2026-08-07 VREI 99 LLC Answer.pdf
Vrei 99 LLC Petitioner Vs. City Of Grand Rapids Respondent · 26-000848-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL VREI 99 LLC, Petitioner, Docket No. 26-000848 v. Parcel No. 41-13-25-284-016 CITY OF GRAND RAPIDS, Respondent. / Sarah R. Belloli Ryan, LLC Representative for Petitioner 101 West Big Beaver Suite 945 Troy, Michigan, 48084 (313) 230-0104 Sarah.Belloli@Ryan.com Kendall R. O’Connor (P84036) Lee S. Schofield (P62748) Grand Rapids Department of Law Attorneys for Respondent 300 Monroe Avenue NW, Suite 620 Grand Rapids, MI 49503 (616) 456-3103 koconnor@grand-rapids.mi.us lschofield@grand-rapids.mi.us / RESPONDENT’S APPEARANCE AND ANSWER TO PETITION WITH PROOF OF SERVICE NOW COMES Kendall R. O’Connor and Lee S. Schofield for the City of Grand Rapids, who hereby enters their Appearance of Counsel on behalf of Respondent City of Grand Rapids, and answers Petitioner’s Petition as follows: 1. Property Parcel No: 41-13-25-284-016. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 1 of Petitioner’s Petition and leaves Petitioner to its proofs.
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2 2. The property identified above is ⛝ real ⬜ personal. ANSWER: Respondent admits the allegations in paragraph 2 of Petitioner’s Petition. 3. If more than one parcel of real property is under appeal, are the properties contiguous? ⬜ Yes ⬜ No. (If no, separate Petitions are required for each non-contiguous parcel.) N/A ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 3 of Petitioner’s Petition and leaves Petitioner to its proofs. 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.) N/A ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 4 of Petitioner’s Petition and leaves Petitioner to its proofs. 5. If parcels of personal property are under appeal, when were the personal property statements filed by parcel number (attach additional page if necessary): N/A ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 5 of Petitioner’s Petition and leaves Petitioner to its proofs. 6. The property identified above is classified as 201 Commercial-Improved ANSWER: Respondent admits the allegations in paragraph 6 of Petitioner’s Petition.
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3 7. If the assessment or assessments at issue were protested, the protest was made to Respondent’s ⬜ March ⬜ July ⬜ December Board of Review. No protest to the Board of Review was required. ANSWER: Paragraph 7 contains legal conclusions to which no response is required. To the extend a response is required, Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 7 of Petitioner’s Petition and leaves Petitioner to its proofs. 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): N/A ANSWER: Paragraph 8 contains legal conclusions to which no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 8 of Petitioner’s Petition and leaves Petitioner to its proofs. 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): N/A ANSWER: Paragraph 9 contains legal conclusions to which no response is required. To the extent a response is required, Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 9 of Petitioner’s Petition and leaves Petitioner to its proofs. 10. The property or properties at issue are located in Kent County. The property’s address is: 99 NW MONROE AVE, GRAND RAPIDS, MI 49503 ANSWER: Respondent admits the allegations in paragraph 10 of Petitioner’s Petition.
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4 11. The assessment or assessments at issue were established by the (applicable local government unit): CITY OF GRAND RAPIDS ANSWER: Respondent admits the allegations in paragraph 11 of Petitioner’s Petition. 12. Petitioner’s legal residence or principal office address is: 6200 WING AVE SE, GRAND RAIDS, MI 49512 ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 12 of Petitioner’s Petition and leaves Petitioner to its proofs. 13. This appeal involved issues relating to the (check all that are applicable); ⛝ 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_____________ ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 13 of Petitioner’s Petition and leaves Petitioner to its proofs. 14. The tax year(s) at issue are: 2026 ANSWER: Plaintiff admits the allegations in paragraph 14 of Petitioner’s Petition. 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): N/A ANSWER: Respondent lacks knowledge or information sufficient to form a belief as the allegations in paragraph 15 of Petitioner’s Petition and leaves Petitioner to its proofs.
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5 16. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $34,903,000 $17,451,500 $15,186,680 ANSWER: Respondent admits the allegations and corresponding values in paragraph 16 of Petitioner’s Petition. 17. Petitioner contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $22,000,000 $11,000,000 $11,000,000 ANSWER: Respondent denies as untrue the allegations and corresponding values in paragraph 17 of Petitioner’s Petition. 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $12,903,000 $6,451,500 $4,186,680 ANSWER: Respondent admits the allegations and corresponding values in dispute in paragraph 18 of Petitioner’s Petition. 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner respectfully requests that the Michigan Tax Tribunal enter an order: (a) reducing the 2026 True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values set forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in excess of those properly owned, plus statutory interest; and (c) granting such other and further relief as is just and equitable. ANSWER: Paragraph 19 of Petitioner’s Petition contains legal conclusions and a prayer for relief to which no response is required. To the extent a response is required, Respondent denies as untrue all allegations in paragraph 19 of Petitioner’s Petition and denies that Petitioner is entitled to any relief or remedy whatsoever with respect to this Petition because it is untrue.
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6 20. List the separate and specific facts upon which Petitioner relies to support the relief requested (attach additional page if necessary): 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 based on improper or inaccurate valuation methodology, including but not limited to the use of non-representative data, failure to account for relevant property characteristics, and/or application of incorrect assumptions. As a result, the assessment is not uniform with comparable properties and results in an excessive and unlawful tax burden. ANSWER: Respondent denies the allegations in paragraph 20 of Petitioner’s Petition as untrue. WHEREFORE, Respondent City of Grand Rapids prays that this Honorable Tribunal dismiss the Petition and award Respondent its costs and attorney fees. CITY OF GRAND RAPIDS, a Michigan municipal corporation Dated: August 7, 2026 By: /s/ Lee S. Schofield Lee S. Schofield (P62748) Assistant City Attorney Attorney for Respondent
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7 PROOF OF SERVICE Alma Echeverria, being first duly sworn, deposes and says that she is a Paralegal in the Office of the City Attorney, attorneys for Respondent herein, and that on August 10, 2026, she served true and complete copies of Respondent’s Appearance and Answer to Petition via first class mail and email, upon: Sarah R. Belloli Ryan, LLC 101 West Big Beaver Suite 945 Troy, Michigan, 48084 Sarah.Belloli@Ryan.com Matthew.Dingman@Ryan.com Joan.Kleiner@Ryan.com /s/ Alma Echeverria Alma Echeverria