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POS and Answer for MTT 26-001256.pdf

Nreg US Holdings Ltd Petitioner Vs. Township Of Howell Respondent · 26-001256-TT

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Page 1

Howell Township 

3525 Byron Road + Howell, MI 48855 

Phone: (517) 546-2817 + Fax (517) 546-1483 

or iS 

www.howelltownshipmi.org 

) 

FOUNDED 

1836 

Embracing Our Future 

September 9, 2026 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

MTT Docket Number: 26-001256-TT 

Tax Code Numbers: 

4706-29-200-032 

Dear Chief Clerk: 

Enclosed you will find the property tax appeal answer form relating to the above Docket Number. All required 

documents are attached. Petitioner was mailed via certified mail a copy of the property tax appeal answer form 

through the United States Postal Service on September 9, 2026. 

If you have any questions or concerns, please do not hesitate to contact me. 

Sincerely, 

@>| hr 

Brent J. Kilpela 

Assessor 

Howell Township

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

NREG US HOLDINGS LTD. 

Petitioner, 

MTT Docket No. 26-001256 

Vv 

HOWELL TOWNSHIP, 

Respondent. 

LAW OFFICE OF HALLAHAN & ASSOCIATES, P.C. 

Brent J. Kilpela 

Laura M. Hallahan (P42101) 

HOWELL TOWNSHIP 

Attorney for Petitioner 

Representative for Respondent 

1750 S. Telegraph Road Suite 200 

3525 Byron Road 

Bloomfield Hills, MI 48302-0179 

Howell, MI 48855 

(248) 731-3089 

(517) 546-2817 

lhallahan@hallahanlaw.com 

assessor@howelltownshipmi.org 

RESPONDENT’S ANSWER TO ENTIRE TRIBUNAL PROPERTY TAX PETITION 

NOW COMES Respondent, Howell Township, by and through its representative, Brent J. 

Kilpela, and hereby answers Petitioner’s Entire Tribunal Property Tax Petition, stating as follows: 

1. 

Petitioner states interest in parcel 4706-29-200-032 with address 4293 Lambert. 

Classification is 201 Commercial with Use of Storage. County is Livingston and School District 

is Howell Public Schools. 

ANSWER: Respondent neither admits nor denies the allegations contained in the

Page 3

3. 

Petitioner states the respondent identified above, assesses and collects taxes on the 

subject property. 

ANSWER: Respondent admits the allegation contained in the above paragraph as 

true. 

4. 

Petitioner 

is 

a taxpayer/party-in-interest with respect to property taxes on the 

subject property. 

ANSWER: Respondent neither admits nor denies the allegations contained in the 

above paragraph and leaves Petitioner to its proofs. 

S. 

Petitioner’s legal residence or principal office address is Hugo Noort, Unit 101-403 

6" Street, New Westminster, BC V3L3B1. 

ANSWER: Respondent neither admits nor denies the allegations contained in the 

above paragraph and leaves Petitioner to its proofs. 

6. 

This appeal involves issues relating to the property’s true cash and taxable values. 

ANSWER: Respondent neither admits nor denies the allegations contained in the 

above paragraph and leaves Petitioner to its proofs. 

7. 

The tax year at issue is 2026. 

ANSWER: Respondent neither admits nor denies the allegations contained in the 

above paragraph and leaves Petitioner to its proofs. 

8. 

The 2026 values for the properties identified above as established by Respondent’s 

Board of Review are as follows: True Cash Value of $6,393,460; State Equalized Value of

Page 4

9. 

Petitioner contends that the 2026 values for the properties identified above are as 

follows: True Cash Value of $2,700,000; State Equalized Value of $1,350,000 and Taxable Value 

of $1,350,000. 

ANSWER: Respondent denies that Petitioner’s contentions of value are accurate and 

respectfully asks the Tribunal to deny Petitioner’s requests. 

10. 

Petitioner contends value 

in dispute for the properties identified above are as 

follows: True Cash Value $3,693,460; State Equalized Value of $1,846,730 and Taxable Value of 

$1,369,898. 

ANSWER: Respondent denies that Petitioner’s contentions of value are accurate and 

respectfully asks the Tribunal to deny Petitioner’s requests. 

11. 

Petitioner lists 4 separate and specific facts about the assessed, state equalized 

and/or taxable values. 

ANSWER: Respondent denies that Petitioner’s facts have any merit and respectfully 

asks the Tribunal to deny Petitioner’s requests. 

WHEREFORE, 

Respondent 

requests 

the 

Tribunal 

uphold 

the 

values 

assessed 

by 

Respondent and Order such other and further relief as this Honorable Tribunal deems just and/or 

equitable. 

