Full record / 2026-08-07 VREI 99 LLC Answer.pdf

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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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. 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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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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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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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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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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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

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