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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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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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.Page 3
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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