2026-06-12 TEG AQ2 LLC.pdf
Teg Aq2 LLC Petitioner Vs. City Of Grand Rapids Respondent · 26-000954-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL TEG AQ2 LLC, Docket No. 26-000954 Petitioner, v. Parcel No. 41-14-09-351-019 CITY OF GRAND RAPIDS, Respondent. / Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226 jcook@honigman.com Kendall R. O’Connor (P84036) Lee S. Schofield (P62748) Grand Rapids Department of Law Attorneys for Respondent 300 Monroe Avenue 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. Petitioner’s principal office address is 365 Route 59, Suite 110, Airmont, NY 10952. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth of the remaining allegations, and leaves petitioner to its proofs. 2. The subject real property, parcel number 41-14-09-351-019, is located at 2248 Briar Hills Dr. NE, Grand Rapids, MI, in Kent County (“Petitioner’s Property”). ANSWER: Admitted.
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2 3. Respondent, City of Grand Rapids, assesses and collects property taxes on Petitioner’s Property. ANSWER: Respondent admits the allegations in this paragraph. 4. In 2026, Respondent’s board of review set the taxable value of Petitioner’s Property at $6,862,142 and assessed Petitioner’s Property at $10,828,200. ANSWER: Respondent admits only that Respondent’s Board of Review set the values as alleged for Petitioner’s Property for the 2026 tax year. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in this paragraph. 5. The assessment will result in a state equalized value in the same amount based on the tentative equalization factor. ANSWER: Respondent admits only that the State Equalized Value (SEV) for Petitioner’s Property for tax year 2026 is the same as the Assessed Value. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in this paragraph. 6. Petitioner’s Property is classified as commercial real. ANSWER: Respondent admits only that Petitioner’s Property is classified as Commercial-Improved. Respondent lacks knowledge or information sufficient to form a belief as the truth of any remaining allegations in this paragraph. 7. Petitioner’s Property is presently used or available for use for commercial purposes. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in this paragraph. 8. Petitioner believes that Petitioner’s Property was originally designed to be used for commercial purposes. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in this paragraph. 9. To the undersigned’s best knowledge, Petitioner’s Property – commercial multifamily housing – is not subject to governmental regulatory agreements and a subsidy.
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3 ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in this paragraph. 10. This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in this paragraph. To the extent that Petitioner is alleging that Respondent’s determinations on any of the issues alleged are incorrect, Respondent denies the allegations as untrue. 11. At this time, Petitioner believes, as it relates to taxable value, there is a dispute relative to the value of a loss. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the truth of the allegations in this paragraph. 12. No board of review protest was required for Petitioner’s Property. ANSWER: This paragraph contains a legal conclusion for which no response is required. To the extent any response is required, Respondent lacks knowledge or information sufficient to form a belief as truth of the allegations in this paragraph. 13. The 2026 assessment – including the state equalized and taxable values – imposed on Petitioner’s Property, the taxes to be levied and collected on Petitioner’s Property, and the mode of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, because they (a) Exceed amounts permitted by the Michigan Constitution and applicable statutes; (b) Are calculated at or derived from higher percentages of true cash value than permissible under the Michigan Constitution and applicable statues; (c) Are based on the application of wrong principles and an erroneous determination of the true cash value of that portion of Petitioner’s Property that is taxable under Michigan law, if any; and (d) Discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection, and due process of law.
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4 ANSWER: This Paragraph 13 and all its subparts (a) through (d) contain legal conclusions to which no response is required. To the extent any response is required Respondent denies all allegations in this paragraph and its subparts (a) through (d) as untrue. 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 12 , 2026 By: /s/ Lee S. Schofield Lee S. Schofield (P62748) Assistant City Attorney Attorney for Respondent
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5 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 12, 2026, she served true and complete copies of Respondent’s Appearance and Answer to Petition via first class mail and email, upon: Jackie J. Cook Honigman LLP 2290 First National Building 660 Woodward Avenue Detroit, MI 48226 jcook@honigman.com /s/ Alma Echeverria Alma Echeverria