Full record / Answer and Affirmative Defenses (26-001382)(008)(FIE Grand Rapids).pdf

Answer and Affirmative Defenses (26-001382)(008)(FIE Grand Rapids).pdf

Fie Grand Rapids (Mi) LLC Petitioner Vs. Township Of Caledonia Respondent · 26-001382-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

_____________________ 

FIE GRAND RAPIDS(MI) LLC, 

Petitioner, 

v 

CHARTER TOWNSHIP OF CALEDONIA, 

Respondent. 

_____________________________________/ 

MTT Docket No. 26-001382 

Parcel No. 41-23-05-200-008 

RESPONDENT’S ANSWER TO 

ENTIRE TRIBUNAL PROPERTY 

TAX PETITION AND AFFIRMATIVE 

DEFENSES 

Sarah R. Belloli 

Ryan, LLC 

Representative for Petitioner 

101 West Big Beaver, Suite 945 

Troy, MI 48084 

(313) 230-0104

Sarah.Belloli@Ryan.com

_____________________________________/ 

Joshua D. Beard (P73388) 

Mika Meyers PLC 

Counsel for Respondent 

900 Monroe Avenue, NW 

Grand Rapids, MI 49503 

(616) 632-8000

tax.tribunal.efile@mikameyers.com

jbeard@mikameyers.com

Respondent, Charter Township of Caledonia, by and through its attorneys, Mika Meyers 

PLC, answers Petitioner’s Entire Tribunal Property Tax Petition as follows: 

1.

Property Parcel No: 41-23-05-200-008.

ANSWER: 

Respondent admits that Property Parcel No. 41-23-05-200-008 is the 

subject of this tax appeal. 

2.

The property identified above is real.

ANSWER: 

The allegation contained in paragraph 2 of the Petition is 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.) 

N/A

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ANSWER: 

The allegations contained in paragraph 3 of the Petition appear to be 

inapplicable because only one parcel is under appeal. 

4. 

Are all of the parcels of personal property located on a parcel of real property under 

appeal? _Yes _No. (If no, separate Petitions are required for each parcel of personal property not 

located on a parcel of real property under appeal.) N/A 

ANSWER: 

The allegations contained in paragraph 4 of this Petition appear to be 

inapplicable because this appeal concerns a parcel of real, not personal, property and 

therefore no answer is required. 

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: 

The allegations contained in paragraph 5 of this Petition appear to be 

inapplicable because this appeal concerns a parcel of real, not personal, property and 

therefore no answer is required. 

6. 

The property identified above is classified as 201 Commercial- Improved. 

ANSWER: 

The allegations contained in paragraph 6 of this Petition are admitted 

because Property Parcel No. 41-23-05-200-008 is classified as 201 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. No protest to the Board of Review 

was required. 

ANSWER: 

Respondent admits that no protest to the Board of Review was 

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

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ANSWER: 

Respondent admits that no protest to the Board of Review was 

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: 

The allegations in paragraph 9 of this Petition do not appear to be 

applicable because Petitioner is not appealing the classification of the subject property and 

therefore no answer is required. 

10. 

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

address is: 5665 North Kraft Lake Dr. SE Caledonia, MI 49316. 

ANSWER: 

Respondent admits that the address of Property Parcel No. 41-23-05-

200-008 is 5665 North Kraft Lake Dr. SE Caledonia, MI 49316 and that the property is 

located in Kent County. 

11. 

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

governmental unit): Charter Township of Caledonia. 

ANSWER: 

The allegations contained in paragraph 11 of the Petition are admitted. 

12. 

Petitioner’s legal residence or principal office address is: 888 Seventh Ave, 4th 

Floor, New York, NY 10019. 

ANSWER: 

The allegations contained in paragraph 12 of the Petition are admitted 

upon information and belief. 

13. 

This appeal involves issues relating to the (check all that are applicable): 

X the property or properties’ true cash and taxable values;

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ANSWER: 

The allegations contained in paragraph 13 of the Petition are admitted 

upon information and belief. 

14. 

The tax year(s) at issue are: 2026. 

ANSWER: 

The allegations contained in paragraph 14 of the Petition are admitted 

upon information and belief. 

