA, and 

other law. 

15. 

Respondent’s uncapping of the Subject Property’s taxable value for tax 

year 2024, which was then carried to tax year 2025, is therefore an error. 

16. 

The amount of taxable value in dispute based on Respondent’s erroneous 

increase in the Subject Property’s taxable value for tax years 2024 and 2025 are as 

follows: 

Year 

TV in Dispute 

2024 

95,607 

2025 

98,571 

 

Count II: Overestimation of Value 

17. 

Alternatively, Petitioner contends that a lawful assessment of the 

Subject Property for tax years 2024 and 2025 cannot exceed the following amounts:1 

Year 

TCV 

AV 

TV 

2024 

 780,000 

 390,000 

 390,000 

2025 

 2,000,000 

 1,000,000

Page 5

5

Page 6

Exhibit A

Page 7

EN

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.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

LAKE FOREST TRAIL HOLDINGS, LLC

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

801 W. Big Beaver Road

Suite 402

City or Town

Troy

State

Michigan

ZIP Code

48084

Telephone Number

248-642-0333

Fax Number

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

jpesick@wwrplaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

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

380 N Old Woodward Ave

Suite 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-642-0333

Fax Number

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

jpesick@wwrplaw.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

11395 Izik's Way

Brighton

Michigan

48116

Taxing Authority (City or Township)

Township Of Green Oak (LIVINGSTON)

County

Livingston

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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values, Uncapping of Taxable Value

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

4716-03-105-028

Classification of Property: Real 

Commercial

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

701500

Current Taxable Value as established by the Board of Review:

701500

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

623000

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

311500

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

311500

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

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STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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 will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jerome P. Pesick

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