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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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) 965-9340Page 2
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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.Page 3
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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.Page 4
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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