MIMg XCV Bronco Club LLC.pdf

Mimg Xcv Bronco Club LLC Petitioner Vs. City Of Kalamazoo Respondent · 26-002589-TT

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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 Michigamme

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

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

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

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