Petition - Nizan Alamo Twp.pdf

Neptune Kalamazoo LLC Petitioner Vs. Township Of Alamo Respondent · 26-001135-TT

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Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NEPTUNE KALAMAZOO, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 39-01-13-476-020 

Petitioner, 

 

 

 

 

 

 

 

39-01-13-476-040 

 

v. 

 

CHARTER TOWNSHIP OF ALAMO, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner NEPTUNE KALAMAZOO, LLC, by and through its attorneys, Williams 

Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner NEPTUNE KALAMAZOO, LLC, is a Michigan limited liability 

company with its registered office located at 1411 Third Street, Port Huron, MI 48060. 

2. 

Respondent Charter Township of Alamo is a Michigan township with its primary 

offices located at 7901 North 6th Street, Kalamazoo, MI 49009. 

The Subject Properties 

3. 

Petitioner owns properties identified as follows:

Petition Page 2 

Parcel Number 

Property Address 

39-01-13-476-020 

8213 Neptune 

39-01-13-476-040 

8233 Neptune 

 

These parcels are physically contiguous to each other. They are referred to collectively in this 

Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Kalamazoo County and are within the 

Plainwell Community school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Properties. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as commercial 

real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ assessments 

for property taxes in the amounts set forth in paragraph 1 of the attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties for the 2026 

tax year cannot exceed the amounts set forth in paragraph 2 of the attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in paragraph 3 of the 

attached Multiple Parcel Form. 

10. 

This Petition presents issues involving the Subject Properties’ valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), 

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available.

Petition Page 3 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, 

the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are 

based on the misapplication of valuation principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments are not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed 

Petitioner’s contentions of value set forth on the attached Multiple Parcel Form and granting 

Petitioner all other relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Brian E. Etzel 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 19, 2026 

 

 

Attorneys for Petitioner

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NEPTUNE KALAMAZOO, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 39-01-13-476-020 

Petitioner, 

 

 

 

 

 

 

 

39-01-13-476-040 

 

v. 

 

CHARTER TOWNSHIP OF ALAMO, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s March 2026 

Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

39-01-13-476-020 

 1,157,800 

 578,900 

 552,533 

39-01-13-476-040 

 966,400 

 483,200 

 367,664 

Totals: 

 2,124,200 

 1,062,100 

 920,197 

 

 

2. 

Petitioner contends that lawful 2026 assessments for the Subject Properties cannot 

exceed the following amounts: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

39-01-13-476-020 

 700,000 

 350,000 

 350,000 

39-01-13-476-040 

 500,000 

 250,000 

 250,000 

Totals: 

 1,200,000 

 600,000 

 600,000

Multiple Parcel Form Page 2 

 

3. 

The amounts in dispute for the 2026 tax year are therefore as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

39-01-13-476-020 

 457,800 

 228,900 

 202,533 

39-01-13-476-040 

 466,400 

 233,200 

 117,664 

Totals: 

 924,200 

 462,100 

 320,197

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