Andrew Apartments LTD - Answer to Petition.pdf

Andrew Apartments Ltd Div Housing, Petitioner Vs. City Of Grand Rapids, Respondent · 25-002250-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

ANDREW APARTMENTS LTD DIV HOUSING, 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

Docket No. 25-002250 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No. 41-18-11-100-039 

CITY OF GRAND RAPIDS, 

 

 

 

 

Respondent. 

___________________________________________________________________________ 

 

Steve Johnson 

Michigan Tax Appeal Services 

Representative for Petitioner 

436 N. Center Street 

Northville, MI 48167 

(248) 392-4342 

info@mitaxappeal.com 

Elizabeth J. Fossel (P41430) 

Kendall R. O’Connor (P84036) 

Grand Rapids Department of Law 

Attorneys for Respondent 

300 Monroe Ave NW, Suite 620 

Grand Rapids, MI 49503 

(616) 456-4029 

efossel@grand-rapids.mi.us 

koconnor@grand-rapids.mi.us 

______________________________________________________________________________ 

RESPONDENT’S APPEARANCE AND ANSWER TO PETITION 

WITH PROOF OF SERVICE 

 

 

NOW COMES Elizabeth J. Fossel and Kendall R. O’Connor 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: 41-18-11-100-039 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition Form 

addressing all other parcels at issue.) 

 

ANSWER: Admitted. 

 

2. The property identified above is x real personal. 

 

ANSWER: Admitted. 

 

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.) 

 

ANSWER: There are no allegations in paragraph 3 of Petitioner’s Petition, and 

therefore no response is required. 

 

4. Are all of the parcels of personal property located on a parcel of real property under appeal? 

Yes __ No x . (If no, separate Petitions are required for each parcel of personal property 

not located on a parcel of real property under appeal.) 

 

ANSWER: Respondent lacks knowledge or information sufficient to form a belief as 

to the truth of this allegation, 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: There are no allegations in paragraph 5 of Petitioner’s Petition, and 

therefore no response is required. 

 

6. The property identified above is classified as Commercial. 

 

ANSWER: Respondent admits the property is classified as 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. 

 

ANSWER: There are no allegations in paragraph 7 of Petitioner’s Petition, and therefore no 

response is required. 

 

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: There are no allegations in paragraph 8 of Petitioner’s Petition, and 

therefore no response is required. 

 

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: There are no allegations in paragraph 9 of Petitioner’s Petition, and 

therefore no response is required. 

 

10. The property or properties at issue are located in Kent County. The property or properties’ 

address is: 

3599 SE Camelot Dr., Grand Rapids, MI 49546 

 

ANSWER: Admitted. 

 

11. The assessment or assessments at issue were established by the (applicable local 

government unit): City of Grand Rapids 

 

ANSWER: Respondent admits the assessment at issue was established by the City of 

Grand Rapids. 

 

12. Petitioner’s legal residence or principal office address is: 

2329 Timberbrook Dr SE, Grand Rapids, MI 49546 

 

 

ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of this allegation, and leaves Petitioner to its proofs. 

 

13. This appeal involved 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 

 

ANSWER: Respondent neither admits nor denies the allegations in paragraph 13 of 

Petitioner’s Petition for the reason that Respondent lacks knowledge or sufficient information to 

form a belief as to the truth of the allegations. 

 

14. The tax year(s) at issue are: 2025 

 

ANSWER: Admitted.

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: There are no allegations in paragraph 15 of Petitioner’s Petition, and 

therefore no response is required. 

 

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 

2025 

3,100,400 

1,550,200 

1,550,200 

 

 

 

 

 

 

 

 

 

 

 

 

 

ANSWER: Respondent denies as untrue the allegations and corresponding values as 

set forth in paragraph 16 of Petitioner’s Petition. The True Cash Value as established by 

Respondent is $3,061,800, and the State Equalized Value and Taxable Value were established 

at $1,530,900. 

 

17. Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

2,000,000 

1,000,000 

1,000,000 

 

 

 

 

 

 

 

 

 

 

 

 

 

ANSWER: Respondent denies as untrue the allegations and corresponding values as set forth 

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 

2025 

1,100,400 

550,200 

550,200 

 

 

 

 

 

 

 

 

 

 

 

 

 

ANSWER: Respondent denies as untrue the allegations and corresponding values in 

disputes as alleged in paragraph 18 of Petitioner’s Petition. The True Cash Value in dispute 

is $1,061,800, and the State Equalized Value and Taxable Value in dispute are $530,900.

19. Petitioner requests the following relief (attach additional page if necessary): 

Petitioner requests that the tribunal reduce the assessed and state equalized value from $1,550,200 to 

$1,000,000 and the taxable value from $1,550,200 to $1,000,000 and order a refund with interest as 

provided by the Tax Tribunal Act. 

 

ANSWER: Paragraph 19 merely states Petitioner’s request for relief to which no response is 

required. To the extent a response is required, Respondent denies that Petitioner is entitled to the 

relief sought or any remedy with regards to this Petition. 

 

20. List the separate and specific facts upon which Petitioner relies to support the relief 

requested (attach additional page if necessary) 

Our initial review of the subject property indicates the assessment exceeds 50% of the true case value. 

 

 

ANSWER: Respondent neither admits nor denies the allegations in paragraph 20 of 

Petitioner’s Petition for the reason that Respondent lacks knowledge or sufficient 

information to form a belief as to the truth of the allegations, and leaves Petitioner to its 

proofs. 

 

 

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, 2025 

 

 

 

By: /s/ Kendall R. O’Connor 

 

 

 

 

 

 

 

 

 

 Kendall R. O’Connor (P84036) 

 Assistant City Attorney 

 Attorney for Respondent

PROOF OF SERVICE 

 

 

Alma Echeverria, being first duly sworn, deposes and says that she is a Legal Secretary in the 

Office of the City Attorney, attorneys for Respondent herein, and that on August 7, 2025, she served true 

and complete copies of Respondent’s Appearance and Answer to Petition via first class mail and email, 

upon: 

 

 

Steve Johnson 

Petitioner’s Representative 

Michigan Tax Appeal Services 

436 N. Center Street 

Northville, MI 48167 

 

info@mitaxappeal.com 

 

 

 

 

 

 

 

 

 

/s/ Alma Echeverria 

 

 

 

 Alma Echeverria

← View full record