2600 Horizon LLC- delete fedex envelope.pdf

2600 Horizon LLC, Petitioner Vs. Township Of Cascade, Respondent · 25-002407-TT

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D 

RECENEY 

 pEcEIVED 

JON 02 2009 

\ 

MAY 29 2025 

U7 

UNA 

a 

ANTAX The 

MICHIG 

CHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

2600 Horizon, LLC, 

Petitioner, 

v. 

MTT Docket No. 

[Parcel No(s). 41-19-07-376-031, 41-19-07-376- 

037] 

TranInfo:qb0f 

 26019836-1 

05/30/25 

Cascade Twp., 

Chit: 

40620 

Amt: $625.00 

ID: 

HONIGHAN LLP 

Respondent. 

PETITION 

2600 Horizon, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage, 

MI 48002. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 41- 

19-07-376-031, 41-19-07-376-037 ("Petitioner's Property"), also known as Horizon Office Park at 

2600 -2610 Horizon Drive SE located in Kent County, Michigan. 

If this petition includes more 

than one (1) real property tax parcel, the tax parcels are contiguous. 

2; 

Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's 

Property. 

3 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$1,063,816 ($531,908, $531,908) and assessed Petitioner's Property at $1,751,600 ($875,800,

4. 

Petitioner's Property is classified as Commercial Real. 

Petitioner's Property 

is 

presently used or available for use for Office purposes. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for Office purposes. 

S. 

This matter involves issues relating to: 

(a) valuation, (b) assessment, (c) taxable 

value and (d) uniformity. 

6. 

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

relative to the value of a loss. 

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner's Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 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 amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

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

higher 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 etroneous 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

(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 ifs constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value 

of Petitioner's Property from $1,063,816 ($531,908, $531,908) 

to $730,000 

($365,000, $365,000), and reducing the 2025 assessed and state equalized value of Petitioner's 

Property from $1,751,600 ($875,800, $875,800) to $730,000 ($365,000, $365,000), and requiring 

Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:/s/ Michael B. Shapiro 

Michael B. Shapiro (P20282) 

Daniel L Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

Dated: May 29, 2025 

mshapiro@henigman.com 

dstanley@honigman.com

rlonigman LLF 

COSTS ADVANCED ACCOUNT 

ne 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

5/29/25 

[| 

278319/547674/DLS 

*EX$625.00%** 

Filing Fee for Petition — 2600 Horizon 

LLC 

15106939.1

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