25-001768.pdf
Tmt Lansing LLC, Petitioner Vs. City Of Lansing, Respondent · 25-001768-TT
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AD RECEIVED SEP 0 4 2025 MICHIGAN TAX TRIBUNAL STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC , MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001768 City of Lansing , Respondent. ENTIRE TRIBUNAL PROPERTY TAX ANSWER 1. X__Admit___Deny. Hf denied, state the parcel number for the property identified on the Entire Tribunal Property Tax Petition for the tax year or years at issue: (If more than one parcel is at issue, attach a completed Multiple Parcel Answer Form addressing all other parcels at issue.) 2. X__Admit Deny. If denied, the property identified on the Entire Tribunal Property Tax Petitionis ___real ___ personal. 3. X__Admit ___Deny. [f denied, identify the contiguous and non-contiguous parcels by parcel number (attach additional page if necessary): 4, ___Admit __ Deny. If denied, identify the parcel or parcels of personal property that are not located on a parcel of real property under appeal by parcel number (attach additional page if necessary): 5. NA Admit ____Deny. a. If denied, state when the personal property statements were filed, if at all: REAL PROPERTY APPEAL b. On what date did the March Board of Review commence: 6. X__Admit ___Deny. If denied, state the classification of the property identified on the Entire Tribunal Property Tax Petition for the tax year or years at issue:
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MTT Docket No. 25-001768 Page 2 of 4 7. 10. 11. 12. NA Admit ___Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional page if necessary): N/A Admit Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): N/A Admit Deny Neither Admit Nor Deny. If denied, state the facts upon which Respondent relies in support of the denial (attach additional page if necessary): N/A X __Admit___ Deny. If denied, in what County are the property or properties located in and what is the address of the property or properties: 1200 KEYSTONE AVE, LANSING MI 48911 X__Admit ___ Deny. If denied, what is the applicable local governmental unit: Admit Deny X__ Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional page if necessary): MAILING ADDRESS ON RECORD: 3400 BELLE CHASE WAY, LANSING MI 48911-4251
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MTT Docket No. 26-001768 Page 3 of 4 14. X Admit Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): 15. Admit Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): N/A 16. The values for the property identified above as established by Respondent's Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 (377-013) 586,600 293,300 203,300 2025 (377-002) 1,260,800 630,400 630,400 17. Respondent contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 (377-013) |586,600 293,300 293,300 2025 (377-002) |1,260,800 630,400 630,400 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 (377-013) [0 0 0 2025 (377-002) [0 0 0
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MTT Docket No. 25-001768 Page 4 of 4 19. Admit X Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional page if necessary): 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 2025 tax year. 20. Admit X Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): Respondent denies the allegations 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. 21. List any separate and specific facts upon which Respondent relies to support every ground on which Respondent relies and also has the burden of proof (attach additional page if necessary): SEE ATTACHED AFFIRMATIVE DEFENSE 22. List affirmative defenses and the separate and specific facts upon which Respondent relies in support of those affirmative defenses (attach additional age if necessary): SEE ATTACHED AFFIRMATIVE DEFENSE SE Respohdent’s Authorized Representative or, if none, Respondent: [\N CA MOA 1A Q0 AL 2 hl h\) \ J Printed Name of Respondent's Authorized Representative or, if none, Respondent: Jennifer Czeiszperger, MMAO Email Address: jennifer.czeiszperger@lansingmi.gov Mailing Address:
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL TMT LANSING LLC Petitioner v MOAHR Docket 25-001768 Parcel No. 33-01-05-03-377-002 & 33-01-05-03-377-013 CITY OF LANSING, Respondent Jennifer Czeiszperger, MMAO City Assessor 124 W. Michigan Avenue 3rd Floor, City Hall Lansing, MI 48933 (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov RESPONDENT’S AFFIRMATIVE DEFENSES 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
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MTT Docket # 25-001768 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 taxable value is incorrect. F. Petitioner asks the Tribunal to grant it preference by application of a self-chosen method of assessment contrary to the intent, purpose and law of this state. 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 equalization as to which it has no legal standing and cannot maintain a cause of action. IL Any decrease in the value of Petitioner’s property was a result of its own intentional
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MTT Docket # 25-001768 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 Petitioners Petition be dismissed with prejudice and that the Respondent be granted all attorney fees and cost wrongfully sustained. puet: _3|ZB12S OFFICE OF THE CITY ASSESSOR CITY OF LANSING By: 200 ol TRY, Jennifer Czeiszperger, MMaO I! ’ City Assessor, City of Lansing 31d Floor, City Hall 124 W Michigan Ave Lansing, Michigan 48933 Telephone: (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT Lansing LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No.25-001768 City of Lansing , Respondent(s) PROOF OF SERVICE Jennifer Czeiszperger states that on 8/28/25 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, Ml 48909 AND Ted Kuch - Krol, LLC 285 Fulton St, 31sr Floor New York, NY 10007 Jennifer Czeiszperger, MMAO [Print/type name of person serving/mailing copy]
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City of Lansing - Assessors 3rd Floor City Hall 124 W. Michigan Ave Lansing, Michigan 48933-1687 P E L