Response to Petition re Kooman Development(27708932.1).pdf

Kooman Development LLC, Petitioner Vs. City Of Grandville, Respondent · 25-002317-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

KOOMAN DEVELOPMENT, LLC 

 

Petitioner, 

v 

 

 

 

 

 

 

MTT Docket No. 25-002317 

 

CITY OF GRANDVILLE, 

 

 

 

Parcel No. 41-17-16-155-035 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jon Aylsworth 

Property Tax Consultants 

861 Pinecrest Ave SE 

Grand Rapids, MI 49506 

(269) 366-0300 

jack@skylinepropertytax.om 

 

Deborah I. Ondersma (P55907) 

VARNUM, LLP 

Attorneys for Respondent 

333 Bridge St., N.W., Suite 1700 

Grand Rapids, MI 49504-5356 

(616) 336-6000 

diondersma@varnumlaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

RESPONDENT'S ANSWER TO PETITION 

AND AFFIRMATIVE DEFENSES 

 

 

NOW COMES Respondent, City of Grandville, and in response to Kooman Development, 

LLC's Petition ("Petitioner") states as follows: 

1. 

Petitioner is Kooman Development LLC whose principal office or address is 8888 

Cavalier Court, Jenison, MI 49428. 

RESPONSE: Respondent neither admits nor denies the principal address of Petitioner, 

as Respondent is without sufficient information to form a belief as to the truth of the 

allegation. Respondent admits that the addressed alleged in paragraph 1 is the same 

address Respondent maintains in its records for the property owner of the subject 

property. 

 

2. 

Respondent, City of Grandville, establishes levies and collects the property taxes 

on the subject property.

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RESPONSE: Respondent admits that the City of Grandville established the tax year 2025 

assessment of the subject property. 

 

 

3. 

The property identification is # 41-17-16-155-035 and the subject property address 

is 3015 Sangra Ave SW, Grandville, MI 49418. The property is classified as industrial, real 

property. Petitioner's Property is presently used for industrial. Petitioner believes that Petitioner's 

Property was originally designed to be used for industrial. 

RESPONSE: Respondent admits that the Parcel 41-17-16-155-035 has an address of 3015 

Sangra Ave SW, Grandville, MI 49418 and classified as industrial improved real property. 

Respondent also admits that the property was originally designed to be used as industrial 

property. 

 

4. 

The property is located in Kent County and the school districts of Grandville Public 

and the Kent Intermediate School District and Grand Rapids Community College. 

RESPONSE: Respondent admits the allegations of paragraph 4. 

 

5. 

This matter involves issues relating to the true cash and taxable values for the parcel 

referenced above for the 2025 tax year. 

RESPONSE: Respondent admits the allegations of paragraph 5, upon information and 

belief. 

 

6. 

For tax year 2025, Respondent's Board of Review determined an assessed value of 

$1,375,100 a state equalized value of $1,375,100 and a taxable value of $1,263,099. 

RESPONSE: Respondent admits that the Respondent's Board of Review affirmed the 

assessed, state equalized, and taxable values identified in paragraph 6. 

 

 

7. 

Petitioner is filing directly with the Michigan Tax Tribunal. 

RESPONSE: Respondent admits the allegation of paragraph 7, upon information and belief.

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8. 

The 2025 values set by the respondent are invalid and unlawful as they exceed the 

amount allowed by Michigan law and the Michigan Constitution and do not reflect the true cash 

value of the fee simple interest as of the applicable tax date. 

RESPONSE: Respondent denies the allegations of paragraph 8 for the reason that they are 

not true. Respondent further states that the property is properly and uniformly assessed. 

 

 

9. 

Petitioner contends the true cash value of the subject property is $1,800,000 which 

would yield a state equalized value of $900,000 and the taxable value $900,000. The amount in 

contention is $475,100 for assessed value, state equalize and $363,099 for taxable value, and the 

amount in contention is $950,200 for true cash value. 

RESPONSE: Respondent denies that the values asserted by Petitioner in paragraph 9 would 

be proper. Respondent admits only that Petitioner has properly calculated the difference 

between its alleged values and the values established by Respondent. Respondent further 

states that the property is properly and uniformly assessed. 

 

 

10. 

Petitioner requests that the Tribunal reduce the assessed value and the taxable value 

of the subject parcel from $1,375,100 and $1,263,099 respectively to $900,000 and order a refund 

with interest, as provided by the Tax Tribunal Act. 

RESPONSE: Respondent denies that Petitioner's requested relief would be appropriate and 

further requests that this Tribunal affirm the assessment as established by Respondent. 

 

 

WHEREFORE, Respondent prays that this Tribunal affirms Respondent's 

assessment of the property, dismiss Petitioner's Petition and award Respondent any other

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relief deemed appropriate, including costs and attorney fees. 

 

 

 

 

 

 

 

 

VARNUM LLP 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

DATED: August 5, 2025 

 

By: 

/s/Deborah I. Ondersma 

 

 

 

 

 

 

 

 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

333 Bridge Street, N.W., Suite 1700 

 

 

 

 

 

 

Grand Rapids, MI 49504 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent and states that it may rely on one or all of the following 

affirmative defenses: 

1. 

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

2. 

Petitioner may not be a proper party in interest and the Tribunal therefore may not 

have jurisdiction over this appeal for this additional reason. 

3. 

Petitioner may not have standing to pursue this appeal. 

4. 

Petitioner’s claims against Respondent are barred because all assessment and 

valuation methods used by Respondent City of Grandville were in compliance with prevailing 

State Tax Commission procedures and in accordance with Michigan law.

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5. 

Respondent reserves the right to add additional affirmative defenses made known 

to it through discovery in this matter. 

 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Respondent 

 

DATED: August 5, 2025 

 

 By: /s/Deborah I. Ondersma 

 

 

 

 

 

 

 

 

 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

333 Bridge Street, N.W., Suite 1700 

 

 

 

 

 

 

Grand Rapids, MI 49504 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

27708932.1

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