Full record / 2026.07.28 Answer to Petition re Grandville (CTL Propco).pdf

2026.07.28 Answer to Petition re Grandville (CTL Propco).pdf

Ctl Propco I LLC Petitioner Vs. City Of Grandville Respondent · 26-000593-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

_________________________ 

 

CTL PROPCO I LLC, 

 

 Petitioner, 

 

v. 

 

CITY OF GRANDVILLE, 

 

 Respondent. 

 

 

Docket No. 26-000593 

 

Parcel No. 41-17-29-151-014 

 

 

Laura M. Hallahan (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3089 

lhallahan@hallahanlaw.com 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Respondent 

Bridgewater Place 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com 

 

ANSWER TO PETITION 

 

 

Respondent, City of Grandville, by and through its attorneys VARNUM LLP, states as 

follows for its answer to Petitioner's Petition: 

1. ☒ The Property that is the subject of this appeal is one real property parcel: 

 

Parcel Number

41-17-29-151-014

Address

3774 Rivertown Pky SW

Classification

201 COMM IMP

Use

Retail

County

Kent

Sch Dist

Grandville Public Schools

 

ANSWER: 

Respondent admits the allegations of paragraph 1. 

 

2. ☒ N/A. If the assessment at issue was protested, the protest was made to 

Respondent's:

Page 2

2 

 

☐ March, 

☐ July, 

☐ December Board of Review. 

 

 

 

ANSWER: 

No allegation is made in paragraph 2; therefore, no response is required. 

Respondent affirmatively states that the Petition did not appeal the subject 

property to any of Respondent’s Boards of Review. 

 

3. Respondent, identified above, assesses and collects taxes on the subject property. 

 

ANSWER: 

Respondent admits that the City of Grandville, through its assessor and 

Board of Review, assesses and collects taxes assessed under Michigan’s 

General Property Tax Act on the subject property. 

 

4. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject 

property. 

 

ANSWER: 

Respondent neither admits nor denies whether Petitioner is a party-in-interest 

as such allegation consists of a legal conclusion to which no answer is required 

or given. Respondent does admit that CTL PROPCO I LLC is listed as the 

taxpayer of record in Respondent’s Assessor’s record. 

 

5. The Petitioner's principal office/legal residence address is: 66 Hudson Blvd E FL 24, 

New York, NY 10001. 

 

ANSWER: 

Respondent neither admits nor denies the location of Petitioner’s principal 

office or legal residence as Respondent is without information sufficient to 

form a belief as to this alleged fact. Respondent admits that the address of 

record that Respondent has for Petitioner is 66 Hudson Blvd E FL 24, New 

York, NY 10001. 

 

6. This appeal involves issues related to: 

 

☒ 

the subject property's true cash value and taxable values 

☐ 

the subject property's taxable value only 

 

there is a dispute as to the value of an addition or loss: ☐ Yes ☐ No 

☐ 

uniformity of the subject property's assessment 

☐ 

the subject property's exemption from ad valorem taxation under MCL _________ 

 

ANSWER: 

Respondent admits the allegations of paragraph 6, upon information and 

belief. 

 

 

7. The tax year at issue is 2026. 

 

ANSWER: 

Respondent admits the allegations of paragraph 7.

Page 3

3 

 

8. 

The values1 established by Respondent's Board of Review for the subject property 

are: 

 

Parcel Number 

 

TCV 

 

SEV 

 

TV 

41-17-29-151-014 

 

2,744,000 

 

1,372,000 

1,372,000 

 

ANSWER: 

Respondent admits that the values alleged in paragraph 8 are the tax year 

2026 values established by Respondent for the subject property. 

 

9. 

Petitioner contends that the values1 for the subject property are: 

 

Parcel Number 

 

 

TCV 

 

SEV 

 

TV 

41-17-29-151-014 

 

2,000,000 

 

1,000,000 

1,000,000 

 

ANSWER: Respondent admits only that the values asserted in paragraph 9 are those 

contended by Petitioner for tax year 2026. Respondent denies that the 

Petitioner's asserted values would be appropriate and further states that the 

subject property is properly and uniformly assessed. 

