26-000693 X2.pdf
Apex Ultra Worldwide, LLC Petitioner Vs. City Of Lansing Respondent · 26-000693-TT
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NB APEX ULTRA WORLDWIDE LLC RECEIVED JUL 2 3 2026 MICH STATE OF MICHIGAN IGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL Petitioner v MOAHR Docket 26-000693 Parcel No. 33-01-01-08-301-321 : CITY OF LANSING, Respondent Jennifer Hendrix, MMAO i City Assessor 124 W. Michigan Avenue 3rd Flooy, City Hall ! Lansing, MI 48933 (517) 483-4136 Jennifer, czeiszperger@lansingmi.gov RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds to the allegations made in Petitioner’s Petition as follows: 1. RESPONDENT’S ANSWER TO PETITIONER’S PETITION AND AFFIRMATIVE DEFENSES Respondent lacks the information and knowledge necessary to respond to the allegations in Paragraph 1. The owner of record is Apex Ultra Worldwide, LLc and the mailing address on record is 2101 W Willow St, Lansing, MI 48917. Respondent admits the allegations in Paragraph 2. Respondent neither admits nor denies the allegations in Paragraph 3 for reason that they
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MTT Docket #f 26-000693 . The 2026 values for the property identified above as established by Respondent’s Board of Review are: Parcel Number True Cash Value Assessed Value Taxable Value 33-01-01-08-301-032 $3,695,600 $1,847,800 $1,682,096 . Respondent contends that the 2026 values for the property identified above are: Parcel Number True Cash Value Assessed Value Taxable Value 33-01-01-08-301-032 | $3,695,600 $1,847,800 $1,682,096 . The 2026 values in dispute for the property identified above are: Parcel Number True Cash Value | Assessed Value | Taxable Value 33-01-01-08-301-032 $0 $0 $0 10. 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 yea. 11. Respondent denies the allegations in Paragraph 11 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. 12. Respondent denies the allegations in Paragraph 12 for reasons that they are untrue, and leaving Petitioner to their strictest proofs. WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal dismiss the Petition; affirm Respondent’s assessed and taxable values, subject to county and state equalization., and award Respondent its cost and attorney fees.
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MTT Docket # 26-000693 Dated: Jdy (5,206 OFFICE OF THE CITY ASSESSOR CITY OF LANSING 2 Lo A ou deny Jennifer\Hendrix, MMAO City Assessor, City of Lansing 3d Floor, City Hall 124 W Michigan Ave Lansing, Michigan 48933 Telephone: (517) 483-4136 Jennifer.czeiszperger(@lansingmi.gov
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MTT Docket # 26-000693 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 # 26-000693 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, seeks by petition to challenge the process of county and state cqualization as to which it has no legal standing and cannot maintain a cause of action. L 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 July 157 d0)¢ : N pred y- OA oud Jennifer Hendrix, MMAO City Assessor, City of Lansing 34 Floor, City Hall 124 W Michigan Ave Lansing, Michigan 48933 Telephone: (517) 483-4136
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR Apex Ultra Worldwide LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. 26-000693 City of Lansing , Respondent(s) PROOF OF SERVICE Jennifer Hendrix states that on Fuly | 5, 2 62L 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 MI 48909 AND Jerome Pesick - WWR&P 380 N Old Woodward Ave, Ste 300 Birmingham, MI 48009 my Newd i [Signature of pefson who is serving/malling copy] Jennifer Hendirx, MMAO [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 MTT Pb. Box 3023% L ANS IAG, MA Hg909 LARA Received JUL 23 2028 yap TL) LEE FTE TE TE Ee ER FT PE TL TT EY