Full record / Wyoming - 4147 Eastern LLC 26-002629 Respondent's Answer (9.1.26) final.pdf

Wyoming - 4147 Eastern LLC 26-002629 Respondent's Answer (9.1.26) final.pdf

4147 Eastern LLC Petitioner Vs. City Of Wyoming, City Of Wyoming Respondents · 26-002629-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

4147 EASTERN, LLC, 

 

 

Petitioner, 

 

v 

 

CITY OF WYOMING, 

 

 

Respondent. 

 

MTT Docket No. 26-002629 

 

Parcel No. 41-18-19-426-011 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Jon Aylsworth 

PROPERTY TAX CONSULTANTS 

Representative For Petitioner 

861 Pinecrest Ave SE 

Grand Rapids, MI 49506 

(269) 366-0300 

jack@skylinepropertytax.com 

 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

/ 

 

 

 

 

RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

Respondent, City of Wyoming, through its attorneys hereby submits this Answer to 

Petitioner’s Petition filed in this matter. 

(1) Respondent lacks sufficient information and/or knowledge to form a belief as to the 

truthfulness of the allegations with respect to Petitioner’s legal residence or principal 

office address and leaves Petitioner to its proofs. 

 

(2) Admitted. 

 

(3) Admitted that the property identification number is 41-18-19-426-011; that the subject 

address is 4147 Eastern Avenue, SE, Wyoming, MI 49508; that the property is 

classified and, upon information and belief, is presently used as commercial real 

property. Respondent lacks sufficient information and/or knowledge to form a belief 

as to the allegations with respect to the intent of the original design of the subject 

property and therefore leaves Petitioner to its proofs. 

 

(4) Admitted. 

 

(5) Paragraph 5 of Petitioner’s petition merely restates Petitioner’s claim and therefore no 

response is required. To the extent a response is required, Respondent admits that

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{06982-001-00161464.1} 

2 

 

4922-7679-8668, v. 1 

Petitioner alleges claims involving the true cash and taxable values of the subject 

property for the 2026 tax year; however, Respondent denies that the subject property 

is improperly assessed and further denies that Petitioner is entitled to any relief. 

 

(6) Respondent admits that the Board of Review determined an assessed value of 

$2,676,200 and a taxable value of $2,676,200; however, Respondent denies that the 

Board of Review established the State Equalized Value. 

 

(7) Admitted. 

 

(8) The allegations in Paragraph 8 of the petition contain conclusions of law to which no 

response is required; Respondent otherwise denies the allegations as untrue. 

 

(9) Respondent denies as untrue the alleged values in Paragraph 9 of the petition. 

Respondent admits that Petitioner accurately calculated the amount in dispute based on 

Petitioner’s allegations; however, Respondent denies that the subject property was 

improperly assessed and further denies that Petitioner is entitled to any relief. 

 

(10) 

Paragraph 10 contains a request for relief to which no response is required; 

Respondent otherwise denies that Petitioner is entitled to any relief. 

 

 

AFFIRMATIVE DEFENSES 

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

 

2. Petitioner’s claims against Respondent are barred because the valuation methods used by 

Respondent comply with the Constitution, state law, and prevailing Michigan State Tax 

Commission procedures. 

 

3. Respondent’s assessment reflects 50% of the subject property’s true cash value and the 

values on the roll, including the taxable value, comply with MCL 211.27a. 

 

4. Petitioner may not be a party in interest capable of bringing this appeal as to the parcel at 

issue in this matter. 

 

5. Petitioner’s claims may be barred in whole or in part for failing to allege sufficient facts to 

invoke the Tax Tribunal’s jurisdiction. 

 

6. Respondent reserves the right to identify further affirmative defenses as may become 

known through discovery. 

 

WHEREFORE, Respondent requests that the Tribunal dismiss Petitioner’s appeal with 

prejudice and award Respondent its costs, attorney fees, and all such further and additional relief 

as this Tribunal may deem appropriate.

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{06982-001-00161464.1} 

3 

 

4922-7679-8668, v. 1 

 

 

Dated: September 1, 2026 

Respectfully submitted by, 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

 

Toby Koenig (P72367) 

Attorneys for Respondent 

 

 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom 

Sluggett, PC, and that on September 1, 2026, she served a copy of Respondent’s Appearance and 

Answer to Petition and Affirmative Defenses with Proof of Service by E-mail to: 

jack@skylinepropertytax.com and U.S. First Class mail upon: 

 

Jon Aylsworth 

PROPERTY TAX CONSULTANTS 

861 Pinecrest Ave SE 

Grand Rapids, MI 49506 

 

 

 

 

 

 

 

 

 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 

 

 Tonya Voakes

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