SIGNED answer venlo.pdf

Vrei Venlo LLC Petitioner Vs. Township Of Big Rapids Respondent · 26-000863-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS & RULES 

MICHIGAN TAX TRIBUNAL 

VREI VENLO LLC, 

MOAHR Docket No. 26-000863 

Petitioner, 

Parcel No. 54-05-016-015-001 and 

54-05-016-015-002 

v 

BIG RAPIDS CHARTER TOWNSHIP, 

ANSWER TO PETITION 

Respondent. 

Sarah R. Belloli 

Eric D. Williams (P33359) 

Representative for Petitioner 

Attorney for Respondent 

101 West Big Beaver, Suite 945 

524 N State Street 

Troy, MI 48084 

Big Rapids, MI 49307 

(313) 230-0104 

(231) 796-8945 

Sarah.Belloli@Ryan.com 

edwl@att.net 

ANSWER TO PETITION 

NOW COMES the Big Rapids Charter Township, by and through its attorney, Eric 

D. Williams, and says for its answer to the Petition filed by Petitioner VREI VENLO LCC: 

1. Admitted that the parcels at issue are No. 54-05-016-015-001 and No. 54-05-016- 

015-002. 

2. 

Admitted that the property is real property. 

3. 

Petitioner did not answer. Respondent believes there to be more than one parcel 

of real property under appeal. 

4. 

Neither admitted nor denied. The allegation regarding personal property parcels 

in inapplicable to the appeal of the valuation of real property only. 

5. 

Admitted that there is no personal property under appeal.

6. Admitted that the Properties are classified as 201 Commercial-Improved. 

7. Admitted that Petitioner did not protest to the Board of Review. 

8. 

Admitted that no protest was required or made. 

9. Admitted that the appeal was timely filed. 

10. Admitted that the Properties at issue are located in Mecosta County, and the 

address of that property is 15345 Venlo Drive, Big Rapids, MI 49307. 

11. Admitted that the assessment and valuation 

at issue were established by 

Respondent Big Rapids Charter Township. 

12. Admitted that the Petitioner's legal residence or principal office address is 6200 

Wing Ave, SE Grand Rapids, MI 49512. 

13. Admitted that this appeal involves issues relating to the Properties’ true cash and 

taxable values, and there was no addition or loss for the purpose of establishing 

the Properties’ taxable value for the 2026 tax year. 

14. Admitted that the tax year at issue is 2026. 

15. Admitted that Petitioner only appeals the current tax year. 

16. The values for the Property as established by the Respondent or its Board of 

Review are: 

Tax 

| Parcel No. 

True Cash Value | State Equalized | Taxable 

Year 

Value 

Value 

2026 

54-05-016-015-001 | $8,544,800 

$4,272,400 

$3,948,085 

2026 

54-05-016-015-002 | $245,400 

$122,700 

$93,782 

2026 

Totals 

$8,790,200 

$4,395,100 

$4,041,867

17. The Respondent Big Rapids Charter Township contends that the values for the 

Property are: 

Tax 

| Parcel No. 

True Cash Value | State 

Equalized | Taxable 

Year 

Value 

Value 

2026 

54-05-016-015-001 

| $8,544,800 

$4,272,400 

$3,948,085 

2026 

54-05-016-015-002 | $245,400 

$122,700 

$93,782 

2026 

Total 

$8,790,200 

$4,395,100 

$4,041,867 

18. The values in dispute for the Property are: 

Tax 

| Parcel No. 

True Cash Value | State 

Equalized | Taxable 

Year 

Value 

Value 

2026 

54-05-016-015-001 

| $2,226,300 

$1,113,150 

$788,835 

2026 

54-05-016-015-002 | $63,900 

$31,950 

$3,032 

2026 

Total 

$2,290,200 

$1,145,100 

$791,867 

19. The relief requested by Petitioner 

is without factual 

or legal support. The 

Respondent Big Rapids Charter Township requests that the Tax Tribunal enter an 

order on Property Parcel No. 54-05-016-015-001 affirming the 2026 true cash value 

of $8,544,800, the state equalized value of $4,272,400, and the taxable value of 

$3,948,085; 

and 

enter 

an 

order 

on 

the 

Property 

Parcel 

No. 

54-05-016-015- 

002affirming the 2026 true cash value of $245,200, the state equalized value of 

$122,700, and taxable value of $93,782. 

20. The facts upon which Petitioner relies are conclusory and denied as untrue. 

21. And 22. Respondent Big Rapids Charter Township relies on the following facts 

and affirmative defenses to support the relief requested:

. 

the assessment, including the state equalized value and taxable value of the 

Properties, are proper and permitted by the Michigan Constitution and 

applicable statutes; and 

. 

the assessment, including the state equalized value and taxable value of the 

Properties, are at the correct percentage of true cash value permitted under 

the Michigan Constitution and applicable statutes; and 

. 

the assessment, including the state equalized value and taxable value of the 

Properties, are based upon the correct determination of the true cash value 

of those portions of the Properties that is taxable under Michigan law; and 

. 

the assessment, including the state equalized value and taxable value of the 

Properties, 

and the mode of assessment employed by Respondent Big 

Rapids Township, affords Petitioner all of its constitutional rights 

to 

uniformity, equal protection, and due process of law; and 

. 

Respondent reserves the right to supplement these affirmative defenses as 

additional defenses become known throughout discovery. 

WHEREFORE, the Respondent Big Rapids Charter Township requests that the Tax 

Tribunal enter an order on the Properties affirming the 2026 true cash value for Parcel No. 

54-05-016-015-001 of $8,544,800, the state equalized value of $4,272,400, and the taxable 

value of $3,948,085; and affirming the 2026 true cash value for Parcel No. 54-05-016-015- 

002 of $245,200, the state equalized value of $122,700, and taxable value of $93,782. 

[Signature on following page.]

Dated: 

2 fosect-0036 

Se \w/. 

Eric D. Williams (P33359) 

Attorney for Soha, 

524 N State Street 

Big Rapids, MI 49307 

(231) 796-8945 

edwl@att.net

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