2026-06-25 Answer GR Ind Properties.pdf
Grand Rapids Ind Properties LLC Petitioner Vs. City Of Grand Rapids Respondent · 26-001570-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL GRAND RAPIDS IND PROPERTIES LLC, Petitioner, Docket No. 26-001570 v. Parcel No. 41-18-20-126-001 CITY OF GRAND RAPIDS, Respondent. ___________________________________________________________________________ Rebecca Shaver Strategic Law Group Attorney for Petitioner 3707 E Southern Ave Mesa, AZ 85206 rebecca@strategiclawgroup.com Kendall R. O’Connor (P84036) Lee S. Schofield (P62748) Grand Rapids Department of Law Attorneys for Respondent 300 Monroe Ave NW, Suite 620 Grand Rapids, MI 49503 (616) 456-3103 koconnor@grand-rapids.mi.us lschofield@grand-rapids.mi.us ______________________________________________________________________________ RESPONDENT’S APPEARANCE AND ANSWER TO PETITION WITH PROOF OF SERVICE NOW COMES Kendall R. O’Connor and Lee S. Schofield for the City of Grand Rapids, who hereby enters their Appearance of Counsel on behalf of Respondent City of Grand Rapids, and answers Petitioner’s Petition as follows: 1. Property Parcel No: 41-18-20-126-001 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) ANSWER: Admitted. 2. The property identified above is x real personal. ANSWER: Admitted.
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2 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 non-contiguous parcel.) ANSWER: There are no allegations in paragraph 3 of Petitioner’s Petition, and therefore no response is required. 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.) ANSWER: There are no allegations in paragraph 4 of Petitioner’s Petition, and therefore no response is required.. 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): ANSWER: There are no allegations in paragraph 5 of Petitioner’s Petition, and therefore no response is required. 6. The property identified above is classified as Industrial. ANSWER: Respondent admits the property is classified as Industrial-Improved. 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s March ____ July ___ December Board of Review. ANSWER: There are no allegations in paragraph 7 of Petitioner’s Petition, and therefore no response is required. 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): ANSWER: There are no allegations in paragraph 8 of Petitioner’s Petition, and therefore no response is required. 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
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3 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): ANSWER: There are no allegations in paragraph 9 of Petitioner’s Petition, and therefore no response is required. 10. The property or properties at issue are located in Kent County. The property or properties’ address is: 1120 SE 36TH ST GRAND RAPIDS, MI 49508 ANSWER: Admitted. 11. The assessment or assessments at issue were established by the (applicable local government unit): City of Grand Rapids Assessor ANSWER: Respondent admits only the assessment at issue was established by the City of Grand Rapids and denies any remaining allegations in this paragraph as untrue. The proper Respondent in this matter is the City of Grand Rapids. 12. Petitioner’s legal residence or principal office address is: 3707 E Southern Ave Mesa, AZ 85206 ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth of this allegation, and leaves Petitioner to its proofs. 13. This appeal involved issues relating to the (check all that are applicable); x 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 ANSWER: Respondent lacks knowledge or sufficient information to form a belief as to the truth of the allegations in paragraph 13 and leaves Petitioner to its proofs.
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4 14. The tax year(s) at issue are: 2026 ANSWER: Admitted. 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): 2026 ANSWER: Respondent admits only that tax year 2026 is being appealed. 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 35,692,200 17,846,100 14,779,022 ANSWER: Respondent admits the allegations and corresponding values as set forth in paragraph 16 of Petitioner’s Petition. 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 17,010,114 8,505,057 8,505,057 ANSWER: Respondent denies as untrue the allegations and corresponding values as set forth in paragraph 17 of Petitioner’s Petition. 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 18,682,086 9,341,043 6,273,965
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5 ANSWER: Respondent admits the allegations and corresponding values in disputes as alleged in paragraph 18 of Petitioner’s Petition. 19. Petitioner requests the following relief (attach additional page if necessary): Given the significant disparity between the income-supported valuation and the current assessment, there appears to be strong support for a reduction in the 2026 assessed market value. The taxpayer is seeking reasonable tax relief to help offset substantial building expenses and elevated operating costs incurred during a financially challenging year. A reduction in the assessed value would more accurately reflect the property’s current economic condition, income-producing capability, and overall market position. ANSWER: Respondent denies all allegations in this Paragraph 19 as untrue. Paragraph 19 also states legal conclusions and/or Petitioner’s request for relief to which no response is required. To the extent a response is required, Respondent denies that Petitioner is entitled to the relief sought or any remedy with regards to this Petition. 20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach additional page if necessary) Please see attached income and expense docs/evidence packet (see attached). ANSWER: Respondent lacks knowledge or sufficient information to form a belief as to the truth of the allegations in paragraph 20, and leaves Petitioner to its proofs. Petitioner again denies as untrue that Respondent is entitled to the relief that it is requesting. WHEREFORE, Respondent City of Grand Rapids prays that this Honorable Tribunal dismiss the Petition and award Respondent its costs and attorney fees. CITY OF GRAND RAPIDS, a Michigan municipal corporation Dated: June 25, 2026 By: /s/ Lee S. Schofield Lee S. Schofield (P62748) Assistant City Attorney Attorney for Respondent
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6 PROOF OF SERVICE Alma Echeverria, being first duly sworn, deposes and says that she is a Paralegal in the Office of the City Attorney, attorneys for Respondent herein, and that on June 25, 2026, she served true and complete copies of Respondent’s Appearance and Answer to Petition via first class mail and email, upon: Rebecca Shaver Strategic Law Group 3707 E Southern Ave Mesa, AZ 85206 rebecca@strategiclawgroup.com /s/ Alma Echeverria Alma Echeverria