Susan Solomon Petitioner V City Of Southfield Respondent

Page 1

Kenneth Solomon

 403 Monterey Rd.

 Pacifica, CA 94044

Home Phone: (650) 738-8037 Email: fogpac@hotmail.com



 July 28, 2026



Department of Licensing and Regulatory Affairs (LARA)

Michigan Tax Tribunal

P.O. Box 30232

Lansing, MI 48909



 RE: REASONS FOR APPEAL OF 2026 ASSESSED VALUE INCREASE

 PARCEL #: 76-24-24-176-008 (Lot 135 – Meadow Downs Sub No. 1)



The subject property has been in my family’s possession since 1955, three years before Southfield

incorporated as a city. In 2024, my sister, Susan Solomon, and I became joint owners thereof.



Pertinent background



The subject property is extraordinarily unique, but not by itself. It is one of the 31 vacant, similar-

sized parcels in an unimproved 15-acre section of an otherwise fully built subdivision in Southfield.

The subdivision, Meadow Downs Subdivision No. 1, established in 1942, notably, abuts the City of

Lathrup Village, to the west, see attached EXHIBIT A. The unimproved section of Meadow Downs

No. 1, containing the subject property, is hereinafter referred to as the “subdivision.”



Each of the 31 parcels in the subdivision, historically, was separately and privately owned. The

subdivision also historically contained limited public infrastructure, e.g., an interior unimproved road

(Meadowood Road) and its right-of-way that provided two points of external access and the only

access to the frontage of each of the lots therein, see attached EXHIBIT B. Meadowood Road

connected west to the abutting neighborhood in the City of Lathrup Village and extended ½ mile

further east, through the City of Southfield, to a major arterial, Greenfield Road. And, in the 1960’s,

the City of Southfield installed limited public utilities1 within the subdivision, while imposing a

separate special assessment fee per utility to defray such costs. All such infrastructure was

historically maintained, as applicable, by each of the respective Cities, until it suddenly wasn’t.



The City of Southfield, from about 1981-1991, imposed severe development constraints on the

subdivision, as discussed further herein, all of which remain today. The City also abandoned its

road infrastructure and most of its utilities therein, while the City of Lathrup Village earlier vacated

its access road thereto. Such abandonment caused the subdivision to evolve from a wide open,

fully accessible, buildable, and build-ready development site into the current inaccessible,

impassable, and undevelopable forest, surrounded by homes, adding to the constraints.



The City of Southfield has not been a passive or neutral regulator and is the cause of the

subdivision remaining unbuilt for the past 45 years. It is also now both the largest landowner and,

effectively, the master developer therein – given it is conversely and clandestinely facilitating

development of an unspecified number of its own lots, as discussed further herein.



1 Refers to water and sewer/stormwater (combined) mains and appurtenances (e.g., fire hydrants, valve

 boxes, manholes, catch basins, etc...), separately installed in the Meadowood R-O-W within the

 subdivision. Another separate but connected water main was also installed in an easement along the

 interior side of the west boundary of the subdivision. All were installed, speculatively, between 1960-70.

Page 2

Appeal of 2026 Assessed Value Increase

 Vacant Parcel # 76-24-24-176-008

 Page 2



Ignored value-reducing factors



Severe development constraints – The uniqueness of the subject property and subdivision stems

from the City-imposed development constraints thereon, all of which are independently value-

reducing. However, the current property record card, I’ve belatedly learned, either excludes,

misrepresents, or over trivializes all such constraints, rendering the assessed value as an extreme

overvaluation of the subject property. Each of the constraints, in order of commencement, is below:



1. No public road access:



 a) Loss of west vehicular access to subdivision - 45 years ago, the west access road to the

 subdivision, in the abutting City of Lathrup Village, was discovered barricaded. It is now

 occupied by mature trees and other landscaping - see attached EXHIBIT C. The reason for

 this was unknown until discovered literally earlier this year: The City of Lathrup Village, in

 1973, had vacated said road,2 permanently eliminating the west access, notably, absent

 any objection by the City of Southfield.



