25-001696.pdf
Bc Equities LP, Petitioner Vs. City Of Battle Creek, Respondent · 25-001696-TT
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RECEIVED MAY 27 2095 De STATE OF MICHIGAN MICHIGAN TAX TRigy, DEPARTMENT OF LICENSING & REGULATORY AFFAIRS wr MICHIGAN TAX TRIBUNAL BC Equities LP, Petitioner, \2 MTT Docket No. 25-001696 Battle Creek, TranInfosqé06 26125061-1 05/26/26 Chkil: 040746 Antz $300.00 Respondent. ID: HONIGHAN LLP / Daniel L. Stanley (P57052) C. Marcel Stoetzel, III (P61912) Honigman LLP City Attorney’s Office Attorneys for Petitioner Attorney for Respondent 222 North Washington Square 10 North Division Street Suite 400 Suite 216 Lansing, MI 48933-1800 Battle Creek, M1 49014 (517) 377-0714 (269) 966-3385 dstanley@honigman.com cmstoetzal@battlecreekmi.gov / Motion to Amend Petition to Contest 2026 Assessed and Taxable Values Petitioner, BC Equities LP, through its attorneys, Honigman LLP, moves to amend the Petition in this matter to include the following: I. In 2026, Respondent determined the taxable value of Petitioner’s Property to be $2,539,200 and Respondent assessed Petitioner’s Property at $2,539,200 , which will result in a state equalized value of the same amount, based upon the tentative equalization factor. 2 The 2026 assessment, including state equalized value and taxable value,
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(b) The 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; (c) The assessment, including taxable value and/or state equalized value, is based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law and is based upon the application of wrong principles; and (d) The 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 moves that this Motion be granted, and Petitioner requests that the Tribunal enter an Order: (i) reducing the 2026 assessed and state equalized value from $2,539,200 to $1,500,000 ; (ii) reducing the 2026 taxable value from $2,539,200 to $1,500,000 ; (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. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner /s/ Daniel L. Stanley Daniel L. Stanley (P57052) 222 North Washington Square Suite 400 Lansing, MI 48933-1800 (517)377-0714 By:
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL BC EQUITIES LP, Petitioner, \2 MTT Docket No. 25-001696 BATTLE CREEK, Respondent. / Proof of Service Lisa Joseph affirms that on May 27, 2026 she served a copy of Petitioner's Motion to Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service in connection with the above-entitled cause upon the following: C. Marcel Stoetzel, IIT Cmstoetzel@battlecreekmi.gov via electronic mail. Dated: May 27, 2026 /s/ Lisa Joseph Lisa Joseph
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Hownigman LLP COSTS ADVANCED AGCOUNT 040744 Invoice Date Invoice Number Invoice Narrative 5/27/26 24559387.1 040744 DLS/230134/511265 Motion to Amend Filing fee # 25-001696 BC Equities-Battle Creek Payment Amount 300.00 RECEIVED MAY 27 2026 MICHIGAN TAX TRIBUNAL