26-000976.pdf

Felix Multi LLC/Alta Enterprises LLC Petitioner Vs. Township Of Blair Respondent · 26-000976-TT

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* 

H.WENDELL JOHNSON* 

RECEIVED 

SMITH SJOHNSON 

JUL 27 2026 

ATTORNEYS 

PROFESSIONAL CORPORATION 

MICHIGAN TAX TRIBUNAL 

LOUIS A. SMITH - FOUNDER 

TIMOTHY P. SMITH 

FIVE HUNDRED THIRTY FOUR EAST FRONT STREET 

(1939-2024) 

KENNETH M. PETTERSON 

POST OFFICE BOX 705 

L.PAGE GRAVES 

’ 

~ 

4 

Z 

ALLEN G. ANDERSON 

Ne 

SHO TWELL, 

TRAVERSE CITY, MICHIGAN 49685-0705 

(1953-2019) 

BRADLEYD, WIERDA 

TELEPHONE: (231) 946-0700 

4 

ih 

FACSIMILE: (231) 946-1735 

WEBSITE 

THEODORE M. LARKIN 

ith-. 

ERE A 

LANSING 517) 482-5142 

‘www.Smith-Johnson.com 

E-MAIL ADDRESS 

RETIRED SHAREHOLDER 

kdeback@smith-johnson.com 

July 23, 2026 

Department of Licensing & Regulatory Affairs 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

Re: 

Felix Multi LLC v Blair Township 

Docket No. 26-976-TT 

Dear Clerk: 

Enclosed for filing please find Answer to Petition and Affirmative Defenses, 2026 

Notice of Assessment, Taxable Valuation and Property Classification for Parcel 28-02-695-001- 

00 and Proof of Service in the above matter. 

Thank you for your assistance in this regard. If you have any questions or concerns, 

please contact me at your convenience. 

Sincerely yours, 

SMITH & JOHNSON, ATTORNEYS, P.C. 

Klas = 

Keeley A. DeBack 

KAD:wmw 

Enclosure 

cc w/enc: 

Sarah Belloli

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

FELIX MULTI LLC/ALTA ENTERPRISES LLC., 

Petitioner, 

v 

BLAIR TOWNSHIP — GRAND 

TRAVERSE, 

Respondent. 

Docket No. 26-000976-TT 

Parcel No. 28-02-695-001-00 

Bradley D. Wierda (P63811) 

Keeley DeBack (P89186) 

SMITH & JOHNSON, ATTORNEYS, P.C. 

Attorneys for Respondent 

534 E. Front St. — PO Box 705 

Traverse City, MI 49685 

(231) 946-0700 

kdeback(@smith-johnson.com 

bwierda@smith-johnson.com 

Sarah R. Belloli 

Ryan, LLC 

Representative for Petitioner 

101 West Big Beaver 

Suite 945 

Troy, MI 48084 

(313)230-0104 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, Blair Township, by and through its attorneys, Smith & 

Johnson, Attorneys, P.C., and for its Answer, states as follows: 

1) 

Respondent admits the Property Parcel Number of the subject property is 28-02-695-001-00.

4) 

Respondent admits that paragraph 4 

is inapplicable because the Petition challenges only the 

assessment of real property and therefore no answer is required. 

5) 

Respondent admits that paragraph 5 is inapplicable because the Petition does not involve personal 

property and therefore no answer is required. 

6) 

Respondent admits that the Subject Property is classified as 201 Commercial-Improved. 

7) Upon information and belief, Respondent admits that Petitioner did not protest to the Board of 

Review. 

8) 

Respondent admits that paragraph 8 is inapplicable and therefore no answer is required. 

9) 

Respondent admits that paragraph 9 is inapplicable and therefore no answer is required. 

10) Respondent admits the address contained in Paragraph 10 of the Petition. 

11) Respondent admits the allegations in Paragraph 11 of the Petition. 

12) Respondent lacks sufficient information and knowledge necessary to respond to the truth of 

the allegations set forth in Paragraph 12 and, therefore, leaves Petitioner to its proofs. 

13) Respondent admits the allegations in Paragraph 13 of the Petition. 

