25-002670.pdf

Rivershell Lansing LLC, Petitioner Vs. City Of Lansing, Respondent · 25-002670-TT

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RECEIVED 

AUG 2 0 2025 

MICHIGAN TAX TRIBUNAL 

N 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Rivershell Lansing LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MTT Docket No. 25-002670 

City of Lansing 

, 

Respondent. 

ENTIRE TRIBUNAL PROPERTY TAX ANSWER 

1. 

X_Admit___Deny. 

If denied, state the parcel number for the property identified 

on the Entire Tribunal Property Tax Petition for the tax year or.years at issue: 

23-50-40-36-226-001 & 23-50-40-36-226-011 

(If more than one parcel is at issue, attach a completed Multiple Parcel Answer 

Form addressing all other parcels at issue.) 

2. 

X__ Admit 

Deny. 

if denied, the property identified on the Entire Tribunal 

Property Tax Petition is ___ real ___ personal. 

3. 

X__Admit___Deny. 

If denied, identify the contiguous and non-contiguous 

parcels by parcel number (attach additional page if necessary): 

4. 

NA Admit ___ Deny. 

If denied, identify the parcel or parcels of personal property 

that are not located on a parcel of real property under appeal by parcel number 

(attach additional page if necessary): 

5. 

N/A Admit ___ Deny. 

a. 

If denied, state when the personal property statements were filed, 

if at all; 

N/A 

b. 

On what date did the March Board of Review commence: 

N/A 

6. 

X__Admit__ Deny. 

If denied, state the classification of the property identified 

on the Entire Tribunal Property Tax Petition for the tax year or years at issue:

MTT Docket No. 25-002670 

Page 2 of 4 

7. 

10. 

11. 

12. 

NA Admit ___Deny. 

If denied, list the separate facts upon which Respondent 

relies in support of the denial (attach additional page if necessary): 

BOARD OF REVIEW NOT REQUIRED 

Admit 

Deny X__ 

Neither Admit Nor Deny. 

If denied, list the separate 

facts upon which Respondent relies in support of the denial (attach additional 

age if necessary): 

BOARD OF REVIEW NOT REQUIRED 

Admit 

Deny X__ 

Neither Admit Nor Deny. 

If denied, state the facts upon 

which Respondent relies in support of the denial (attach additional page if 

necessary): 

N/A 

X_Admit ___Deny. 

If denied, in what County are the property or properties 

located in and what is the address of the property or properties: 

X__Admit__ Deny. 

If denied, what 

is the applicable local governmental unit: 

Admit 

Deny X__ 

Neither Admit Nor Deny. 

If denied, list the separate facts 

upon which Respondent relies in support of the denial (attach additional page if 

necessary): 

MAILING ADDRESS ON RECORD: 

23075 LAUREL VALLEY ST 

SOUTHFIELD, MI 48034

MTT Docket No. 25-002670 

Page 3 of 4 

14. 

X__Admit 

Deny 

Neither Admit Nor Deny. 

If denied, list the separate 

facts upon which Respondent relies in support of the denial (attach additional 

page if necessary): 

15. 

Admit 

Deny N/A Neither Admit Nor Deny. 

If denied, list the separate 

facts upon which Respondent relies in support of the denial (attach additional 

age if necessary): 

16. 

The values for the property identified above as established by Respondent's 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 (226-001) 

$2,507,000 

$1,253,500 

$931,817 

2025 (226-011) 

$3,347,000 

$1,673,500 

$1,223,385 

17. 

Respondent contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 (226-001) 

{$2,507,000 

$1,253,500 

$931,817 

2025-(226-011) [$3,347,000 

$1,673,500 

$1,223,385 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 (226-001) 

{0 

0 

0 

2025 (226-011) 

10 

0 

0

MTT Docket No. 25-002670 

Page 4 of 4 

19. 

Admit X__Deny 

Neither Admit Nor Deny. 

If denied, list the separate 

facts upon which Respondent relies in support of the denial (attach additional 

page if necessary): 

Respondent acknowledges Petitioner’ 

s beliefs as to the issues in this appeal 

but denies that those issue have merit and further denies that Petitioner is 

entitled to any relief. 

20. 

Admit 

X__ Deny 

Neither Admit Nor Deny. 

If denied, list the separate 

facts upon which Respondent relies in support of the denial (attach additional 

age if necessary): 

Respondent denies the allegations in Paragraph 20 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. 

21. 

List any separate and specific facts upon which Respondent relies to support 

every ground on which Respondent relies and also has the burden of proof 

(attach additional page if necessary): 

SEE ATTACHED AFFIRMATIVE DEFENSE 

22. 

List affirmative defenses and the separate and specific facts upon which 

Respondent relies in support of those affirmative defenses (attach additional 

age if necessary): 

SEE ATTACHED AFFIRMATIVE DEFENSE 

Signatur 

AVY 

OY 

ent's Bes Representative or, if none, Respondent: 

=n ae 

(A 

let {0 ) AGO] 

Printed Name of Respondent's L— Bossi or, if none, Respondent: 

Jennifer Czeiszperger 

Email Address: jennifer.czeiszperger@lansingmi.gov 

Mailing Address:

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

RIVERSHELL LANSING LLC 

Petitioner 

v 

MOAHR Docket 25-002670 

Parcel No. 23-50-40-36-226-001 

23-50-40-36-226-011 

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 

RESPONDENTS AFFIRMATIVE DEFENSES 

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

MTT Docket # 25-002670 

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 

taxable value is incorrect. 

F. Petitioner asks the Tribunal to grant it preference by application of a self-chosen method 

of assessment contrary to the intent, purpose and law of this state. 

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. 

L 

Any decrease in the value of Petitioner’s property was a result of its own intentional

MTT Docket # 25-002670 

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 

bated 

N 

| 

EXC OF “ | 

ated: 

vif 

~~ 

Indo 

(se IRYPY Cl 

Jenifer Czeiszperger, MMAO 

| 

/ 

City Assessor, City of Lansing 

31d Floor, City Hall 

124 

W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Rivershell Lansing LLC 

1 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No.25-002670 

City of Lansing 

, 

Respondent(s) 

PROOF OF SERVICE 

Jennifer Czeiszperger 

states that on 8/14/25 

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, MI 48909 

AND 

Stephen Polter 

2600 W Big Beaver, Ste L100 

Troy, Ml 48084 

ly (Ww {a Um AAD 

[Signature of person who is servihg/mailing copy] 

Jennifer Czeiszperger, MMAO 

[Print/type name of person serving/mailing copy]

City of Lansing - Assessors 

3rd Floor City Hall 

124 W. Michigan Ave. 

Lansing, Michigan 48933-1687 

M

PO

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