 b) Loss of east vehicular access to subdivision – Also 45 years ago, the City of Southfield,

 initially inexplicably, and without notice, barricaded the east access to the subdivision,

 functionally landlocking both the subject property and subdivision since that time. Such

 “LANDLOCKED” condition was documented earlier by the City Assessor’s Office, see

 attached EXHIBIT D. Most striking, after the barricade was first discovered, the City,

 inexplicably, “refuse[d]” to remove it.3 A decade later, the City alleged it was installed to

 “prevent dumping in and around the vacant area”, see attached EXHIBIT E. The barricade,

 initially an immovable steel guardrail, was recently replaced with vehicle obstacles, see

 photos attached as EXHIBIT F.



 c) Loss of interior road & vehicular access to all interior lots - The City of Southfield also long-

 ago, inexplicably and without notice, ceased all use and maintenance of Meadowood Road

 and its right-of-way within the subdivision. This caused the road to disintegrate and

 disappear and

Page 3

Appe

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 DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 PROPERTY TAX APPEAL PETITION FORM

 VALUATION / UNCAPPING APPEAL



 MTT DOCKET NO.



 Petitioner’s Contact Information:

 Filer Type: Local Unit of Government:

 Individual



 First Name M.I. Last Name

 Susan Solomon



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

 25635 Grand Concourse St.



 City or Town State ZIP Code

 Southfield Michigan 48075



 Telephone Number

 248-557-1157



 E-mail Address

 solomons@comcast.net



 Subject Property Information:

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

 1 *If no, you must file separate appeals for each parcel



 N/A

 Property Address (No., Street)

 Meadowood Road (unimproved right-of-way)



 City or Town County State ZIP Code

 Southfield Oakland Michigan 48076



 Taxing Authority (City or Township)

 City Of Southfield (OAKLAND)



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



 True Cash and Taxable Values

 Taxable Value Only (calculation)



 Please Explain the Reason for this Appeal:



 1 of 3

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 See attached document titled "REASONS FOR APPEAL OF 2026 ASSESSED VALUE INCREASE", including associated exhibits:



 Summary of issues:



 Rebuttal of impartiality of taxing authority and accuracy of assessed value, based on each of the following:

 + Bad faith and conflicts of interest by taxing authority

 + Failure to recognize uniquessness of subject propery by excluding, misrepresenting, and/or over trivializing value-reducing factors

 + Contrary to prior independent qualified property appraisal that found, due to uniqueness and restrictive nature of subject property:

 - Highest and best use is indeterminable

 - Market approach is unreliable

 - No comparables available or applicable

 - Zero ($0) market value

 + Flawed methodologies

 + Invalid comparables

 + Unequal and non-uniform taxation

 + Other documented facts



 Jurisdictional Issues:

 Did you protest the assessment at a Board of Review? Yes



 If Yes, check which Board of Review you attended: March



 If No, please check the applicable reason(s):



 Year(s) Under Appeal:

 2026



 Valuation Information for Each Parcel under Appeal:

 Parcel Number:

 76-24-24-176-008



 Classification of Property: Real (check one)



 Residential (check one)



 Current Assessed Value as established by the Board of Review:

 10800



 Current Taxable Value as established by the Board of Review:

 973



 What do you believe is the fair market value?

 0



 2 of 3

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value.

 0



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

 0



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

 Petitioner’s Signature:



 /s/ Susan Solomon



 Attorney or Authorized Agent’s Signature:



 /s/



 Fee Information:



 If you do not have a Principal Residence Exemption of at least 50% at the time of the filing of this petition, you are required to pay a filing fee for

 the filing of this appeal.



 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.



 Property tax appeal: Residential** Non-Residential

 SEV or TV in contention* Filing fee*** Filing Fee**

 $100,000 or less...........................................................................................$ 125.00 $250.00

 $100,000.01 to $500,000.00.........................................................................$ 200.00 N/A

 More than $500,000…..................................................................................$ 300.00 N/A



 Does the subject property have a principal residence exemption of at least 50% as of the date of the filing of this petition?

