26-001570.pdf

Grand Rapids Ind Properties LLC Petitioner Vs. City Of Grand Rapids Respondent · 26-001570-TT

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Kendall 

R O'Connor, Director 

Patrick 

A. Beatty 

Michael C.Dalere 

Ordinance Enforcement Division 

(616) 456-3388 

Melissa A. Powell, Director 

Charles T. Koop. Il 

Kevin M. Bramble 

CITY OF GRAND RAPIDS 

MICHIGAN 

DEPARTMENT OF LAW 

PHILIP L. STROM 

City Attorney 

SARAH J.HARTMAN 

Deputy City Attorney 

620 City [all 

300 Monroe Ave, NW 

Grand Rapids, M[ 49205 

(616) 456-2181 

Fax (616) 456-4569 

RECEIVED 

JUN 2 92076 

MHEHIGAN 

TAX 

TRIBUNAL 

Elizabeth J. Fassel, Director 

Dylan M.Gill 

LeeS. Schofield 

June 25, 2026 

Department of Licensing and Regulatory Affairs 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

Re: 

GRAND RAPIDS IND PROPERTIES LLC 

v CITY OF GRAND RAPIDS 

Docket No. 26-001570 

Dear Clerk, 

Enclosed please find for filing Respondent’s Appearance and Answer to Petition with 

Proof of Service in connection with the above referenced matter. 

If you have any questions, please do not hesitate to contact our office. 

 § truly yours, 

Lee S. Schofie 

City of Grand Rapids

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 

Kendall R. O’Connor (P84036) 

Strategic Law Group 

Lee S. Schofield (P62748) 

Attorney for Petitioner 

Grand Rapids Department of Law 

3707 E Southern Ave 

Attorneys for Respondent 

Mesa, AZ 85206 

300 Monroe Ave NW, Suite 620 

rebecca@strategiclawgroup.com 

Grand Rapids, M1 49503 

(616) 456-3103 

koconnor@egrand-rapids.mi.us 

Ischofield@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.)

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-Impreved. 

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):

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 propetties’ 

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 

Ifthe 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

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 

Taxable Value 

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 

Taxable Value 

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.

| 

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 appeats 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

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

CITY 

OF GRAND RAPIDS 

DEPARTMENT OF LAW 

520 CITY HALL 

300 MONROE N.W. 

GRAND RAPIDS, MI 49503 

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MICHIGAN TAX TRIBUNAL 

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