03549629.pdf
Village Plaza Group LLC, Petitioner V City Of Mt Pleasant, Respondent · 24-003485-TT
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
SMALL CLAIMS DIVISION
_____________________
VILLAGE PLAZA GROUP LLC,
Petitioner,
v
CITY OF MT. PLEASANT,
Respondent.
_____________________________________/
MTT Docket No. 24-003485
Parcel No. 17-000-15318-00
RESPONDENT’S ANSWER AND
AFFIRMATIVE DEFENSES TO
PROPERTY TAX APPEAL PETITION
Sam Miller
PropTax America, LLC
26923 Havelock
Dearborn Heights, MI 48127
(313) 377-1447
nassco123@yahoo.com
_____________________________________/
Joshua D. Beard (P73388)
Mika Meyers PLC
Counsel for Respondent
900 Monroe Avenue, NW
Grand Rapids, MI 49503
(616) 632-8000
tax.tribunal.efile@mikameyers.com
jbeard@mikameyers.com
Respondent, City of Mt. Pleasant, by and through its attorneys, Mika Meyers PLC, answers
Petitioner’s Property Tax Appeal Petition as follows:
1.
Petitioner’s Contact Information:
Name: Village Plaza Group LLC
ANSWER:
Admitted upon information and belief.
2.
Petitioner’s Attorney/Authorized Representative’s Contact Information:
Sam Miller, PropTax America
26923 Havelock
Dearborn Heights, MI 48127
(313) 377-1447
nassco123@yahoo.com
ANSWER:
Admitted upon information and belief.Page 2
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3.
Subject Property Information:
How many parcels are you appealing? 1
Property Address: 911 & 913 E. Pickard St.
Taxing Authority: Mt. Pleasant
County: Isabella
ANSWER: Admitted upon information and belief.
4.
Issues being appealed: True Cash and Taxable Value
ANSWER:
Admitted upon information and belief.
5.
Explain the Reason for this Appeal: SEV is too high.
ANSWER:
Respondent admits this is Petitioner’s reason for appeal but denies as
untrue that the SEV is too high.
6.
Jurisdictional Issues:
Years you are appealing: 2024
Did you protest the assessment at a Board of Review? No.
If no, check applicable reason(s): Not required to attend.
Did you request a poverty exemption at the BOR? No.
ANSWER:
Respondent admits the allegations contained in paragraph 6.
7.
Valuation Information:
Parcel Identification Number: 17-000-15318-00
Classification of Property: Real / Commercial
Current Assessed Value as established by the BOR: 1,204,700
Current Taxable Value as established by the BOR: 1,204,700
What do you believe is the fair market value? 2,209,400
Multiply the True Cash Value by .5 and enter here. This is your contention of
Assessed Value: 1,104,700
If you believe the Taxable Value differs from your contention of Assessed Value,
enter your contention of Taxable Value: 100,000
ANSWER:
Respondent admit that: Parcel Number 17-000-15318-00 is the subject
of this tax appeal; the subject property is classified as real, commercial property; the 2024
Assessed Value is $1,204,700; and the 2024 Taxable Value is $1,204,700. Respondent also
admits that the fair market value of $2,209,400 and assessed value of $1,104,700 constitute
Petitioner’s 2024 value contentions for the property but denies as untrue that Petitioner’sPage 3
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value contentions accurately reflect the fair market and assessed values. Respondent believes
that Petitioner made a typographical error in contending that the taxable value of the subject
property is $100,000, but nevertheless denies as untrue that the contention accurately reflects
the taxable value.
8.
Classification Information: N/A
WHEREFORE, Respondent respectfully requests that this Honorable Tribunal affirm the
true cash, assessed, state equalized and taxable value of the subject property as placed on the 2024
and subsequent tax rolls by Respondent, dismiss the Petition, and grant Respondent its costs,
attorney’s fees, and such other relief as the Tribunal deems appropriate.
Respectfully submitted,
MIKA MEYERS PLC
Attorneys for Respondent
Dated: October 15, 2024
By: By: /s/ Joshua D. Beard
Joshua D. Beard (P73388)
900 Monroe Avenue, NW
Grand Rapids, MI 49503
(616) 632-8000
tax.tribunal.efile@mikameyers.comPage 4
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AFFIRMATIVE DEFENSES
Respondent, City of Mt. Pleasant, through its attorneys, Mika Meyers PLC, in defense of
Village Plaza Group LLC’s Petition, asserts the following affirmative defenses:
1.
The Petition fails to state a claim upon which relief may be granted.
2.
Petitioner may not be a party in interest in this tax appeal and may lack standing to
bring this appeal.
3.
Petitioner’s tax appeal may be time-barred if Petitioner failed to comply with MCL
205.735a, or otherwise failed to timely file its tax appeal, or both.
4.
Respondent reserves the right to add to these defenses.
WHEREFORE, Respondent respectfully requests that this Honorable Tribunal affirm the
true cash, assessed, state equalized and taxable value of the subject property as placed on the 2024
and subsequent tax rolls by Respondent, dismiss the Petition, and grant Respondent its costs,
attorney’s fees, and such other relief as the Tribunal deems appropriate.
Respectfully submitted,
MIKA MEYERS PLC
Attorneys for Respondent
Dated: October 15, 2024
By: /s/ Joshua D. Beard
Joshua D. Beard (P73388)
900 Monroe Avenue, NW
Grand Rapids, MI 49503
(616) 632-8000
tax.tribunal.efile@mikameyers.com