 

 

10. 

The values1 in dispute are: 

 

Parcel Number 

 

 

TCV 

 

SEV 

 

TV 

41-17-29-151-014 

 

744,000 

 

372,000 

372,000 

 

ANSWER: Respondent admits only that the values asserted in paragraph 10 correctly 

calculate the difference between the values asserted in paragraphs 8 and 9 and 

relate to tax year 2026. Respondent denies that the Petitioner's contended 

values would be appropriate and further states that the subject property is 

properly and uniformly assessed. 

 

 

11. 

Petitioner relies upon the following to support the relief requested: 

 

 

The 2026 values imposed on Petitioner's property, and the taxes to be levied and 

collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer 

for the reasons that: 

 

(a) 

The assessed, state equalized and/or taxable values exceed the amounts 

permitted by the Michigan Constitution and applicable statutes; 

 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages 

of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

 

1 TCV=true cash value, SEV=state equalized value, TV=taxable value.

Page 4

4 

 

 

(c) 

The assessed, state equalized and/or taxable values are based upon an 

erroneous determination of true cash value of that portion of Petitioner's 

property that is taxable under Michigan law and are based upon the 

application of wrong principles; and 

 

(d) 

The assessed, state equalized and/or taxable values, and the mode of 

assessment adopted by Respondent, discriminate against Petitioner and 

deny Petitioner its constitutional rights of uniformity, equal protection and 

due process of law. 

 

ANSWER: Respondent denies the allegations of paragraph 11, including all parts thereof, 

for the reason that they are not true. Respondent further states that the subject 

property is properly and uniformly assessed. 

 

 

Petitioner requests that the Tribunal enter an order reducing the 2026 values from those 

established by Respondent's Board of Review to those contended by Petitioner, and order refunds 

attributable to the reductions, with interest, as provided by the Tax Tribunal Act. 

 

ANSWER: 

Respondent denies that the relief requested by Petitioner for tax year 2026 

would be appropriate. The subject property is properly and uniformly 

assessed. 

 

WHEREFORE, Respondent prays that this Tribunal affirms Respondent's assessment of 

the property, dismiss Petitioner's Petition and award Respondent any other relief deemed 

appropriate, including costs and attorney fees. 

Respectfully submitted, 

 

 

 

 

 

 

VARNUM LLP 

 

 

 

 

 

 

Attorneys for Respondent 

 

Dated: July 28, 2026 

 

By:__/s/ Deborah I. Ondersma________________ 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

BUSINESS ADDRESS & TELEPHONE: 

 

 

 

 

 

 

 

Bridgewater Place 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

ajbrody@varnumlaw.com 

 

 

 

 

 

 

diondersma@varnumlaw.com

Page 5

5 

 

AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent states that it may rely on one or all of the following affirmative 

defenses: 

1. 

Petitioner has failed to state a claim upon which relief can be granted. 

2. 

Petitioner may not be a proper party in interest and the Tribunal therefore may not 

have jurisdiction over this appeal for this additional reason. 

3. 

Petitioner may not have standing to pursue this appeal. 

4. 

Petitioner’s claims against Respondent are barred because all assessment and 

valuation methods used by Respondent City of Grandville were in compliance with prevailing 

State Tax Commission procedures and in accordance with Michigan law. 

5. 

Petitioner is a foreign limited liability company that is not licensed to do business 

in Michigan, and therefore lacks capacity to bring this appeal in the Michigan Tax Tribunal under 

MCL 450.5007. 

6. 

Respondent reserves the right to add additional affirmative defenses made known 

to it through discovery in this matter. 

Respectfully submitted, 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

Attorneys for Respondent 

 

Dated: July 28, 2026 

 

 

By:__/s/ Deborah I. Ondersma__________ 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

 

Bridgewater Place 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 (616) 336-6000 

 

 

 

 

 

 

ajbrody@varnumlaw.com 

 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

29416642.1

PDF reading copy

← View full record