14) Respondent admits the allegations in Paragraph 14 of the Petition. 

15) Respondent admits that paragraph 15 is inapplicable and therefore no answer is required. 

16) Respondent admits the allegations contained in Paragraph 16 of the Petition. 

17) The Respondent denies the allegations contained in Paragraph 17 of the Petition because they are 

untrue.

19) The Respondent denies that Petitioner is entitled to the relief requested in Paragraph 19 

and demands strict proof thereof. 

20) 

A. Respondent denies that the State Equalized Value exceeds fifty percent (50%) of the 

subject property’s True Cash Value or that the assessment violates any applicable 

statutory or constitutional limitation and demands strict proof thereof. 

B. Respondent denies that the assessment is based on improper or inaccurate valuation 

methodology, the use of non-representative data, failure to account for relevant property 

characteristics, application of incorrect assumptions, 

or that the assessment 

is not 

uniform with comparable properties or results in an excessive or unlawful tax burden 

and demands strict proof thereof. 

WHEREFORE, Respondent, Blair Township respectfully requests the Tribunal dismiss 

the Petition with prejudice, affirm Respondent's assessment and taxable value of the subject 

property, and award Respondent its costs and attorney fees. 

SMITH & JOHNSON, ATTORNEYS, P.C 

wa 

Bradley D. Wierda (P63811) 

Keeley A. DeBack (P89186) 

Attorneys for Respondent 

Dated: July 23, 2026

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, Blair Township, by and through its attorneys, Smith & 

Johnson, Attorneys, P.C., and asserts the following affirmative defenses: 

1. 

Petitioner has failed to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

Petitioner has failed to allege specific or sufficient facts to establish fraud, error of law, 

discrimination, application of improper principles, or illegality on the part of the 

Respondent. 

3. 

Petitioner has failed to allege how the mode and method of appraising its property failed 

to conform with the mode and method applied in the case of all of the properties in the 

Respondent's taxing unit for the year in question. 

4. 

Itisthe Petitioner’s burden to establish the subject property’s true cash value. See MCL 

205.737(3). 

5. 

The Petitioner bears the burden of proving by a preponderance of the evidence that the 

assessment is incorrect. 

6. 

Petitioner has failed to allege specific or sufficient facts to establish the true cash value, 

assessed value, and taxable value of it’s property.

the true cash value of the subject property. 

9. 

Petitioner fails to allege specific or sufficient facts to support its allegations that the 

property's taxable value is improper. 

10. Petitioner's claims are barred because the valuation methods used by Respondent 

followed statutory and constitutional requirements. 

11. Any decrease in 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. 

12. Respondent reserves the right to add additional affirmative defenses as they may become 

known during the course of these proceedings. 

Respectfully submitted, 

SMITH & JOHNSON, ATTORNEYS, P.C 

HK 

fOued— 

Dated: 

July 23, 2026 

Bradley D. Wierda (P63811) 

Keeley A. DeBack (P89186) 

Attorneys for Respondent

Michigan Department of Treasury, 

THIS 

IS 

NOT 

A TAX 

BILL 

L-4400 

1019 (Rev. 10-25) 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of Public Act 206 of 1893, Sec. 211.24¢ and Sec.211.34c, as amended. This is a model assessment notice to be used by the local assessor. 

FROM 

PARCEL IDENTIFICATION 

BLAIR TOWNSHIP 

PARCEL NUMBER: 

28-02-695-001-00 

PE SaiNe rs 

RTMENT 

PROPERTY ADDRESS: 

1061 STEPKE CT 

GRAWN, Mi 49637 

TRAVERSE CITY, MI 49685 

SCHOOL DISTRICT CODE: 

28010 

OWNER'S NAME AND ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: 

EXEMPTIONS 

FELIX MULTI LLC 

% Exempt As "Homeowners Principal Residence" 

0% 

WP CAREY INC, ONE MANHATTAN WEST 

% Exempt 

As "Quallfid Agricultural Property” 

0% 

Fo on FLOOR 

% Exempt As "MBT Industrial Personal": 

0% 

' 

% Exempt As "MBT Commercial Personal"; 