 No



 3 of 3

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 DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 Susan Solomon,

 Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

 v

 MTT Docket No. 26-002839

 City Of Southfield,

 Respondent.



 NOTICE OF DOCKET NUMBER



 TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket

 number has been assigned to that petition. The assignment of the docket number does

 not mean that the Tribunal has authority over the petition or that the petition complies

 with the Tribunal’s rules. The docket number needs to be included on all documents

 submitted in this case.



 Respondent shall file an answer to the petition within 28 days of the issuance of a

 copy of this Notice to Respondent. Tribunal answer forms are available on our

 website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer

 form. Failure to file the answer within the 28-day time frame may result in the

 placement of Respondent in default, as provided by TTR 281. Further, an electronic

 copy of the petition can be reviewed by utilizing the Docket Lookup Search on the

 Tribunal’s website.



 By: Tribunal Clerk

 Entered: October 6, 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



 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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 Susan Solomon,

 Petitioner, MICHIGAN TAX TRIBUNAL

 SMALL CLAIMS DIVISION

 v

 MTT Docket No. 26-002839

 City Of Southfield,

 Respondent.



 NOTICE OF DOCKET NUMBER



 TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket

 number has been assigned to that petition. The assignment of the docket number does

 not mean that the Tribunal has authority over the petition or that the petition complies

 with the Tribunal’s rules. The docket number needs to be included on all documents

 submitted in this case.



 Respondent shall file an answer to the petition within 28 days of the issuance of a

 copy of this Notice to Respondent. Tribunal answer forms are available on our

 website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer

 form. Failure to file the answer within the 28-day time frame may result in the

 placement of Respondent in default, as provided by TTR 281. Further, an electronic

 copy of the petition can be reviewed by utilizing the Docket Lookup Search on the

 Tribunal’s website.



 By: Tribunal Clerk

 Entered: October 6, 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



 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

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

CONTACT INFORMATION

 PETITIONER #2 of 2

 Property Parcel No: 76-24-24-176-008



Ken Solomon

403 Monterey Rd.

Pacifica, CA 94044

(650) 738-8037

fogpac@hotmail.com

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 DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 MICHIGAN TAX TRIBUNAL



 Docket Number: 26-002839



 Is this case currently pending in the Small Claims Division? Yes



 Party Filing Document

 Petitioner



 Files



 Document Type: Attachments to Petition

 Attachment File Name: Contact Info for 2nd Petitioner



 Fee Information

 Filing Fee: $ 0.00



 Payment Information

 Payment: $ 0.00



 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

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

04/02/2026 11:54 AM

 2026 BOARD OF REVIEW DECISION



 FROM PROPERTY IDENTIFICATION:

 CITY OF SOUTHFIELD 26:24.04:176-008

 26000 EVERGREEN RD

 SOUTHFIELD, MI 48076 MEADOWOOD RD



 NAME AND ADDRESS OF OWNER OR PERSON NAMED ON ASSESSMENT ROLL: T1N.R10E,SEC 24 52 MEADOW DOWNS SUBDN NO. 1

 LOT 135



 SOLOMON, S & SOLOMON, K

 25635 GRAND CONCOURSE ST

 SOUTHFIELD MI 48075-1748



 THIS PROPERTY IS CLASSIFIED 402 (RESIDENTIAL-VACANT)



 Pursuant to Michigan Compiled Laws (MCL) 211.30 (4), each year the assessor shall notify each person who appealed the

 value on their property tax assessment in March, or were authorized by the owner to make such an appeal in March. Such

 notification shall be mailed by the first Monday in June.



 The City of Southfield Board of Review has completed their review of your appeal regarding the 2026 assessed and/or

 taxable value, and has made the following decision(s):



 Board of Review Comments:



 DENIED - COMPARABLES SUPPORT VALUE



 2026 ORIGINAL ASSESSED VALUE 10,800 |



 2026 "BOARD OF REVIEW" ASSESSED VALUE 10,800



 (If the above amounts are the same, no revisions have oc



 2026 ORIGINAL TAXABLE VALUE 973



 2026 “BOARD OF REVIEW" TAXABLE VALUE 973



 2026 PRINCIPAL RESIDENCE EXEMPTION/QUALIFIED AG % 0.0000



 Please feel free to contact the assessor at the address listed above or call if you have any questions.



