Kentwood-Grand Stay Hotel Suites 26-000473 Appearance and Answer (7.27.26) final.pdf
Grand Stay Hotel Suites Inc. Petitioner Vs. City Of Kentwood Respondent · 26-000473-TT
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1 4912-8226-9121, v. 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL GRAND STAY HOTEL SUITES, INC., Petitioner, v CITY OF KENTWOOD, Respondent. MTT Docket No. 26-000473-TT Parcel No. 41-18-14-252-009 / Laura M. Hallahan (P42101) HALLAHAN & ASSOCIATES, P.C Attorneys for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.com Toby Koenig (P72367) Patrick Sweeney (P79822) 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 enterers his appearance on behalf of Respondent City of Kentwood in this matter. Dated: July 27, 2026 Respectfully submitted, BLOOM SLUGGETT, PC /s/ Toby Koenig Toby Koenig (P72367) Attorneys for Respondent 161 Ottawa Ave. NW, Suite 400 Grand Rapids, MI 49503
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2 4912-8226-9121, v. 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL GRAND STAY HOTEL SUITES, INC., Petitioner, v CITY OF KENTWOOD, Respondent. MTT Docket No. 26-000473-TT Parcel No. 41-18-14-252-009 / Laura M. Hallahan (P42101) HALLAHAN & ASSOCIATES, P.C Attorneys for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.com Toby Koenig (P72367) Patrick Sweeney (P79822) 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. Admitted. 2. There are no allegations in paragraph 2 of Petitioner’s petition. 3. Admitted. 4. Paragraph 4 of the petition contains a legal conclusion to which no response is required. 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. Paragraph 6 contains a legal conclusion to which no response is required; Respondent denies that the subject property’s true cash and taxable values are incorrect and further denies that Petitioner is entitled to any relief.
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3 4912-8226-9121, v. 1 7. Admitted. 8. Respondent denies that the values in paragraph 8 of Petitioner’s petition accurately reflect the values on the ad valorem assessment roll for tax year 2026. 9. Respondent denies the values alleged in paragraph 9 of Petitioner’s petition as untrue, denies that the subject property was improperly assessed, and denies that Petitioner is entitled to any relief. 10. Respondent denies that the values alleged in paragraph 10 of Petitioner’s petition accurately reflect the values in dispute, denies that the subject property was improperly assessed, and denies that Petitioner is entitled to any relief. 11. The allegations set forth in paragraph 11 and its subparts contain legal conclusions and requests for relief 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. 12. The final paragraph of Petitioner’s petition contains a request for relief to which no response is required; Respondent 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. Petitioner may not be a proper party in interest with standing to file this appeal. 7. Respondent reserves the right to identify further affirmative defenses as may become known through discovery.
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4 4912-8226-9121, v. 1 Dated: July 27, 2026 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 July 27, 2026, she served a copy of Respondent’s Appearance and Respondent’s Answer to Petition and Affirmative Defenses by First Class and electronic mail upon: Laura M. Hallahan HALLAHAN & ASSOCIATES, P.C Attorneys for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.com /s/ Tonya Voakes Tonya Voakes