25-001746.pdf
Coughlin Partners LLC, Petitioner Vs. City Of Lansing, Respondent · 25-001746-TT
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RECEIVED SEP 95 2025 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL Coughlin Partners, LLC Petitioner v MOAHR Docket 25-001746 Parcel No. 33-01-01-17-226-292 CITY OF LANSING, Respondent Jennifer Czeiszperger, MMAO City Assessor 124 W. Michigan Avenue 3rd Floor, City Hall Lansing, MI 48933 (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov RESPONDENT’S ANSWER TO PETITIONER’S PETITION AND AFFIRMATIVE DEFENSES RESPONDENT, the City of Lansing, through its Assessor, Jennifer Czeiszperger, hereby responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent denied the allegations in Paragraph 1, the parcel numbers listed have been combined for the 2025 tax year to parcel number 33-01-01-17-226-292. The listed parcel numbers are no longer active parcel numbers. Further the mailing address on records is 24500 Northwestern Hwy, Ste 100, Southfield, MI 48075. ’ 2. Respondent admits the allegations in Paragraph 2.
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MTT Docket # 25-001746 10. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies that those issues have merit and further denies that Petitioner is entitled to any relief. Further, the subject property did not have any “additions” or “losses” for the 2025 tax year. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies that those issues have merit and further denies that Petitioner is entitled to any relief. Further, the subject property did not have any “additions” or “losses” for the 2025 tax yeat. Respondent denies the allegations in paragraph 7. The Petitioner did not make a March Board of Review appeal for the 2025 assessment. This was not required for this property classification. Respondent denies the allegations in Paragraph 8 for the reason that it is untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are constitutional. Respondent contends that the 2025 values for the property identified above are: Parcel Number True Cash Value Assessed Value Taxable Value 33-01-01-17-226-292 | $ 1,099,400 $549,700 $549,7008 The 2025 values in dispute for the property identified above are: Parcel Number True Cash Value | Assessed Value | Taxable Value 33-01-01-17-226-292 $0 $0 $0 WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal dismiss the Petition; affirm Respondent’s assessed and taxable values, subject to county and state equalization., and award Respondent its cost and attorney fees.
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MTT Docket # 25-001746 AFFIRMATIVE DEFENSES PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the following affirmative defenses: A. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against the Respondent and to support Petitioner’s claim for relief. B. The Tribunal is charged with finding a property’s true cash value to determine the property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). C. Petitioner has the burden of establishing the property’s true cash value. See MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). B. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, and application of wrong principles or illegality on the part of the Respondent or its agents. C. Petitioner fails to allege the mode and method of assessing the subject property failed to conform to the mode and method applied in the case of all properties within the Respondent’s taxing unit for the tax year in questions. D. Petitioner fails to allege specific and sufficient facts needed to establish the true cash value, assessed and taxable value for the subject property. E. Petitioner fails to allege specific and sufficient facts to support its allegations that the assessed value of the subject property, as equalized, is at a level other than 50% and it also fails to allege specific and sufficient facts to support its allegations that the subject property’s
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MTT Docket # 25-001746 G. Petitioner asks this Tribunal to grant it illegal preference by application of a method of assessment different from that utilized in the assessment of other properties in the Respondent’s taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. H. Petitioner, in essence, seeks by petition to challenge the process of county and state equalization as to which it has no legal standing and cannot maintain a cause of action. I, Any decrease in the value of Petitioner’s property was a result of its own intentional acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. J. Respondent has properly and lawfully assessed Petitioner’s property and established its taxable value in accordance with statutory and constitutional requirements. K. Respondent reserves the right to add affirmative defenses which may become known during the course of informal or formal discovery proceedings. WHEREFORE, Respondent denies that the Petitioner is entitled to any relief and respectfully requests that the Respondent’s assessed and taxable values for the year under appeal be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be granted all attorney fees and cost wrongfully sustained. OFFICE OF THE CITY ASSESSOR Dated: September 22, 2025 City ‘Assessor, City of Lansing 3d Floor, City Hall 124 W Michigan Ave Lansing, Michigan 48933
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Coughlin Partners, LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No.25-001746 City of Lansing , Respondent(s) PROOF OF SERVICE Jennifer Czeiszperger states that on September 22, 2025 he/she [Name of person serving/mailing petition] [date of service] served a copy of the Answer relative to the above-captioned matter upon: [Provide name and address of the party/people being served] MTT P.O. Box 30232, Lansing, Ml 48909 AND Foley & Lardner LLP/Jason Conti 500 Woodward Ave, Ste 2700 Detroit, Ml 48226 is serving/mailing copy] Jennifer Czeiszperger, MMAO [Print/type name of person serving/mailing copy]
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City of Lansing - Assessors 3rd Floor City Hall Es ou Lc aE :