Signed Written Answer.pdf

Ch Flats LLC Petitioner Vs. Township Of Big Rapids Respondent · 26-000972-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS & RULES 

MICHIGAN TAX TRIBUNAL 

C.H. FLATS, LLC, 

MOAHR Docket No. 26-000972 

Petitioner, 

Parcel No. 5405-022-015-002 

v 

CHARTER TOWNSHIP OF BIG RAPIDS, 

ANSWER TO PETITION 

Respondent. 

Sarah R. Belloli 

Eric D. Williams (P33359) 

Representative for Petitioner 

Attorney for Respondent 

101 West Big Beaver, Suite 945 

524 N State Street 

Troy, MI 48084 

Big Rapids, MI 49307 

(313) 230-0104 

(231) 796-8945 

Sarah.Belloli@Ryan.com 

edwl@att.net 

ANSWER TO PETITION 

NOW COMES the Charter Township of Big Rapids, by and through its attorney, 

Eric D. Williams, and says for its answer to the Petition filed by Petitioner C.H. Flats, LLC: 

1. 

2. 

Admitted that the parcel at issue is No. 54-05-022-015-002 

Admitted that the property is real property. 

Admitted that there is not more than one parcel of real property under appeal. 

Neither admitted nor denied. The allegation regarding personal property parcels 

is inapplicable to the appeal of the valuation of real property only. 

Admitted that there is no personal property under appeal. 

Admitted that the Property is classified as 201 Commercial-Improved. 

Admitted that Petitioner did not protest to the Board of Review.

8. Admitted that no protest was required or made. 

9. Admitted that the appeal was timely filed. 

10. Admitted that the Property at issue is located in Mecosta County, and the address 

of that property is 14465 Northland Drive, Big Rapids, MI 49307. 

11. Admitted 

that the assessment and valuation 

at issue were established by 

Respondent Big Rapids Charter Township. 

12. Admitted that the Petitioner's legal residence or principal office address is 6200 

Wing Ave SE, Grand Rapids, MI 49512. 

13. Admitted that this appeal involves issues relating to the Property's true cash and 

taxable values, and there was no addition or loss for the purpose of establishing 

the Property’s taxable value for the 2026 tax year. 

14. Admitted that the tax year at issue is 2026. 

15. Admitted that Petitioner only appeals the current tax year. 

16. The values for the Property as established by the Respondent's Board of Review 

are: 

Year 

True Cash Value 

| State Equalized Value | Taxable Value 

2026 

$4,242,200 

$2,121,100 

$1,979,829 

17. The Respondent Charter Township of Big Rapids contends that the values for the 

Property are as follows after settlement of prior appeal: 

Year 

True Cash Value 

| State Equalized Value | Taxable Value 

2026 

$4,242,200 

$2,121,100 

$1,848,600 

18. The values in dispute for the Property are: 

2

Year 

True Cash Value 

| State Equalized Value | Taxable Value 

2026 

$1,242,200 

$621,100 

$348,600 

19. The relief requested by Petitioner 

is without factual or legal support. The 

Respondent Charter Township of Big Rapids requests that the Tax Tribunal enter 

an order on the Property affirming the 2026 true cash value of $4,242,200 the state 

equalized value of $2,121,100, and the taxable value of $1,848,600. 

20. The facts upon which Petitioner relies are conclusory and denied as untrue. 

21. The Respondent Charter Township of Big Rapids relies on the following facts to 

support the relief requested: 

a. 

the assessment, including the state equalized value and taxable value of the 

Property, are proper and permitted by the Michigan Constitution and 

applicable statutes; and 

the assessment, including the state equalized value and taxable value of the 

Property, are at the correct percentage of true cash value permitted under 

the Michigan Constitution and applicable statutes; and 

the assessment, including the state equalized value and taxable value of the 

Property, are based upon the correct determination of the true cash value 

of that portion of the Property that is taxable under Michigan law; and 

the assessment, including the state equalized value and taxable value of the 

Property, and the mode 

of assessment employed by the Respondent 

Charter Township of Big Rapids, affords Petitioner all of its constitutional 

rights to equal protection, due process of law, and uniformity. 

3

22. The affirmative defenses and specific facts on which the Respondent relies in 

support of those affirmative defenses are: 

a. 

the assessment, including the state equalized value and taxable value of the 

Property, are proper and permitted by the Michigan Constitution and 

applicable statutes; and 

b. 

the assessment, including the state equalized value and taxable value of the 

Property, are 

at the correct percentage permitted under the Michigan 

Constitution and applicable statutes for the true cash value; and 

c. 

the assessment, including the state equalized value and taxable value of the 

Property, and 

the mode 

of assessment used 

by Respondent Charter 

Township of Big Rapids, 

d. Respondent reserves the right to supplement these affirmative defenses as 

additional defenses become known throughout discovery. 

WHEREFORE, the Respondent Charter Township of Big Rapids requests that the Tax 

Tribunal enter an order on the Property affirming the 2026 true cash value of $4,242,200, 

the state equalized value of $2,121,00, and the taxable value of $1,848,600. 

Dated: 

3¢ Eas Jodo 

Eric D. Williams (P33359) 

Attorney for Respondent 

524 N State Street 

Big Rapids, MI 49307 

(231) 796-8945 

edwl@att.net

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