0% 

Exempt ~ roemed Veteran or 

CIYes 

[X] No 

Exempt 

As "Qualified Forest Property" 

[7] Yes 

No 

Exempt 

As "Development Property”: 

[dyes 

[X] No 

LEGAL DESCRIPTION: 

LOT 1 ALSO COM NE COR LOT 1 THN 43 TO C/L TH S 89 DEG 42' E 100' TH S 543' TH N 89 DEG 42' 

W 100' TH N 500' TO POB 

SEC 8 T26N R11W STEPKE SUBDIVISION PUBLIC UTILITY LINE EASEMENT - SEWER RECORDED 8-11-05 2005R-18108 

ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 

201 

Commercial 

PRIOR YEAR'S CLASSIFICATION 

201 

Commercial 

PRIOR AMOUNT 

CURRENT TENTATIVE 

CHANGE FROM 

; 

PRIOR YEAR TO 

YEAR: 

2025 

AMOUNT YEAR: 

526 

CURRENT YEAR 

1. TAXABLE VALUE: 

1,005,364 

1,032,508 

27,144 

2. ASSESSED VALUE: 

1186600] 

1,153,500 

3100] 

3. TENTATIVE EQUALIZATION FACTOR: 

1.000 

4. STATE EQUALIZED VALUE (SEV): 

1,156,600 

1,153,500] 

-3,100 

5. WAS THERE A TRANSFER OF OWNERSHIP IN 2025 THAT RESULTED IN A TAXABLE VALUE UNCAPPING? 

[7] Yes 

No 

6. Assessor Change Reason(s): 

Market Adjustment 

The 2026 Inflation rate Multiplier is: 1.027 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the Following: 

Name: 

Telephone Number: 

Email Address: 

WENDY L WITKOP 

(231) 276-9263 

107 

ASSESSOR@BLAIRTOWNSHIPMLGOV 

March Board of Review Appeal Information. The Board of Review will meet at the following dates and times: 

THE TAXABLE VALUE, THE ASSESSED VALUE, THE STATE EQUALIZED VALUE, THE PROPERTY CLASSIFICATION, OR THE

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

FELIX MULTI LLC/ALTA ENTERPRISES LLC., 

Petitioner, 

v 

BLAIR TOWNSHIP — GRAND 

TRAVERSE, 

Respondent. 

Docket No. 26-000976-TT 

Parcel No. 28-02-695-001-00 

Bradley D. Wierda (P63811) 

Keeley DeBack (P89186) 

SMITH & JOHNSON, ATTORNEYS, P.C. 

Attorneys for Respondent 

534 E. Front St. — PO Box 705 

Traverse City, MI 49685 

(231) 946-0700 

kdeback@smith-johnson.com 

bwierda@smith-johnson.com 

Sarah R. Belloli 

Ryan, LLC 

Representative for Petitioner 

101 West Big Beaver 

Suite 945 

Troy, MI 48084 (313)230-0104 

(313)230-0104 

Sarah.Belloli@Ryan.com 

Matthew.Dingman@Ryan.com 

Joan.Kleiner@Ryan.com 

PROOF OF SERVICE 

Wendy M. Webb says that on July 23, 2026, she did serve 

a copy of ANSWER TO 

PETITION AND AFFIRMATIVE DEFENSES 

and 

2026 NOTICE OF ASSESSMENT, 

TAXABLE VALUATION AND PROPERTY CLASSIFICATION for Parcel 28-02-695-001-00 

by depositing the same in 

a United States mail receptacle, with first-class postage thereon fully 

prepaid, in Traverse City, Michigan, enclosed in a sealed envelope plainly addressed to the following 

at said address: 

Sarah R. Belloli 

Ryan, LLC 

101 West Big Beaver, Suite 945 

Troy, MI 48084

SMITH & JOHNSON, ATTORNEYS 

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GRAND RAPIDS MI 

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PROFESSIONAL CORPORATION 

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POST OFFICE BOX 705 

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TRAVERSE CITY, MICHIGAN 49685-0705 

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Department of Licensing & Regulatory Affairs 

Michigan Tax Tribunal 

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P.O. Box 30232 

Lansing, MI 48909 

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