Full record / Kentwood-Grand Stay Hotel Suites 26-000473 Appearance and Answer (7.27.26) final.pdf

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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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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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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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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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

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