Full record / Kentwood - Lowe's Home Centers Inc. 25-002238 - Appearance Answer & ADs with POS 6-30-25.pdf

Kentwood - Lowe's Home Centers Inc. 25-002238 - Appearance Answer & ADs with POS 6-30-25.pdf

Lowes Home Centers Inc, Petitioner Vs. City Of Kentwood, Respondent · 25-002238-TT

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Page 1

{06939-001-00161453.1} 

1 

4898-5706-3760, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LOWE’S HOME CENTERS, INC., 

 

 

Petitioner, 

 

v 

 

CITY OF KENTWOOD, 

 

 

Respondent. 

 

MTT Docket No. 25-002238-TT 

 

Parcel No. 41-18-14-101-083 

 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(313) 465-7622 

mshapiro@honigman.com 

 

dstanley@honigman.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9343 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

APPEARANCE 

 

NOW COMES attorney Toby Koenig, of the law firm of Bloom Sluggett, PC, and hereby 

enters his appearance on behalf of Respondent City of Kentwood in this matter. 

 

 

 

 

 

 

Dated: June 30, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340

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{06939-001-00161453.1} 

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4898-5706-3760, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LOWE’S HOME CENTERS, INC., 

 

 

Petitioner, 

 

v 

 

CITY OF KENTWOOD, 

 

 

Respondent. 

 

MTT Docket No. 25-002238-TT 

 

Parcel No. 41-18-14-101-083 

 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(313) 465-7622 

mshapiro@honigman.com 

 

dstanley@honigman.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9343 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

 

/ 

 

 

RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent through its attorneys, Bloom Sluggett, PC, and hereby 

submits its Answer to Petition and Affirmative Defenses as follows: 

1. Respondent neither admits nor denies as it lacks sufficient knowledge or information 

to form a belief as to the truthfulness of the allegations in paragraph 1 of Petitioner’s 

petition and therefore leaves Petitioner to its proofs. 

 

2. Admitted. 

 

3. Admitted. 

 

4. Admitted that the subject property is classified as Commercial Real. Respondent 

neither admits nor denies the remaining allegations in paragraph 4 of Petitioner’s 

petition as Respondent lacks sufficient knowledge or information to form a belief as 

to the truthfulness of the allegations and therefore leaves Petitioner to its proofs.

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{06939-001-00161453.1} 

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4898-5706-3760, v. 1 

5. Respondent neither admits nor denies as it lacks sufficient knowledge or information 

to form a belief as to the truthfulness of the allegations in paragraph 5 of Petitioner’s 

petition and therefore leaves Petitioner to its proofs. 

 

6. Denied. 

7. Respondent neither admits nor denies as it lacks sufficient knowledge or information 

to form a belief as to the truthfulness of the allegations in paragraph 7 of Petitioner’s 

petition and therefore leaves Petitioner to its proofs. 

 

8. The allegations set forth in paragraph 8 and its subparts contain legal conclusions to 

which no response is required; Respondent otherwise denies the legal conclusions and 

any factual allegations contained therein, and further denies that the subject property 

was improperly assessed, and denies that Petitioner is entitled to any relief. 

 

9. The final paragraph of Petitioner’s petition contains a request for relief to which no 

response is required; Respondent otherwise denies that Petitioner is entitled to any 

relief. 

 

WHEREFORE, Respondent requests that the Tribunal dismiss Petitioner’s appeal with 

prejudice, and award Respondent its costs, attorney fees, and all such further and additional relief 

as this Tribunal may deem appropriate. 

 

AFFIRMATIVE DEFENSES 

1. Petitioner has failed to state a claim upon which relief can be granted. 

2. Petitioner’s claims against Respondent are barred because the valuation methods used 

by Respondent comply with the Constitution, state law, and prevailing State Tax Commission 

procedures. 

 

3. Respondent’s assessment reflects 50% of the subject property’s true cash value, and 

the values on the roll, including the taxable value, comply with the GPTA. 

 

4. Petitioner has failed to allege facts to support standing to bring this appeal or that it is 

a proper party-in-interest. 

 

5. Petitioner has failed to allege facts to support its allegation that the taxable value of 

the subject property is improper. 

 

6. Respondent reserves the right to identify further affirmative defenses as may become 

known through discovery.

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4898-5706-3760, v. 1 

 

 

 

 

 

 

 

Dated: June 30, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

 

 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom 

Sluggett, PC, and that on June 30, 2025, she served a copy of Respondent’s Appearance and 

Respondent’s Answer to Petition and Affirmative Defenses by First Class and electronic mail 

upon: 

 

 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(313) 465-7622 

mshapiro@honigman.com 

 

dstanley@honigman.com 

 

 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 

 

 Tonya Voakes

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