Answer to Petition.pdf
Thunder Bay Community Health Service, Inc. Petitioner Vs. City Of Alpena Respondent · 26-001125-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL THUNDER BAY COMMUNITY HEALTH SERVICES, INC. MTT Docket No. 26-001125 TT Petitioner, vs Parcel Nos. 093-357-000-008-00 093-637-000-200-00 CITY OF ALPENA, a Municipal Corporation Respondent. ADAM J. BRODY (P62035) DEBORAH I. ONDERSMA (P55907) VARNUM, LLP Attorneys for Petitioner 333 Bridge Street, N.W. P.O. Box 352 Grand Rapids, MI 49501-0352 (616) 336-6000 ajbrody@varnumlaw.com diondersma@varnumlaw.com WILLIAM A. PFEIFER (P45263) Attorney for Respondent City Attorney, City of Alpena 114 S. Second Avenue Alpena, Michigan 49707 (989) 354-8242 bill@alpenalegal.com ANSWER TO PETITION Respondent CITY OF ALPENA, by and through Berg Assessing and Consulting, Inc. Assessor for the City of Alpena, and William A. Pfeifer, City Attorney answers the Petition filed in this matter as follows:
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1. Denied as untrue. According the most recent Domestic Nonprofit Annual Report filed on August 14, 2026 Thunder Bay Community Health Service, Incorporated, its Registered Office is located at 15774 State Street, Hillman, Michigan 49746. 2. Neither admitted nor denied. While Petitioner may be a party in interest to the real property, the principal business located at the property is Bay Athletic Club, LLC. 3. Admitted. 4. Respondent admits that the subject property contains two parcels and is classified as 201 Commercial Improved. 5. Respondents admit that the involved property are contiguous parcels. 6. Neither admitted nor denied as the Board of Review decisions referenced by Petitioners were not attached to Respondent’s copy of the Petition. 7. Admitted. 8. Denied as untrue and Respondent leaves Petitioner to its proofs. 9. Neither admitted nor denied for lack of information. 10. Admitted. 11. Admitted. 12. Denied as untrue and Respondent leaves Petitioner to its proofs. 13. Respondent admits the values in dispute are correctly stated. 14. Denied as untrue and Respondent leaves Petitioner to its proofs. 15. Respondent denies the specific facts contained in paragraph 15 for the reason that the determinations by the City of Alpena Assessor are appropriate and proper under the laws of the State of Michigan in regard to taxation and value of property.
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16. Respondent denies the specific facts contained in paragraph 16 for the reason that the determinations by the City of Alpena Assessor are appropriate and proper under the laws of the State of Michigan in regard to taxation and value of property. AFFIRMATIVE DEFENSE The City of Alpena assessed the Petitioner’s property fairly and equitably as required by law. Petitioner’s Register Office according to its corporate filing is in Montmorency County, Michigan. Petitioners do not provide any direct healthcare services to the underserved population at the subject property. WHEREFORE, Respondent requests that the Tribunal affirm the 2026 values as follows: Parcel 093-357-000-008-00: True cash value Assessed value Taxable value $155,800 $77,900 $65,830 Parcel 093-637-000-200-00: True cash value Assessed value Taxable value $1,186,200 $593,600 $593,600 be SI P[2E ERT William A. Pfeifer (P45263) City Attorney ISACKSON & WALLACE, P.C. 114 S. Second Avenue Alpena, MI 49707 (989) 354-8242