ANSWER Grandville re Chigago Dr Re Holdings.pdf

Chicago Dr Re Holdings LLC Petitioner Vs. City Of Grandville Respondent · 26-001505-TT

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STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

CHICAGO DR RE HOLDINGS, LLC, 

 

 Petitioner, 

 

v. 

 

CITY OF GRANDVILLE, 

 

 Respondent. 

 

 

MTT Docket No. 26-001505 

 

Parce No. 41-17-18-327-002 

Aaron M. Fales (P72864) 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

330 Hamilton Row, Suite 350 

Birmingham, MI 48009 

(248) 767-9840 

aaron@afaleslaw.com 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Bridgewater Place 

333 Bridge Street NW 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com 

 

ANSWER TO PETITION 

 

 

Respondent, City of Grandville, by and through its attorneys, VARNUM LLP, states as 

follows for its answer to Petitioner's Petition: 

1. 

Petitioner's principal office address is 30201 Orchard Lake Rd., Ste. 100, 

Farmington Hills, MI 48334. Petitioner is a party in interest with respect to property taxes on real 

property tax parcel no. 41-17-18-327-002 ("Petitioner's Property"), at 4584 Chicago Dr., 

Grandville, MI 49418. 

RESPONSE: Respondent neither admits nor denies the allegations of paragraph 1 as they 

relate to whether the address provided is Petitioner's "principal" address as Respondent is 

without sufficient information to form a belief. Respondent neither admits nor denies 

whether Petitioner is a proper party in interest as Respondent is without sufficient 

information to form a belief. Respondent further states that the address in Respondent's 

records for Petitioner is 30201 Orchard Lake Rd 110, Farmington Hills, MI 48334.

2 

 

Respondent also states that the address Respondent has for parcel 41-17-18-327-002 is 4584 

Chicago Dr. SW, Grandville, MI. 

 

2. 

Respondent, City of Grandville assesses and collects property taxes on Petitioner's 

Property. 

RESPONSE: Respondent admits that it assesses, levies and attempts to collect the property 

taxes on PPN No. 41-17-18-327-002 (the "Property"). 

 

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$297,400 and assessed Petitioner's Property at $297,400 resulting in a state equalized value of the 

same amount based on the tentative equalization factor. 

RESPONSE: Respondent admits that the 2026 taxable and assessed values of the Property 

is $297,400. 

 

4. 

Petitioner's Property is classified as Commercial Real Property. Petitioner's 

Property is commercial property. Petitioner believes that Petitioner's Property was designed to be 

used as a commercial purposes. 

RESPONSE: Respondent admits that the Property is classified as 201 commercial 

improved real property and that the Property is used for commercial purposes. Respondent 

admits, upon information and belief, that the Property was designed to be used for 

commercial purposes. 

 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

RESPONSE: Respondent neither admits nor denies the allegations in Paragraph 5, as 

Respondent is without sufficient knowledge or information to form a belief as to their truth. 

Respondent affirmatively states that the Property is properly and uniformly assessed. 

 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss.

3 

 

RESPONSE: Respondent neither admits nor denies the allegations in Paragraph 6, as 

Respondent is without sufficient knowledge or information to form a belief as to their truth 

relating to any alleged loss at the Property. 

 

7. 

The 2026 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

and operate as a fraud upon the taxpayer for the reasons that: 

a. 

The assessment, including state equalized value and/or taxable value, 

exceeds the amounts permitted by the Michigan Constitution and applicable 

statutes; 

b. 

The assessment, including state equalized value and/or taxable value, are at 

high percentages of true cash value than permissible under the Michigan 

Constitution and applicable statutes; 

c. 

The assessment, including taxable value and/or state equalized value, are 

based upon an erroneous determination of the true cash value of that portion 

of Petitioner's Property that is taxable under Michigan law, and are based 

upon the application of wrong principles; and 

d. 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection and due process of law. 

RESPONSE: Respondent denies all of the allegations of paragraph 7, including all subparts, 

for the reason that they are not true. Respondent denies that Petitioner's contentions of value 

are correct. Respondent affirmatively states that the Property is properly and uniformly 

assessed.

4 

 

WHEREFORE, Respondent prays that this Tribunal affirm Respondent's assessment of the 

property, dismiss Petitioner's Petition and award Respondent any other relief deemed appropriate, 

including costs and attorney fees. 

Respectfully submitted, 

 

 

 

 

 

 

VARNUM LLP 

 

 

 

 

 

 

Attorneys for Respondent 

 

Dated: October 13, 2026 

 

 

By:_/s/ Deborah I. Ondersma _____________ 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

 

 

 

 

 

 

 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

BUSINESS ADDRESS & TELEPHONE: 

 

 

 

 

 

 

 

Bridgewater Place 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

(616) 336-6000 

 

 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent and states that it may rely on one or all of the following 

affirmative defenses: 

1. 

Petitioner has failed to state a claim upon which relief can be granted. 

2. 

Petitioner may not be a proper party in interest and the Tribunal therefore may not 

have jurisdiction over this appeal for this additional reason. 

3. 

Petitioner may not have standing to pursue this appeal. 

4. 

Petitioner’s claims against Respondent are barred because all assessment and 

valuation methods used by Respondent City of Grandville were in compliance with prevailing 

State Tax Commission procedures and in accordance with Michigan law. 

5. 

Petitioner may not have capacity to bring this appeal in the Michigan Tax Tribunal. 

6. 

Respondent reserves the right to add additional affirmative defenses made known 

to it through discovery in this matter.

5 

 

Respectfully submitted, 

 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Respondent 

 

Dated: October 13, 2026 

 

 

 

By: /s/ Deborah I. Ondersma 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

Business Address/Telephone: 

 

 

 

 

 

 

 

333 Bridge Street, N.W., Suite 1700 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

Telephone: (616) 336-6000 

 

 

 

 

 

 

 

ajbrody@varnumlaw.com 

 

 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

 

 

 

 

 

 

29831250.1

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