26-000731 X2.pdf
Reo Gateway, LLC Petitioner Vs. City Of Lansing Respondent · 26-000731-TT
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NB RECEIVED JUL 2 8 2026 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL REO GATEWAY, LLC Petitioner v MOAHR Docket 26-000731 Parcel No. 33-01-01-21-301-021 CITY OF LANSING, Respondent Jennifer Hendrix, MMAO City Assessor 124 W, Michigan Avenue 3rd Floor, City Hall Lansing, MI 48933 (517) 483-4136 Jennifer .czeiszperger@lansingmi.gov RESPONDENT’S ANSWER TO PETITIONER'S PETITION AND AFFIRMATIVE DEFENSES RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds to the allegations made in Petitioner's Petition as follows: 1. Respondent admits the allegations in Paragraph 1. 2. Respondent admits the allegations in Paragraph 2. 3. Respondent admits the allegations in Paragraph 3.
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MTT Docket # 26-000731 7. 9. Respondent lacks the information and knowledge necessary to respond to the allegations in Paragraph 7. The mailing address on record is 503 Mall Ct, Suite 312, Lansing, MI 48912. . Respondent neither admits nor denies the allegations in Paragraph 8 for reason that they do not have sufficient knowledge to for a belief as to the truth of the allegations, and [eaving Petitioner to their strictest proofs. Respondent admits the allegations in Paragraph 9. 10. The 2026 values for the property identified above as established by Respondent's Board 11. of Review are: Parcel Number True Cash Value | Assessed Value Taxable Value 33-01-01-21-203-021 | $8,208,600 $4,104,300 $4,104,300 Respondent contends that the 2026 values for the propeity identified above are: Parcel Number True Cash Value Assessed Value Taxable Value 33-01-01-21-203-021 | $8,208,600 $4,104,300 $4,104,300 12. The 2026 values in dispute for the property identified above ate: Parcel Number True Cash Value | Assessed Value | Taxable Value 33-01-01-21-203-021 | $0 $0 $0 13. Respondent acknowledges Petitioner's beliefs as to the issues in this appeal but denies that those issues have merit and further denies that Petitioner is entitled to any relief. Further, the subject property did not have any “additions” or “losses” for the 2026 tax year. 14. Respondent denies the allegations in Paragraph 14 for the reason that it is untrue, In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are constitutional. Further, the subject property did not have any “additions” or “losses” for the 2026 tax year.
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MTT Docket # 26-000731 OFFICE OF THE CITY ASSESSOR fo 34 OF LANSING ate Tul /5 AOR bred: _SU415,28 ud once ay Jennifer Hendix, MMAO City Assessor, City of Lansing 31d Floor, City Hall 124 W Michigan Ave Lansing, Michigan 48933 Telephone: (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov
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MTT Docket # 26-000731 AFFIRMATIVE DEFENSES PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the following affirmative defenses: A. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against the Respondent and to support Petitioner’s claim for relief. B. The Tribunal is charged with finding a property’s true cash value to determine the property’s lawful assessment, Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). C. Petitioner has the burden of establishing the property’s true cash value. See MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). B. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, and application of wrong principles or illegality on the part of the Respondent or its agents. C. Petitioner fails to allege the mode and method of assessing the subject property failed to conform to the mode and method applied in the case of all properties within the Respondent's taxing unit for the tax year in questions. D. Petitioner fails to allege specific and sufficient facts needed to establish the true cash value, assessed and taxable value for the subject property. E. Petitioner fails to allege specific and sufficient facts to support its allegations that the assessed value of the subject property, as equalized, is at a level other than 50% and it also fails to allege specific and sufficient facts to support its allegations that the subject property’s
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MTT Docket ff 26-000731
G.
Petitioner asks this Tribunal to grant it illegal preference by application of a method
of assessment different from that utilized in the assessment of other properties in the Respondent’s
taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers.
H.
Petitioner, in essence, secks by petition to challenge the process of county and state
equalization as to which it has no legal standing and cannot maintain a cause of action.
I
Any decrease in the value of Petitioner’s property was a result of its own intentional
acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden.
J.
Respondent
has
properly
and
lawfully
assessed
Petitioner’s
property
and
established its taxable value in accordance with statutory and constitutional requirements.
K.
Respondent reserves the right to add affirmative defenses which may become
known during the course of informal or formal discovery proceedings.
WHEREFORE, Respondent denies that the Petitioner
is entitled
to any relief and
respectfully requests that the Respondent’s assessed and taxable values for the year under appeal
be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be
granted all attorney fees and cost wrongfully sustained.
OFFICE OF THE CITY ASSESSOR
CITY OF LANSING
Dated:
SA {
[5 2036
By:
“T,
=
22 ons
lod LL
Jennifer re
MMAO
City Assessor, City of Lansing
3d Floor, City Hall
124 W Michigan Ave
Lansing, Michigan 48933
Telephone: (517) 483-4136Page 6
WON Gd STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR REO Gateway LLC y MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. 26-000731 Cily of Lansing . Respondent(s) PROOF OF SERVICE Jennifer Hendrix states that on July | 5,202 6 he/she [Name of person serving/mailing petition] [date of service] served a copy of the Answer relative to the above-captioned matter upon: [Provide name and address of the party/people being served] MTT P.O. Box 30232, Lansing, Ml 48309 AND Michael Matheson 200 Woodland Pass, Ste F East Lansing, MI 48823 = WAL ls Newey [Signaturé of person who is serving/maililg copy] Tenn Yor Wendie x [Print/type name of person serving/mailing copy)
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CITY OF LANSING ASSESSOR 3RD FLOOR, CITY HALL 124 W. MICHIGAN AVENUE LANSING, MICHIGAN 48933 Received JUL 23 20% LARA MTT 20,Box 30232 LANSING, Mm 45704 Fir FE eel ye pepe Eg eg lglg fobs 0