 Valuation Appeals - If you decide to protest this decision, pursuant to MCL 205.735a, it may be further appealed to the Michigan

 Tax Tribunal by filing a petition that can be obtained at www.michigan.gov/taxtrib (click Small Claims Tab). A copy of this letter

 and a completed petition should be mailed to Michigan Tax Tribunal, P.O. Box 30232, Lansing, Michigan 48909.

The deadline for filing an appeal is as follows:



 Residential and Small Claims July 31, 2026

 Commercial and Industrial Real May 31, 2026

 Personal Property” May 31, 2026



 *you must provide a copy of the Personal Property Statement you timely filed



Classification Appeals: (to or from residential, commercial or industrial) should be directed to the State Tax Commission, P.O.

Box 30471 Lansing, MI 48909 not later than June 30, 2026

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 DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 MICHIGAN TAX TRIBUNAL



 Docket Number: 26-002839



 Is this case currently pending in the Small Claims Division? Yes



 Party Filing Document

 Petitioner



 Files



 Document Type: Attachments to Petition

 Attachment File Name: 2026 MBOR Decision



 Fee Information

 Filing Fee: $ 0.00



 Payment Information

 Payment: $ 0.00



 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

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

APPEAL OF 2026 ASSESSED VALUE INCREASE



City of Lathrup Village City of Southfield



 UNIMPROVED PORTION OF

 MEADOW DOWNS SUB NO. 1

 31 Parcels (15 acres total)



 Subject Parcel #: 76-24-24-176-008 EXHIBIT

 A

Page 2

EXHIBIT B (improved)



 Property SUBDIVISION Subject (unimproved)



 Lot135 R-O-WINCREASE

 Road SUBJECT

 MeadowoodVALUE Southfield

 of

 CityASSESSED

 Village2026 Village) EastOF Lathrup St. Lathrup

 of of

 City City

 byAPPEAL Meadowood

 (vacated

Page 3

EXHIBIT C



 APPEAL OF 2026 ASSESSED VALUE INCREASE



LOCATION OF FORMER MEADOWOOD ST. EAST

 (West access road to subdivision)



 Meadowood St. East (former)



 (60-foot wide unimproved public right-of-way – Vacated 1973)



 City of Lathrup Village, MI

Page 4

EXHIBIT D

 APPEAL OF 2026 ASSESSED VALUE INCREASE

Adjustment

Value

Land

=

LVA

Page 5

EXHIBIT E

 APPEAL OF 2026 ASSESSED VALUE INCREASE City of Southfield

 26000 Evergreen Rd. • P.O. Box 2055 • Southfield, MI 48037-2055



 July 15, 1992



Milton Solomon

25635 Concourse

Southfield, MI 48076



Dear Mr. Solomon:



I am writing in response to an inquiry made by your son, Ken Solomon regarding property

that you own on Meadowood (Sidwell parcel 2424-176-008). Nik Banda and I met with

your son last week to discuss this vacant property and the possibility that you plan to sell

it for the development of a house.



We determined that there is currently a right-of-way leading to the property with water

and sewer already in place, but no roadway improvement. In fact, the right of way access

has been barricaded to prevent dumping in and around this vacant area. Mr. Solomon

asked if this barricade could be removed. It is our understanding that you have contacted

Mr. Habowski regarding the removal of the barricade which is to be worked out with the

Department of Public Works.



Additionally, our maps show that this property is contained within a wetlands area that is

larger than two acres and would, therefore need to be reviewed by the Michigan

Department of Natural Resources as well as by the City to determine the actual extent and

boundaries of the wetlands. This review is required before a permit can be issued that

would allow for construction of a house. We discussed that it may be difficult to sell the

property without knowing whether the property can be developed with a house. Mr.

