2026-10-05 GR SE Answer.pdf
Gr Se, Inc Petitioner Vs. City Of Grand Rapids Respondent · 26-001122-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL GR SE, INC, Docket No. 26-001122 Petitioner, v. Parcel No. 41-18-11-476-039 CITY OF GRAND RAPIDS, Respondent. / Peter Ellenson (P47383) Law Office of Peter Ellenson, P.C. Attorney for Petitioner 30500 Northwestern Highway, Suite 500 Farmington Hills, MI 48334 (248) 406-4443 peter@ellensonlaw.com Kendall R. O’Connor (P84036) Lee S. Schofield (P62748) City of Grand Rapids Law Department Attorneys for Respondent 300 Monroe Ave. NW, Suite 620 Grand Rapids, MI 49503 (616) 456-3103 koconnor@grand-rapids.mi.us lschofield@grand-rapids.mi.us / RESPONDENT’S APPEARANCE AND ANSWER TO PETITION WITH PROOF OF SERVICE NOW COMES Kendall R. O’Connor and Lee S. Schofield for the City of Grand Rapids, who hereby enter their Appearance of Counsel on behalf of Respondent City of Grand Rapids, and answers Petitioner’s Petition as follows: 1. Petitioner is a party in interest with respect to the property taxes for the following parcel number: 41 18 11 476 039, located at 3900 SE Stahl, Grand Rapids, MI 49546. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in paragraph 1 of Petitioner’s Petition and leaves Petitioner to its proofs.
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2 2. Petitioner’s principal office address is 1010 Beacon Blvd., Grand Haven, MI 49417. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in paragraph 2 of Petitioner’s Petition and leaves Petitioner to its proofs. 3. Respondent City of Grand Rapids assesses and collects the ad valorem property taxes associated with the subject parcels. ANSWER: Respondent admits the allegations in paragraph 3 of Petitioner’s Petition only with respect to the parcel identified in paragraph 1 of Petitioner’s Petition. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in paragraph 3 of Petitioner’s Petition and leaves Petitioner to its proofs. 4. The subject property is classified as commercial improved (201). ANSWER: Respondent admits the allegations in paragraph 4 of Petitioner’s Petition only with respect to the parcel identified in paragraph 1 of Petitioner’s Petition. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in paragraph 4 of Petitioner’s Petition and leaves Petitioner to its proofs. 5. The subject property is located in Kent County. ANSWER: Respondent admits the allegations in paragraph 5 of Petitioner’s Petition only with respect to the parcel identified in paragraph 1 of Petitioner’s Petition. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in paragraph 5 of Petitioner’s Petition and leaves Petitioner to its proofs. 6. This appeal involves the property’s true cash and taxable values. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in paragraph 6 of Petitioner’s Petition and leaves Petitioner to its proofs. 7. The tax year at issue is 2026. ANSWER: Respondent admits the allegations in paragraph 7 of Petitioner’s Petition.
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3 8. No Board of Review petitions was filed or required. ANSWER: Paragraph 8 of Petitioner’s Petition contains legal conclusions to which no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in paragraph 8 of Petitioner’s Petition and leaves Petitioner to its proofs. 9. The 2026 values for the subject property as established by the Respondent at its March 2026 Board of Review are: True Cash Value Assessed Value Taxable Value 4,425,000 2,212,500 2,212,500 ANSWER: Respondent admits the allegations and corresponding values alleged in paragraph 9 of Petitioner’s Petition with respect to the property identified in paragraph 1 of Petitioner’s Petition. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in paragraph 9 of Petitioner’s Petition and leaves Petitioner to its proofs. 10. Petitioner contends that the values for the subject property are: True Cash Value Assessed Value Taxable Value 3,000,000 1,500,000 1,500,000 ANSWER: Respondent denies the allegations and corresponding values alleged in paragraph 10 of Petitioner’s Petition as untrue with respect to the property identified in paragraph 1 of Petitioner’s Petition. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in paragraph 10 of Petitioner’s Petition and leaves Petitioner to its proofs. 11. The values in dispute for the subject property are: True Cash Value Assessed Value Taxable Value 1,425,000 712,500 712,500 ANSWER: Respondent admits the allegations and corresponding values in dispute alleged in paragraph 11 of Petitioner’s Petition with respect to the property identified in paragraph 1 of Petitioner’s Petition. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in paragraph 11 of Petitioner’s Petition and leaves Petitioner to its proofs.
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4 12. Petitioner requests that this Honorable Tribunal order the assessing entity to correct its tax rolls to reflect taxable, assessed and state equalized values as indicated above (or on the attached supplement) to issue refunds as appropriate, and to pay interest and costs. ANSWER: Respondent denies the allegations in paragraph 12 of Petitioner’s Petition as untrue and denies that Petitioner is entitled to any relief whatsoever. 13. The basis for the requested relief is that the assessed and taxable values exceed 50% of the true cash value of the subject property. ANSWER: Respondent denies the allegations in paragraph 13 of Petitioner’s Petition as untrue and denies that Petitioner is entitled to any relief whatsoever. WHEREFORE, Respondent City of Grand Rapids prays that this Honorable Tribunal dismiss the Petition and award Respondent its costs and attorney fees. CITY OF GRAND RAPIDS, a Michigan municipal corporation Dated: October 6, 2026 By: /s/ Lee S. Schofield (P62748) Assistant City Attorney Attorney for Respondent Lee S. Schofield
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5 PROOF OF SERVICE Alma Echeverria, being first duly sworn, deposes and says that she is a Paralegal in the Office of the City Attorney, attorneys for Respondent herein, and that on October 6, 2026, she served true and complete copies of Respondent’s Appearance and Answer to Petition via first class mail and email, upon: Peter Ellenson Law Office of Peter Ellenson, P.C. 30500 Northwestern Highway, Suite 500 Farmington Hills, MI 48334 peter@ellensonlaw.com /s/ Alma Echeverria Alma Echeverria