2026-10-07 901 Fulton Answer.pdf
901 Fulton LLC Petitioner Vs. City Of Grand Rapids Respondent · 26-001243-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL _______________________ 901 FULTON LLC, Petitioner, Docket No. 26-001243 v. Parcel No.: 41-13-26-283-012 CITY OF GRAND RAPIDS, Respondent. _____________________________________________________________________________ Steve Johnson Michigan Tax Appeal Services Representative for Petitioner 436 N. Center Street Northville, MI 48167 (248)-392-4342 info@mitaxappeal.com Kendall R. O’Connor (P84036) Lee S. Schofield (P62748) City of Grand Rapids Law Department Attorneys for Respondent 300 Monroe Ave. 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 enter their Appearance of Counsel on behalf of Respondent City of Grand Rapids, and answers Petitioner’s Petition as follows: 1. Property Parcel No: 41-13-26-283-012 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 1 of Petitioner’s Petition and leaves Petitioner to its proofs.
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2 2. The property identified above is x real personal. ANSWER: Respondent admits the allegations in paragraph 2 of Petitioner’s Petition. 3. If more than one parcel of real property is under appeal, are the properties contiguous? ____ Yes ____ No. (If no, separate Petitioners are required for each non-contiguous parcel.) ANSWER: There are no allegations in paragraph 3 of Petitioner’s Petition and therefore no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 3 of Petitioner’s Petition and leaves Petitioner to its proofs. 4. Are all of the parcels of personal property located on a parcel of real property under appeal? ____ Yes _x__ No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 4 of Petitioner’s Petition and leaves Petitioner to its proofs. 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): N/A. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 5 of Petitioner’s Petition and leaves Petitioner to its proofs. 6. The property identified above is classified as Commercial ANSWER: Respondent admits the allegations in paragraph 6 of Petitioner’s Petition. The real property with the parcel code number identified in paragraph 1 of Petitioner’s Petition is classified as 201 Commercial.
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3 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s ____ March ____ July ____ December Board of Review. ANSWER: There are legal conclusions in paragraph 7 of Petitioner’s Petition and so no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 7 of Petitioner’s Petition and leaves Petitioner to its proofs. 8. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary). N/A ANSWER: There are legal conclusions in paragraph 8 of Petitioner’s Petition and so no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 8 of Petitioner’s Petition and leaves Petitioner to its proofs. 9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach page if necessary): N/A ANSWER: There are legal conclusions in paragraph 9 of Petitioner’s Petition and so no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 9 of Petitioner’s Petition and leaves Petitioner to its proofs. 10. The property or properties at issue are located in Kent County. The property or properties’ address is: 901 W Fulton St, Grand Rapids, MI 49504 ANSWER: Respondent admits the allegations in paragraph 10 of Petitioner’s Petition. The real property with the parcel code number identified in paragraph 1 of Petitioner’s Petition has the location and common address alleged.
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4 11. The assessment or assessments at issue were established by the (applicable local government unit): City of Grand Rapids ANSWER: Respondent admits only that it establishes the assessments for the real property with the parcel code number identified in paragraph 1. Respondent lacks knowledge or information sufficient to form a belief as to the truth of any remaining allegations in paragraph 11 of Petitioner’s Petition and leaves Petitioner to its proofs. 12. Petitioner’s legal residence or principal office address is: 152 E 6th Street, Holland, MI 49423 ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 12 of Petitioner’s Petition and leaves Petitioner to its proofs. 13. This appeal involved issues relating to the (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 lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 13 of Petitioner’s Petition and leaves Petitioner to its proofs. 14. The tax year(s) at issue are: 2026 ANSWER: Respondent admits the allegations in paragraph 14 of Petitioner’s Petition. 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary): N/A ANSWER: There are no allegations in paragraph 15 of Petitioner’s Petition and therefore no response is required. To the extent a response is required, Respondent
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5 lacks knowledge or information sufficient to form a belief as to the truth the allegations in paragraph 15 of Petitioner’s Petition and leaves Petitioner to its proofs. 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 2,307,200 1,153,600 1,153,600 ANSWER: Respondent admits the allegations and corresponding values in paragraph 16 of Petitioner’s Petition. 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 1,849,480 924,740 924,740 ANSWER: Respondent denies the allegations and corresponding values in paragraph 17 of Petitioner’s Petition as untrue. 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 457,720 228,860 228,860 ANSWER: Respondent admits the allegations and corresponding values in dispute in paragraph 18 of Petitioner’s Petition. 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner requests that the Tribunal reduce the assessed, state equalized, and taxable values from 1,153,600 to 924,740 and order a refund with interest as provided by the Tax Tribunal Act. ANSWER: Respondent denies the allegations in paragraph 19 of Petitioner’s Petition as untrue and denies that Petitioner is entitled to any relief whatsoever.
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6 20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach additional page if necessary) Our initial review of the subject property indicates the assessment exceeds 50% of the true cash value. ANSWER: Respondent denies the allegations in paragraph 20 of Petitioner’s Petition 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: October 8, 2026 By: /s/ Lee S. Schofield Lee S. Schofield (P62748) Assistant City Attorney Attorney for Respondent
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7 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 October 8, 2026, she served true and complete copies of Respondent’s Appearance and Answer to Petition via first class mail and email, upon: Steve Johnson Michigan Tax Appeal Services Representative for Petitioner At: info@mitaxappeal.com /s/ Alma Echeverria Alma Echeverria