Banda stated that no other property in this area has been reviewed by the DNR for

wetlands, so we do not have an indication of what the DNR's findings will be. However,

without any input from the DNR, our opinion is that according to our maps, the land is

covered by wetlands and is therefore undevelopable without mitigation of the wetlands

area. If you want to proceed with wetlands review, applications for the DNR and city

review are available from the City of Southfield Planning Department.



We also discussed the possibility of offering to sell the property to the neighbors to the

south of the property. Another possibility is to donate the land to the city and use the

value of the property as a tax write-off.



 Mayor Council President City Clerk City Treasurer City Administrator

 Donald E Fracassi Suzanne Goldstein Mary A. Bonner Roman J. Gronkowski Robert R. Block

 City Council

 Denise R. Alexander Peter J. Cristiano Vicki Goldbaum Steve S. Hurite Sidney Lantz Eli E. Robinson

Page 6

Milton Solomon EXHIBIT E

July 15, 1992

Page 2



Finally, we suggested talking to the City Assessor to discuss reducing the assessed value

of the property and therefore the amount of taxes to be paid.



If you have any questions regarding this matter please call me at 354-9540.



Sincerely,



Barbara McBeth

Planning Technician

Page 7

EAST ACCESS TO SUBDIVISION (May 2026)



 EXHIBIT

 F

Page 8

EAST ACCESS TO SUBDIVISION (2013)



 EXHIBIT

 F

Page 9

EXHIBIT G



 APPEAL OF 2026 ASSESSED VALUE INCREASE



 DOCUMENTATION OF CONDITION OF

 1 of 2 FIRE HYDRANTS & WATER VALVE BOXES

 (Unimproved section of Meadow Downs Subdivision No. 1)



 2026

 2 MISSING HOSE NOZZLE CAPS

 (1 each on East & West sides)



 BROKEN WATER VALVE BOX

 With missing cover



 BROKEN PIECE OF

 WATER VALVE BOX



Note: The photos above (2026) & below (2019) of the same fire hydrant, demonstrate the above-ground

utility fixtures have been effectively abandoned by City of Southfield DPW for many years. Another

earlier photo, excluded herein, shows some of the same damage in 2013, corroborating that such

abandonment likely began well before 13 years ago. Such photos depict at least one of the fire hydrants

has been missing both of its hose nozzle caps, exposing the nozzle threads to damage and the hydrant

barrel to debris collection and rapid corrosion along two sides, affecting the performance of, and/or

potentially damaging, downstream supply lines and pump equipment. The hydrant also has a cracked

lower standpipe (see photo - next page). And, the water control valve box that serves the hydrant has

been both broken and coverless, exposing the underground valve to corrosion and other damage.

Page 10

EXHIBIT G

 APPEAL OF 2026 ASSESSED VALUE INCREASE



 DOCUMENTATION OF CONDITION OF

 SAME FIRE HYDRANT & WATER VALVE BOX

 (Unimproved section of Meadow Downs Subdivision No. 1)



2019



 2 MISSING HOSE NOZZLE CAPS

 (1 each on East & West sides)



 BROKEN WATER VALVE BOX

 With missing cover



 BROKEN PIECE OF

 WATER VALVE BOX



 CRACKED

 LOWER STANDPIPE

 (East side)

Page 11

1 " = 100 ' Meadow Downs Sub No 1 CITY OF SOUTHFIELD WETLANDS MAP (6-29-26) µ



 St APPEAL

 Pierce OF

 2026



 Meadowood Rd ASSESSED SUBJECT PROPERTY

 VALUE

 INCREASE



 THIS MAP WAS

Page 12

US

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 DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 MICHIGAN TAX TRIBUNAL



 Docket Number: 26-002839



 Is this case currently pending in the Small Claims Division? Yes



 Party Filing Document

 Petitioner



 Files



 Document Type: Attachments to Petition

 Attachment File Name: Appeal Exhibits A - P



 Fee Information

 Filing Fee: $ 0.00



 Payment Information

 Payment: $ 0.00



 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

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

Kenneth Solomon

 403 Monterey Rd.

 Pacifica, CA 94044

Home Phone: (650) 738-8037 Email: fogpac@hotmail.com



 July 28, 2026



Department of Licensing and Regulatory Affairs (LARA)