Respectfully submitted,

Page 5

09/10/2026 

valuation Report 

07:42 AM 

Assessment 

Roll: 

2026 

BACKUP FROM 3/9/26 

4706-29-200-032 

2026 Est. T.C.V. 

NREG 

US HOLDINGS LTD 

property Class: 

201 

4293 

LAMBERT 

DR 

Map 

#: 

BRENT 

J. 

KILPELA ASSESSOR 

HOWELL, 

MI 48855-7338 

Land value Estimates 

for Land Table 201.COMMERCIAL 

RSC 

* 

Factors 

* 

Description 

Frontage 

Depth 

Front 

Depth 

Rate %Adj. 

Reason 

value 

COMMERCIAL NSC 

13.920 Acres 54,368 

250.000 

SITEWORK 

1,892,000 

13.92 Total 

Acres 

Total 

Est. 

Land value 

= 

1,892,000 

Land Improvement Cost 

Estimates 

Description 

Rate 

Size % Good 

cash value 

Total 

Estimated 

Land Improvements True Cash value 

= 

0 

Cost Estimates 

for Commercial/Industrial 

Building/Section: 

0 

Built 

2024 

Description 

of Occupancy: 

BUILDING 

A (MINI-STORAGE) 

Costs 

are taken from the warehouses 

- Mini 

cost schedules. 

<<<<< 

Calculator Cost Computations 

>55>> 

Class: 

S 

Quality: 

Good 

Stories: 

1 

Story Height: 

9 

Perimeter: 

0 

Base Rate for Upper Floors 

= 60.65 

Adjusted Square 

Foot Cost 

for Upper 

Floors 

= 60.65 

Total 

Floor Area: 

9,065 

Base Cost New of Upper Floors 

= 

549,792 

9065 Sq.Ft. 

of Sprinklers 

@ 

6.71, 

Cost New 

= 

60826 

Reproduction/Replacement 

Cost 

= 

610,618 

Eff.Age:1 

Phy .%Good/Abnr. 

Phy. /Func./Econ. /Overall %Good: 

98 /100/100/100/98.0 

Total Depreciated Cost 

= 

598,406 

ECF 

(MINI STORAGE) 

1.500 

=> Tcv of Bldg: 

0 

= 

897,608 

Replacement Cost/Floor Area= 67.36 

Est. TCV/Floor Area= 99.02 

Cost Estimates 

for Commercial/Industrial 

Building/Section: 

0 

Built 

2024 

Description 

of Occupancy: 

OFFICE 

1ST FL/APARTMENT 2ND 

Costs 

are taken 

from the office Buildings 

cost schedules. 

<<<<< 

calculator Cost Computations 

>>>>> 

Class: 

Ss 

Quality: 

Good 

Stories: 

2 

Story Height: 

9 

Perimeter: 

0 

Base Rate for Upper Floors 

= 218.01 

(10) 

Heating system: 

Package Heating 

& Cooling 

Cost/sqFt: 

32.69 

100% 

Adjusted Square 

Foot Cost 

for 

Upper 

Floors 

= 250.70 

Total 

Floor Area: 

1,716 

Base Cost New of Upper 

Floors 

= 

430,201

Page 6

09/10/2026 

valuation Report 

B 

Assessment Ro11: 

2026 

07:42 AM 

BACKUP FROM 3/9/26 

Class: 

S 

Quality: 

Good 

Stories: 

1 

Story Height: 

8 

Perimeter: 

0 

Base Rate for Upper Floors 

= 61.61 

Adjusted Square 

Foot Cost 

for 

Upper 

Floors 

= 61.61 

Total 

Floor Area: 

6,600 

Base Cost New of Upper Floors 

= 

406,626 

Reproduction/Replacement Cost 

= 

406,626 

Eff.Age:1 

Phy. %Good/Abnr.Phy. /Func./Econ./Overall 

%Good: 

98 /100/100/100/98.0 

Total Depreciated Cost 

= 

398,493 

ECF 

(MINI 

STORAGE) 

1.500 

=> TCV 

of 

Bldg: 

0 

= 

597,740 

Replacement Cost/Floor Area= 61.61 

Est. 

TCV/Floor Area= 90.57 

Cost Estimates 

for Commercial/Industrial 

Building/Section: 

0 

Built 

0 

Description 

of Occupancy: 

BUILDING 

C (25x140) 

Costs 

are taken from the warehouses 

- Mini 

cost schedules. 

