Pinery Park Apts LDHA LLC v Wyoming - 2026 Proof of Service.pdf
Pinery Park Apts Ldha LLC Petitioner Vs. City Of Wyoming Respondent · 26-001257-TT
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September 3, 2026 Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 MTT Docket No. 26-001257-TT Pinery Park Apts LDHA LLC, Petitioner, v City of Wyoming, Respondent. Dear Honorable Tribunal Enclosed for filing, with regards to the above referenced docket number, please find: 1. A Proof of Service indicating that a copy of the Petition was served on the appropriate parties. If you should have any questions or concerns, please contact me at 313.230.0104. Respectfully Submitted Ryan, LLC ___________________________ Mark T. McMerrell Petitioner’s Representative 600 Superior Avenue E, Suite 1810 Cleveland, OH 44114 313.230.0104 /s/ Mark T. McMerrell
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATOR AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL Pinery Park Apts LDHA LLC, Petitioner, MTT Docket No. 26-001257-TT v City of Wyoming, Respondent. PROOF OF SERVICE I, Janet Muchewicz, being duly sworn, deposes and says that on September 3, 2026, a copy of the Petition relative to the above-captioned matter, was served by U.S Postal Service upon: Certified Mail 1. City of Wyoming Assessor, 1155 28th St SW, Wyoming, Michigan 49509 2. City of Wyoming Clerk, 1155 28th St SW, Wyoming, Michigan 49509 First Class Mail 3. Kent County Clerk, 300 Monroe Ave NW #1, Grand Rapids, Michigan 49503 4. Wyoming Public Schools, 3575 Gladiola SW, Wyoming, Michigan 49519 5. Kent County Equalization, 300 Monroe Avenue NW, Grand Rapids, Michigan 49503 6. State Treasurer, Michigan Department of Treasury, 430 W. Allegan Lansing, Michigan 48922 ________________________ Janet Muchewicz Petitioner’s Representative 600 Superior Avenue E, Suite 1810 Cleveland, OH 44114 313.230.0104 /s/ Janet Muchewicz
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GRETCHEN WHITMER GOVERNOR STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS Lansing MARLON I. BROWN, DPA DIRECTOR Pinery Park Apts LDHA LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. City of Wyoming , Respondent. ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 41-17-11-252-051 (If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form addressing all other parcels at issue.) 2. The property identified above is X real personal. 3. If more than one parcel of real property is under appeal, are the properties contiguous? X Yes ___No. (If no, separate Petitions are required for each non- contiguous parcel.) 4. Are all of the parcels of personal property located on a parcel of real property under appeal? Yes No. (If no, separate Petitions are required for each parcel of personal property not located on a parcel of real property under appeal.) 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): 6. The property identified above is classified as 201 Commercial- Improved 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s March July December Board of Review. X NA MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 26-001257
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MTT Docket No. Page 2 of 4 8. If a protest was required and no protest was made, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): 9. If the appeal was not submitted by the deadline for the filing of an appeal for the classification or classifications of the properties at issue (i.e., May 31 or July 31 of the tax year involved), list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the assessment or assessments at issue (attach additional page if necessary): 10. The property or properties at issue are located in Kent County. The property or properties’ address is: 2300 NEWSTEAD AVE SW 2250 11. The assessment or assessments at issue were established by the (applicable local governmental unit): City of Wyoming 12. Petitioner’s legal residence or principal office address is: 4530 E THOUSAND OAKS BLVD, STE 100 WESTLAKE VILLAGE, CA 91362 13. This appeal involves issues relating to the (check all that are applicable): X the property or properties’ true cash and taxable values the property or properties’ taxable value only If the property or properties’ taxable value is at issue, is there a dispute as to the value of an addition or loss? Yes No uniformity of the property or properties’ assessment the property or the properties’ exemption from ad valorem taxation under MCL 14. The tax year(s) at issue are: 2026 26-001257
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MTT Docket No. Page 3 of 4 15. If more than the current tax year is being appealed, list the separate and specific facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior tax year or years (attach additional page if necessary):NA 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 2026 $7,386,600 $3,693,300 $3,144,962 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $5,000,000 $2,500,000 $2,500,000 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $2,386,000 $1,193,300 $644,962 19. Petitioner requests the following relief (attach additional page if necessary): 20. List the separate and specific facts upon which Petitioner relies to support the relief Petitioner relies on the following facts to support the relief requested: The subject assessments imposed on the subject property and the taxes to be levied and collected are invalid for the reason that: a. The equalized assessment thus imposed on the subject property is more than 50% of its true cash value in violation of the applicable statutory and constitutional limitations. b. The assessment is unlawful and is based upon the application of wrong principles and thereby operates as a fraud upon the taxpayer. Petitioner respectfully requests the Tax Tribunal hear this case and enter an order reducing the 2026 True Cash, State Equalized and Taxable Values and direct Respondent to refund to Petitioner any excess taxes, fees and penalties paid, plus interest and costs. 26-001257
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MTT Docket No. 26-001257 Page 4 of 4 Signature of Petitioner’s Authorized Representative or, if none, Petitioner: Email Address: john.maurice@ryan.com Mailing Address: John B. Maurice 101 West Big Beaver, Suite 945 Troy, Michigan, 48084 Telephone Number: (248) 809-5527 Date: 5/22/2026 /s/ John Maurice