Michigan Tax Tribunal

P.O. Box 30232

Lansing, MI 48909



 RE: REASONS FOR APPEAL OF 2026 ASSESSED VALUE INCREASE

 PARCEL #: 76-24-24-176-008 (Lot 135 – Meadow Downs Sub No. 1)



The subject property has been in my family’s possession since 1955, three years before Southfield

incorporated as a city. In 2024, my sister, Susan Solomon, and I became joint owners thereof.



Pertinent background



The subject property is extraordinarily unique, but not by itself. It is one of the 31 vacant, similar-

sized parcels in an unimproved 15-acre section of an otherwise fully built subdivision in Southfield.

The subdivision, Meadow Downs Subdivision No. 1, established in 1942, notably, abuts the City of

Lathrup Village, to the west, see attached EXHIBIT A. The unimproved section of Meadow Downs

No. 1, containing the subject property, is hereinafter referred to as the “subdivision.”



Each of the 31 parcels in the subdivision, historically, was separately and privately owned. The

subdivision also historically contained limited public infrastructure, e.g., an interior unimproved road

(Meadowood Road) and its right-of-way that provided two points of external access and the only

access to the frontage of each of the lots therein, see attached EXHIBIT B. Meadowood Road

connected west to the abutting neighborhood in the City of Lathrup Village and extended ½ mile

further east, through the City of Southfield, to a major arterial, Greenfield Road. And, in the 1960’s,

the City of Southfield installed limited public utilities1 within the subdivision, while imposing a

separate special assessment fee per utility to defray such costs. All such infrastructure was

historically maintained, as applicable, by each of the respective Cities, until it suddenly wasn’t.



The City of Southfield, from about 1981-1991, imposed severe development constraints on the

subdivision, as discussed further herein, all of which remain today. The City also abandoned its

road infrastructure and most of its utilities therein, while the City of Lathrup Village earlier vacated

its access road thereto. Such abandonment caused the subdivision to evolve from a wide open,

fully accessible, buildable, and build-ready development site into the current inaccessible,

impassable, and undevelopable forest, surrounded by homes, adding to the constraints.



The City of Southfield has not been a passive or neutral regulator and is the cause of the

subdivision remaining unbuilt for the past 45 years. It is also now both the largest landowner and,

effectively, the master developer therein – given it is conversely and clandestinely facilitating

development of an unspecified number of its own lots, as discussed further herein.



1 Refers to water and sewer/stormwater (combined) mains and appurtenances (e.g., fire hydrants, valve

 boxes, manholes, catch basins, etc...), separately installed in the Meadowood R-O-W within the

 subdivision. Another separate but connected water main was also installed in an easement along the

 interior side of the west boundary of the subdivision. All were installed, speculatively, between 1960-70.

Page 2

Appeal of 2026 Assessed Value Increase

 Vacant Parcel # 76-24-24-176-008

 Page 2



Ignored value-reducing factors



Severe development constraints – The uniqueness of the subject property and subdivision stems

from the City-imposed development constraints thereon, all of which are independently value-

reducing. However, the current property record card, I’ve belatedly learned, either excludes,

misrepresents, or over trivializes all such constraints, rendering the assessed value as an extreme

overvaluation of the subject property. Each of the constraints, in order of commencement, is below:



1. No public road access:



 a) Loss of west vehicular access to subdivision - 45 years ago, the west access road to the

 subdivision, in the abutting City of Lathrup Village, was discovered barricaded. It is now

 occupied by mature trees and other landscaping - see attached EXHIBIT C. The reason for

 this was unknown until discovered literally earlier this year: The City of Lathrup Village, in

 1973, had vacated said road,2 permanently eliminating the west access, notably, absent

 any objection by the City of Southfield.



