26-000774.pdf
Red Senior Living Holdings LLC Petitioner Vs. City Of Lansing Respondent · 26-000774-TT
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RECEIVED AUG 18 2026 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL RED SENIOR LIVING HOLDINGS LLC Petitioner v MOAHR Docket 26-000774 Parcel No. 33-01-01-14-426-007 CITY OF LANSING, Respondent Jennifer Hendrix, MMAO City Assessor 124 W. Michigan Avenue 3rd Floor, City Hall Lansing, MI 48933 (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov RESPONDENT’S ANSWER TO PETITIONER’S PETITION AND AFFIRMATIVE DEFENSES RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent admits the allegations in Paragraph 1. 2. Respondent admits the allegations in Paragraph 2. 3. Petitioner has not set forth any allegations to warrant a response. 4. Petitioner has not set forth any allegations to warrant a response.
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MTT Docket # 26-000774 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. Petitioner has not set forth any allegations to warrant a response. Respondent admits the allegations in Paragraph 10. Respondent admits the allegations in Paragraph 11. Respondent lacks the information and knowledge necessary to respond to the allegations in Paragraph 12. The owner of record is Red Senior Living Holdings, LLC, 150 E Borad St, Columbus, OH 43215. Respondent neither admits nor denies the allegations in Paragraph 13 for reason that they do not have sufficient knowledge to for a belief as to the truth of the allegations, and leaving Petitioner to their strictest proofs. Respondent admits the allegations in Paragraph 14. Petitioner has not set forth any allegations to warrant a response. 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 33-01-01-14-426-007 | $20,959,200 $10,479,600 $9,705,150 Respondent contends that the 2026 values for the property identified above are: Parcel Number True Cash Value Assessed Value Taxable Value 33-01-01-14-426-007 | $20,959,200 $10,479,600 $9,705,150 The 2026 values in dispute for the property identified above are: Parcel Number True Cash Value | Assessed Value | Taxable Value 33-01-01-14-426-007 $0 $0 $0 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 year, and leaving Petitioner to their strictest proofs.
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MTT Docket # 26-000774 have any “additions” or “losses” for the 2026 tax year, 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. OFFICE OF THE CITY ASSESSOR | A CITY OF LANSING Dated: 2 Zl 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 # 26-000774 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). D. 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. E. 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. F. Petitioner fails to allege specific and sufficient facts needed to establish the true cash value, assessed and taxable value for the subject property. G. 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 # 26-000774 L 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. J: Petitioner, in essence, seeks by petition to challenge the process of county and state equalization as to which it has no legal standing and cannot maintain a cause of action. K. 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. L. Respondent has properly and lawfully assessed Petitioner’s property and established its taxable value in accordance with statutory and constitutional requirements. M. 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 5 CITY OF LANSING Dated: 2ly Br nee I . adi Nowe yp Jennifer Hendrix, MMAO : City Assessor, City of Lansing 3d Floor, City Hall 124 W Michigan Ave Lansing, Michigan 48933 Telephone: (517) 483-4136
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STATE OF MICHIGAN ORETCHEN WHITHER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA LANSING DIRECTOR RED SENIOR LIVING HOLDINGS LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. 26-000774 CITY OF LANSING Respondent(s) PROOF OF SERVICE JENNIFER HENDRIX, MMAO states that on 3) / i [av 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 48809 AND SARAH R. BELLOLI 101 W BIG BEAVER, STE 945 TROY, MI 48084 A ud oud ins [Sighattire of person who is serving/mailing copy] JENNIFER HENDRIX, 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 - I NM TT FO. BX 202333 kn, PeAosy ER TET ATER E SRP-FME EEE