Petition 2025 - Medical Behavorial et al Texas Twp.pdf

Medical Behavioral Hospital Of Mi LLC Dba Kalamazoo Bh Hospital, Petitioner Vs. Township Of Texas, Respondent · 25-002004-TT

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60714748.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Medical Behavioral Hospital of Michigan LLC, 

D/B/A Kalamazoo Behavioral Health Hospital, 

Petitioner, 

v. 

Texas Township, 

Respondent, 

MTT Docket No. ________ 

Parcel No. 09-02-376-002 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

Entire Tribunal Property Tax Petition 

Medical Behavioral Hospital of Michigan LLC, D/B/A Kalamazoo Behavioral Health 

Hospital (“Petitioner”), through its attorneys, Honigman LLP, says: 

1.

Petitioner's principal office address is 112 W. Jefferson Blvd., Suite 600, South 

Bend, IN 46601. 

2.

Petitioner is a party in interest with respect to property taxes on tax parcel number 

09-02-376-002 ("Petitioner's Property") 

3.

Petitioner’s Property has an address of 5802 S. 9th St., Kalamazoo, MI 49009 

4.

Petitioner’s Property is located in Kalamazoo County, Michigan. 

5.

Respondent, Texas Twp., assesses and collects property taxes on Petitioner's 

Property.

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60714748.1 

6.

Respondent’s Board of Review set the 2025 taxable value of Petitioner's Property 

at $7,417,117 and set the 2025 assessed value of Petitioner's Property at $7,708,900, which will 

result in a state equalized value in the same amount based upon the tentative equalization factor. 

7.

Petitioner's Property is classified as commercial real. 

8.

Petitioner's Property is presently used or available for use for commercial purposes. 

9.

Petitioner believes that Petitioner's Property was originally designed to be used for 

commercial purposes. 

10.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

11.

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any losses under MCL 211.27a(2)(a). 

12.

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any additions under MCL 211.27a(2)(a). 

13.

A board of review protest was not required for Petitioner’s Property. 

14.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected on Petitioner’s Property, are 

invalid and unlawful for the following reasons: 

(a) 

The 2025 assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

The 2025 assessment, including state equalized value and/or taxable value, 

is at a higher percentage of true cash value than permissible under the 

Michigan Constitution and applicable statutes;

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60714748.1 

(c) 

The 2025 assessment, including taxable value and/or state equalized value, 

is based on an erroneous determination of the true cash value of that portion 

of Petitioner's Property that is taxable under Michigan law, and is based on 

the application of wrong principles; and 

(d) 

The 2025 assessment, including state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $7,417,117 to $5,500,000; (ii) reducing the 2025 

assessed and state equalized value of Petitioner's Property from $7,708,900 to $5,500,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Dated: May 30, 2025 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

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