 b) Loss of east vehicular access to subdivision – Also 45 years ago, the City of Southfield,

 initially inexplicably, and without notice, barricaded the east access to the subdivision,

 functionally landlocking both the subject property and subdivision since that time. Such

 “LANDLOCKED” condition was documented earlier by the City Assessor’s Office, see

 attached EXHIBIT D. Most striking, after the barricade was first discovered, the City,

 inexplicably, “refuse[d]” to remove it.3 A decade later, the City alleged it was installed to

 “prevent dumping in and around the vacant area”, see attached EXHIBIT E. The barricade,

 initially an immovable steel guardrail, was recently replaced with vehicle obstacles, see

 photos attached as EXHIBIT F.



 c) Loss of interior road & vehicular access to all interior lots - The City of Southfield also long-

 ago, inexplicably and without notice, ceased all use and maintenance of Meadowood Road

 and its right-of-way within the subdivision. This caused the road to disintegrate and

 disappear and

Page 3

Appe

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 DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 PROPERTY TAX APPEAL PETITION FORM

 VALUATION / UNCAPPING APPEAL



 MTT DOCKET NO.



 Petitioner’s Contact Information:

 Filer Type: Local Unit of Government:

 Individual



 First Name M.I. Last Name

 Susan Solomon



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

 25635 Grand Concourse St.



 City or Town State ZIP Code

 Southfield Michigan 48075



 Telephone Number

 248-557-1157



 E-mail Address

 solomons@comcast.net



 Subject Property Information:

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

 1 *If no, you must file separate appeals for each parcel



 N/A

 Property Address (No., Street)

 Meadowood Road (unimproved right-of-way)



 City or Town County State ZIP Code

 Southfield Oakland Michigan 48076



 Taxing Authority (City or Township)

 City Of Southfield (OAKLAND)



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



 True Cash and Taxable Values

 Taxable Value Only (calculation)



 Please Explain the Reason for this Appeal:



 1 of 3

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 See attached document titled "REASONS FOR APPEAL OF 2026 ASSESSED VALUE INCREASE", including associated exhibits:



 Summary of issues:



 Rebuttal of impartiality of taxing authority and accuracy of assessed value, based on each of the following:

 + Bad faith and conflicts of interest by taxing authority

 + Failure to recognize uniquessness of subject propery by excluding, misrepresenting, and/or over trivializing value-reducing factors

 + Contrary to prior independent qualified property appraisal that found, due to uniqueness and restrictive nature of subject property:

 - Highest and best use is indeterminable

 - Market approach is unreliable

 - No comparables available or applicable

 - Zero ($0) market value

 + Flawed methodologies

 + Invalid comparables

 + Unequal and non-uniform taxation

 + Other documented facts



 Jurisdictional Issues:

 Did you protest the assessment at a Board of Review? Yes



 If Yes, check which Board of Review you attended: March



 If No, please check the applicable reason(s):



 Year(s) Under Appeal:

 2026



 Valuation Information for Each Parcel under Appeal:

 Parcel Number:

 76-24-24-176-008



 Classification of Property: Real (check one)



 Residential (check one)



 Current Assessed Value as established by the Board of Review:

 10800



 Current Taxable Value as established by the Board of Review:

 973



 What do you believe is the fair market value?

 0



 2 of 3

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA

 GOVERNOR LANSING DIRECTOR



 Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value.

 0



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

 0



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

 Petitioner’s Signature:



 /s/ Susan Solomon



 Attorney or Authorized Agent’s Signature:



 /s/



 Fee Information:



 If you do not have a Principal Residence Exemption of at least 50% at the time of the filing of this petition, you are required to pay a filing fee for

 the filing of this appeal.



 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.



 Property tax appeal: Residential** Non-Residential

 SEV or TV in contention* Filing fee*** Filing Fee**

 $100,000 or less...........................................................................................$ 125.00 $250.00

 $100,000.01 to $500,000.00.........................................................................$ 200.00 N/A

 More than $500,000…..................................................................................$ 300.00 N/A



 Does the subject property have a principal residence exemption of at least 50% as of the date of the filing of this petition?

 No



 3 of 3

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.