answer to petition-SNT.pdf

Kpg Holland Petitioner Vs. City Of Holland Respondent · 26-001550-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

KPG HOLLAND, 

 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 26-001550-TT 

 

CITY OF HOLLAND, 

 

 

 

Parcel No.: 70-16-26-300-075 

 

 

 

Respondent. 

 

 

Paul M. Jones, Jr. (P82235) 

Jones Pyatt Law, LLC 

Representative for Petitioner 

435 East Main Street, Suite 220 

Greenwood, IN 46143 

(317) 991-1864 

paul@jonespyattlaw.com 

 

Vincent L. Duckworth (P64222) 

Rachel L. Hillegonds (P67684) 

Attorney for Respondent 

Cunningham Dalman, P.C. 

321 Settlers Road 

Holland, MI 49423 

(616) 392-1821 

vince@cunninghamdalman.com 

rachel@cunninghamdalman.com 

 

 

ANSWER TO ENTIRE TRIBUNAL PROPERYT TAX PETITION 

 

Respondent, City of Holland, by and through its attorneys, Cunningham Dalman, P.C., and 

for its Answer to Entire Tribunal Property Tax Petition states as follows: 

1. 

Property Parcel No. 70-16-26-300-075. 

ANSWER: Admitted. 

2. 

The property identified above is _X_real ___personal. 

ANSWER: Admitted. 

3. 

Not applicable. 

4. 

Not applicable. 

5. 

Not applicable. 

6. 

The property is identified above is classified as 201-Commercial-Improved.

2 

ANSWER: Admitted. 

 

7. 

If the assessment or assessments at issue were protested, the protest was made to 

Respondent’s ___ March ___ July ___December Board of Review. 

ANSWER: Upon information and belief, Petitioner did not appeal to the Board of Review. 

 

8. 

Not applicable. 

9. 

Not applicable. 

10. 

The property or properties at issue are located in Ottawa County. The property or 

properties’ address is: 1269 E 16th St, Holland, MI 49423. 

ANSWER: Admitted. 

11. 

The assessment or assessments at issue were established by (applicable local 

governmental unit): City of Holland. 

ANSWER: Admitted. 

12. 

Petitioner’s legal residence or principal office address is: 5100 Charles Ct, Ste 101, 

Zionsville, IN 46077. 

ANSWER: Respondent is without sufficient information to admit or deny the allegations, 

and leaves Petitioner to its strictest proofs. 

 

13. 

This appeal involves issues relating to (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 is without sufficient information to admit or deny the allegations, 

and leaves Petitioner to its strictest proofs. 

 

14. 

The tax year(s) at issue are: 2026.

3 

ANSWER: Admitted. 

15. 

Not applicable. 

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 

35,531,800 

17,765,900 

17,456,535 

 

ANSWER: Admitted. 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

29,000,000 

14,500,000 

14,500,000 

 

ANSWER: Admitted, in part, to the extent Petitioner contends certain values should be 

applied to the property, but denied that Petitioner’s claimed values are accurate because 

they grossly understate the actual value of the subject property. 

 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

6,531,800 

3,265,900 

2,956,535 

 

ANSWER: Respondent admits that the values in dispute are correct but denies that the 

values in dispute are proper for the actual values of this property. 

 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Reduction of TCV, SEV and AV as indicated in paragraph 17. 

ANSWER: Denied that Petitioner is entitled to this relief in that Petitioner’s allegations 

understate the value of the property. 

 

20. 

List the separate and specific facts upon which Petitioner relies to support the relief 

requested (attach additional page if necessary): 

Comparable sales and/or income capitalization analysis. Petitioner may obtain an appraisal for the 

purpose of this appeal. Valuation evidence will be provided in accordance with the Tribunal's 

disclosure schedule.

4 

ANSWER: Denied. 

 

 

WHEREFORE, Respondent requests that the tribunal dismiss this proceeding and award 

Respondent its costs and attorney fees. 

 

Dated: October 22, 2026 

 

 

By: 

/s/ Vincent L. Duckworth 

 

 

 

 

 

 

 

 

 

Vincent L. Duckworth (P64222) 

 

 

 

 

 

 

 

Cunningham Dalman, P.C. 

 

 

 

 

 

 

 

City Attorney 

 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

 

321 Settlers Road, P.O. Box 1767 

 

 

 

 

 

 

 

Holland, MI 49422-1767 

 

 

 

 

 

 

 

(616) 392-1821

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