<<<<< 

Calculator Cost Computations 

>>>>> 

Class: 

S 

Quality: 

Good 

Stories: 

1 

Story Height: 

9 

Perimeter: 

0 

Base Rate for Upper Floors 

= 67.89 

(10) 

Heating system: 

Space Heaters, 

Radiant 

Cost/SqFt: 

6.16 

100% 

Adjusted Square 

Foot Cost 

for 

Upper 

Floors 

= 74.05 

Total 

Floor Area: 

3,500 

Base Cost New of Upper 

Floors 

= 

259,175 

Reproduction/Replacement Cost 

= 

259,175 

Eff.Age:1 

phy. %Good/Abnr. 

Phy. /Func./Econ. /overall %Good: 

98 /100/100/100/98.0 

Total 

Depreciated Cost 

= 

253,992 

ECF 

(MINI STORAGE) 

1.500 

=> TCV of Bldg: 

0 

= 

380,987 

Replacement Cost/Floor Area= 74.05 

Est. 

TCcV/Floor Area= 108.85 

Cost Estimates 

for Commercial/Industrial 

Building/section: 

0 

Built 

2024 

Description 

of Occupancy: 

BUILDING 

D 

(25x288) 

Costs 

are taken from the warehouses 

- Mini 

cost schedules. 

<<<<< 

calculator Cost Computations 

>>>>> 

Class: 

S 

Quality: 

Good 

Stories: 

1 

Story Height: 

10 

perimeter: 

0 

Base Rate for Upper Floors 

= 63.42 

Adjusted square 

Foot Cost for Upper Floors 

= 63.42 

Total 

Floor Area: 

7,200 

Base Cost New of Upper 

Floors 

= 

456,624

Page 7

09/10/2026 

valuation Report 

. 

Assessment 

Roll: 

2026 

07:42 AM 

BACKUP FROM 3/9/26 

Base 

Rate 

for 

Upper Floors 

= 65.32 

(10) 

Heating system: 

Package Heating 

& Cooling 

Ccost/sqFt: 

20.44 

40% 

Adjusted Square 

Foot Cost 

for Upper 

Floors 

= 73.496 

Total 

Floor Area: 

12,000 

Base Cost 

New of Upper Floors 

= 

881,952 

Reproduction/Replacement 

Cost 

= 

881,952 

Eff.Age:1 

Phy.%Good/Abnr.Phy./Func./Econ. 

/overall %Good: 

98 /100/100/100/98.0 

Total 

Depreciated 

Cost 

= 

864,313 

ECF 

(MINI STORAGE) 

1.500 

=> TCV of Bldg: 

6 

= 

1,296,469 

Replacement Cost/Floor Area= 

73.50 

Est. 

TCV/Floor Area= 108.04 

2026 

Est. T.C.V. 

4706-29-200-032 

= 

6,393,460 

Est. 

Tcv/Total 

Floor Area 

= 159.51 

2025 Assessed 

MBOR 

S.E.V. 

Base for Cap 

IRM 

2,511,573 

2,511,573 

2,511,573 

1,981,248 

2.70 

2026 

New 

Eq. Adjustment 

Loss 

Additions 

Tax Adjustment 

Losses 

685,157 

0 

0 

685,157 

53493 

0 

2026 Assessed 

MBOR 

S.E.V. 

Capped 

->Taxable<- 

PRE/MBT 

3,196,730 

3,196,730 

3,196,730 

2,719,898 

2,719,898 

0

Page 8

39' 

OFFICE 1ST FLOOR 

44" 1716 «| APARTMENT 2ND FLO

65' 

46 

33' 

107" 

51" 

9065 sf 

100 

BUILDING A MINI-STORAGE 

4706-29-200-032 

NREG 

US HOLDINGS 

LTD 

4293 LAMBERT DR 

BUILDING 

A

Page 9

50" 

132 

BUILDING B MINI-STOR

6600 sf 

NON-CONDITIONED

Page 10

BUILDING C MINI-STOR

NON-CONDITIONED 

3500 sf 

140’ 

25' 

4706-29-200-032 

~~ 

NREG 

US HOLDINGS 

LTD 

4293 

LAMBERT 

DR. 

BUILDING 

C

Page 11

23" 

BUILDING D MINI-STORAGE 

NON-CONDITIONED 

7200 sf 

4706-29-200-032 

288’ 

NREG 

US HOLDINGS 

LTD 

4293 

LAMBERT 

DR 

BUILDING 

D

Page 12

Building G 12000 sf 

270 

8

Climate Controlled 

Uncondit

52' 

8600 sf 

3400

85' 

12" 

1 To 

100° 

4706-29-200-032 

NREG 

US HOLDINGS 

LTD 

4293 LAMBERT DR 

BUILDING 

G 

BUILT 

I

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