MIMg XCV Bronco Club LLC.pdf
Mimg Xcv Bronco Club LLC Petitioner Vs. City Of Kalamazoo Respondent · 26-002589-TT
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Page 1
WGC
RECEIVED
APR 29 2026
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
MIMG XCV Bronco Club, LLC,
Petitioner,
MTT Docket No.
Vv
Parcel No. 06-19-483-003
City of Kalamazoo,
Respondent.
Stewart L. Mandell (P33781)
Jackie J. Cook (P68781)
Honigman, LLP
Attorneys for Petitioner
2290 First National Building
660 Woodward Avenue
Detroit, MI 48226-3506
(313) 465-7420
slmandell@honigman.com
jcook@honigman.com
Petition
MIMG XCV Bronco Club, LLC (“Petitioner”), through its attorneys, Honigman LLP, says:
L.
Petitioner's principal
office address
is 2195 North Highway
83,
Suite
14B,
Franktown, CO 80116-9664. Petitioner is a party in interest with respect to property taxes on tax
parcel number 06-19-483-003 ("Petitioner's Property"), with an address of 3201 MichigammePage 2
3. In 2026, Respondent determined the taxable value of Petitioner's Property to be $9,366,700 and assessed Petitioner's Property at $9,366,700, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 4. Petitioner's Property is classified as commercial improved. Petitioner's Property is presently used or available for use for commercial purposes. Petitioner believes that Petitioner's Property was originally designed to be used for commercial purposes. 5. To the best knowledge of the undersigned, the multifamily units comprising Petitioner’s Property are not subject to a governmental regulatory agreement or a subsidy. 6. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity, equal protection, and due process. 7. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. No board of review protest was required for Petitioner’s Property. 8. The 2026 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, is at a higher percentage of true cash value than permissible under the Michigan Constitution and
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Property that is taxable under Michigan law, and is based upon the application of wrong principles; and [C)]) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection, and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 2026 assessed value, state equalized value, and taxable value of Petitioner's Property from $9,366,700 to $7,000,000; (ii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is entitled. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: Stewart L. Mandell (P33781) Jackie J. Cook (P68781) 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7420 simandell@honigman.com Dated: April 29, 2026 icook@honigman.com
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Honiaman LLP COSTS ADVANCED ACCOUNT 040701 Invoice Date Invoice Number Invoice Narrative Payment Amount 4129/26 040701 277710/540842/DLS #4%$600,00%%% Motion to Amend Filing Fee 21074678.1