26-001373.pdf
Iip-Mi 5 LLC Petitioner Vs. City Of East Lansing Respondent · 26-001373-TT
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101 West Big Beaver Suite 945 Troy, Michigan 48226 Tel. 313.230.0104 Fax 313.230.0114 www.ryan.com July 1, 2026 Re: IIP-MI 5 LLC v City of East Lansing MTT Docket No.: 26-001373 Dear Chief Clerk: Petitioner hereby serves all parties provided for in Michigan Tax Tribunal Rule 221 with its petition in this matter. Pursuant to the rule, the petition notes the docket number assigned by the tribunal and is served within 45-days of the issuance of the notice of docket number. If you have any questions regarding the enclosed pleading, please do not hesitate to contact our office directly at (313) 230-0104. Respectfully, Sarah R. Belloli Ryan, LLC cc: State of Michigan Treasurer Lansing Public Schools Ingham County Equalization Director Ingham County Clerk City of East Lansing Assessor City of East Lansing Clerk Enclosures
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Joan Kleiner STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFARIS MICHIGAN TAX TRIBUNAL IIP-MI 5 LLC Petitioner, v MTT Docket No.: 26-001373 City of East Lansing Respondent, Proof of Service Joan Kleiner, being duly sworn, deposes and says that July 1, 2026, she served a copy of the Petition relative to the above-captioned matter, via first class mail, upon: State of Michigan Treasurer Department of Treasury Treasury Building 430 West Allegan Lansing, MI 48922 Lansing Public School Board Secretary 519 W. Kalamazoo Lansing, MI 48933 Ingham County Equalization Director 341 S. Jefferson St. Mason, MI 48823 Ingham County Clerk 341 S. Jefferson St. Mason, MI 48854 and via certified mail, return receipt requested, upon: City of East Lansing Assessor 410 Abbot Rd Rm 109 East Lansing, MI 48823 City of East Lansing Clerk 410 Abbot Rd, Room 100 East Lansing, MI 48823 with proper postage affixed thereto. July 1, 2026
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR IIP-MI 5 LLC, Petitioner(s) v City of East Lansing, Respondent(s) MICHIGAN TAX TRIBUNAL MTT Docket No. ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 33-20-01-02-226-020 2. The property identified above is ☑ real ☐ personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? ☐ Yes ☐ No. (If no, separate Petitions are required for each noncontiguous parcel.) N/A 4. Are all of the parcels of personal property located on a parcel of real property under appeal? ☐ Yes ☐ No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) N/A 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): N/A 6. The property identified above is classified as 201 Commercial-Improved 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s ☐ March ☐ July ☐ December Board of Review. No protest to the Board of Review was required. MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 26-001373
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MTT Docket No. ____________________ Page 2 of 4 8. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): N/A 9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): N/A 10. The property or properties at issue are located in Ingham County. The property’s address is: 3315 COOLIDGE RD, EAST LANSING, MI 48823 11. The assessment or assessments at issue were established by the (applicable local governmental unit): City of East Lansing 12. Petitioner’s legal residence or principal office address is: 11440 WEST BERNARDO COURT #100, SAN DIEGO, CA 92127 13. This appeal involves issues relating to the (check all that are applicable): ☑ the property or properties’ true cash and taxable values ☐ the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or loss? ☐ Yes ☐ No ☐ uniformity of the property or properties’ assessment ☐ the property or the properties’ exemption from ad valorem taxation under MCL ______ 14. The tax year(s) at issue are: 2026 26-001373
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MTT Docket No. ____________________ Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary): N/A 16. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $2,807,200 $1,403,600 $1,156,396 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $1,700,000 $850,000 $850,000 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $1,107,200 $553,600 $306,396 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026 True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess of those properly owed, plus statutory interest; and (c) granting such other and further relief as is just and equitable. 20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach additional page if necessary): A. The equalized assessment thus imposed on the subject property is more than 50% of its true cash value in violation of the applicable statutory and constitutional limitations. B. The assessment is based on improper or inaccurate valuation methodology, including but not limited to the use of non-representative data, failure to account for relevant property characteristics, and/or application of incorrect assumptions. As a result, the assessment is not uniform with comparable properties and results in an excessive and unlawful tax burden. 26-001373
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MTT Docket No. ____________________ Page 4 of 4 Signature of Petitioner’s Authorized Representative or, if none, Petitioner: /s/ Sarah R. Belloli Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner: Sarah R. Belloli Email Address: Sarah.Belloli@Ryan.com Matthew.Dingman@Ryan.com Joan.Kleiner@Ryan.com Mailing Address: 101 West Big Beaver, Suite 945 Troy, Michigan 48084 Telephone Number: (313) 230-0104 Date: 2026-05-25 26-001373