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25-002287.pdf

206 Michigan LLC, Petitioner Vs. City Of Lansing, Respondent · 25-002287-TT

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Page 1

RECEIVED 

JUL 08 2025 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

206 MICHIGAN LLC 

Petitioner 

v 

MOAHR Docket 25-002287 

Parcel No. 33-01-01-16-402-002 

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 admits the allegations in Paragraph 1 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

MTT Docket # 25-002287 

7. 

Respondent admits the allegations in Paragraph 7. 

8. 

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 

Respondents mode of assessment are constitutional. 

10. 

The 2025 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-16-402-002 

$10,880,400 

$5,440,200 

$3,676,808 

Respondent contends that the 2025 values for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-16-402-002 | $10,880,400 

$5,440,200 

$3,676,808 

The 2025 values in dispute for the property identified above are: 

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

33-01-01-16-402-002 

$0 

$0 

$0 

Respondent denies the allegations in Paragraph 10 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. 

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.

Page 3

MTT Docket # 25-002287 

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

Page 4

MTT Docket # 25-002287 

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. 

I. 

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: 7 3 

I 1 

CITY OF 

@p, 

lhsssnpoges 

®/ U4 

Je nififer Czeiszflerger, MMAO 

/ pgs 

= Assessor, City of Lansing 

3d Floor, City Hall 

124 

W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136

Page 5

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON |. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

206 MICHIGAN LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No.25-002287 

CITY OF LANSING 

, 

Respondent(s) 

PROOF OF SERVICE 

JENNIFER CZEISZPERGER 

states that on 

Hi IS lzs 

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 

JON AYLSWORTH, PROPERTY TAX CONSULTANTS 

861 PINECREST AVE SE 

GRAND RAPIDS, MI 49506 

ing/mailing copy] 

JENNIFER CZEISZPERGER, MMAO 

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

Page 6

Clty of Lansing - Assessors 

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Lénging, Michigan 48955 1657 

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