Full record / 26-000693.pdf

26-000693.pdf

Apex Ultra Worldwide, LLC Petitioner Vs. City Of Lansing Respondent · 26-000693-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.

Page 1

RECEIVED 

JUL 13 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

APEX ULTRA WORLDWIDE LLC 

Petitioner 

v 

MOAHR Docket 26-000693 

Parcel No. 33-01-01-08-301-321 

CITY OF LANSING, 

Respondent 

Jennifer Hendrix, MMAO 

City Assessor 

124 W. Michigan Avenue 

3rd Floor, City Hall 

Lansing, MI 48933 

(517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

AND AFFIRMATIVE DEFENSES 

RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds 

to the allegations made in Petitioners Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the allegations 

in Paragraph 1. 

The owner of record is Apex Ultra Worldwide, LLc and the mailing 

address on record is 2101 W Willow St, Lansing, MI 48917. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent neither admits nor denies the allegations in Paragraph 3 for reason that they

Page 2

MTT Docket # 26-000693 

7. 

The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

True Cash Value 

| Assessed Value 

Taxable Value 

33-01-01-08-301-032 | $3,695,600 

$1,847,800 

$1,682,096 

8. 

Respondent contends that the 2026 values for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-08-301-032 | $3,695,600 

$1,847,800 

$1,682,096 

9. 

The 2026 values in dispute for the property identified above are: 

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

33-01-01-08-301-032 

$0 

$0 

$0 

10. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief, 

Further, the subject property did not have any “additions” or “losses” for the 2026 tax 

year. 

11. Respondent denies the allegations in Paragraph 11 for the reason that it is untrue. In further 

answer, the assessed, state equalized and/or taxable values do not exceed permitted 

amounts, do not exceed the percentage of true cash value permitted by law, were correctly 

determined and are based upon correct application of proper principles, and the values and 

Respondent’s mode of assessment are constitutional. Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year. 

12. Respondent denies the allegations in Paragraph 12 for reasons that they are untrue, and 

leaving Petitioner to their strictest proofs. 

WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal 

dismiss the Petition; affirm Respondent’s assessed and taxable values, subject to county and state 

equalization, and award Respondent its cost and attorney fees.

Page 3

MTT Docket # 26-000693 

Dated: 

__{ 

| N22 

OFFICE OF THE CITY ASSESSOR 

by 

F 

LANSING 

ma they 

pes Hee MMAO 

City Assessor, City of Lansing 

3d Bloor, City Hall 

124 W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov

Page 4

MTT Docket # 26-000693 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the 

following affirmative defenses: 

A, 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against the Respondent and to support Petitioner’s claim for relief. 

B. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Athi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

C. 

Petitioner has the burden of establishing the property’s true cash value. See MCL 

205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

B. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, and application of wrong principles or illegality on the part of the Respondent or 

its agents. 

C. 

Petitioner fails to allege the mode and method of assessing the subject property 

failed to conform to the mode and method applied in the case of all properties within the 

Respondent’s taxing unit for the tax year in questions. 

D. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

E. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject property, as equalized, is at a level other than 50% and it also 

fails to allege specific and sufficient facts to support its allegations that the subject property’s

Page 5

MTT Docket # 26-000693 

G. 

Petitioner asks this Tribunal to grant it illegal preference by application of a method 

of assessment different from that utilized in the assessment of other properties in the Respondent’s 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitionet, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

LL 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

J. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

K. 

Respondent reserves the right to add affirmative defenses which may become 

known during the course of informal or formal discovery proceedings. 

WHEREFORE, Respondent denies that the Petitioner 

is entitled 

to any relief and 

respectfully requests that the Respondent’s assessed and taxable values for the year under appeal 

be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be 

granted all attorney fees and cost wrongfully sustained, 

OFFICE OF THE CITY ASSESSOR 

CITY OF LANSING 

Dated: 7/8)z¢, 

om 

I do 

dice 

Jenn| \fer Hendrix, MMAO 

City Assessor, City of Lansing 

34 Bloor, City Hall 

124 W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136

Page 6

ray, 

4 

I 

Hrs 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Apex Ulira Worldwide LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

! 

MTT Docket No, 26-000693 

City of Lansing 

, 

Respondent(s) 

PROOF OF SERVICE 

Jennifer Hendrix 

states that on 

7/8/26 

hefshe 

[Name of person serving/mailing petition} 

[date of service] 

served a copy of the Answer 

relative to the above-captioned matter upon: 

[Provide name and address of the party/people being served] 

MTT P.O. Box 30232, Lansing MI 48808 

AND 

Jerome Pesick 

- WWR&P 

380 N Old Woodward Ave, Ste 300 

Birmingham, Mi 48009 

fan ture of person who is serving/mailing copy 

Jennifer Hendirx, MMAO 

[Print/type name of person serving/mailing copy]

Page 7

CITY OF LANSING 

ASSESSOR 

3RD FLOOR, CITY HALL 

124 W. MICHIGAN AVENUE 

LANSING, MICHIGAN 48933 

TT ——— 

VHT 

Wet 

i 

bose 

mr 

0.0, PBaL H0r%)- 

Peneosy 

( ting 

Al 4570 9

PDF reading copy

← View full record