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): NA 

ANSWER: 

The allegations in paragraph 15 of the Petition appear to be 

inapplicable because it does not appear that Petitioner is attempting to appeal prior tax years 

and therefore no answer 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 

2026 

$44,431,200 

$22,215,600 

$19,148,995 

 

ANSWER: 

The allegations contained in paragraph 16 of this Petition are admitted 

as the true cash, assessed and taxable values on the tax roll. 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$30,000,000 

$15,000,000 

$15,000,000 

 

ANSWER: 

Respondent admits that the allegations contained in paragraph 17 

constitute Petitioner’s 2026 value contentions for the property. However, Respondent denies 

as untrue that Petitioner’s contentions accurately reflect the true cash, assessed, and taxable 

values for the property. 

18. 

The values in dispute for the property identified above are:

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Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$14,431,200 

$7,215,600 

$4,148,995 

 

ANSWER: 

Respondent admits that based upon Petitioner’s contentions of value, 

the allegations in paragraph 18 related to the true cash, assessed and taxable values appear 

to reflect the values in dispute. Further, Respondent denies as untrue that Petitioner’s value 

contentions accurately reflect the true cash, assessed, and taxable values for the property at 

issue. 

19. 

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

Petitioner respectfully requests the Michigan Tax Tribunal enter an order: (a) reducing the 2026 

True Cash Value, State Equalized Value, and Taxable Value of the subject property to the values 

set forth in paragraph 17 above; (b) directing Respondent to refund to Petitioner all taxes paid in 

excess of those properly owed, plus statutory interest; and (c) granting such other and further relief 

as is just and equitable. 

ANSWER: 

Respondent neither admits nor denies the allegations contained in 

paragraph 19 of this Petition because the allegations merely constitute Petitioner’s request 

for relief and no answer is required. To the extent that an answer is required, the allegations 

contained in paragraphs 17 and 19 of this Petition are denied as untrue, as Respondent 

believes that the values currently on the tax roll accurately reflect the true cash, state 

equalized, assessed and taxable values for the property at issue, such that no reduction in 

value and no refund are warranted. 

20. 

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

requested (attach additional page if necessary):

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A. The equalized assessment thus imposed on the subject property is more than 50% 

of its true cash value in violation of the applicable statutory and constitutional 

limitations. 

B. The assessment is based on improper or inaccurate valuation methodology, 

including but not limited to the use of non-representative data, failure to account 

for relevant property characteristics, and/or application of incorrect assumptions. 

As a result, the assessment is not uniform with comparable properties and results 

in an excessive and unlawful tax burden. 

ANSWER: 

Respondent denies as untrue the allegations contained in paragraph 20 

of this petition. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal affirm the 

true cash, assessed, state equalized and taxable value of the subject property as placed on the 2026 

and subsequent tax rolls by Respondent, dismiss the Petition, and grant Respondent its costs, 

attorney’s fees, and such other relief as the Tribunal deems appropriate. 

Respectfully submitted, 

 

MIKA MEYERS PLC 

Attorneys for Respondent 

 

 

Dated: August 3, 2026 

 

 

By: /s/ Joshua D. Beard 

 

 

 

 

Joshua D. Beard (P73388) 

 

900 Monroe Avenue, NW 

 

Grand Rapids, MI 49503 

 

(616) 632-8000 

 

tax.tribunal.efile@mikameyers.com

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AFFIRMATIVE DEFENSES 

Respondent, Charter Township of Caledonia, through its attorneys, Mika Meyers PLC, in 

defense of FIE Grand Rapids (MI) LLC’s Petition, asserts the following affirmative defenses: 

1. 

The Petition fails to state a claim upon which relief may be granted. 

2. 

Petitioner may not be a party in interest in this tax appeal and may lack standing to 

bring this appeal. 

3. 

Petitioner’s tax appeal may be time-barred if Petitioner failed to comply with MCL 

205.735a, or otherwise failed to timely file its tax appeal, or both. 

4. 

Respondent reserves the right to add to these defenses. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal affirm the 

true cash, assessed, state equalized and taxable value of the subject property as placed on the 2026 

and subsequent tax rolls by Respondent, dismiss the Petition, and grant Respondent its costs, 

attorney’s fees, and such other relief as the Tribunal deems appropriate. 

Respectfully submitted, 

 

MIKA MEYERS PLC 

Attorneys for Respondent 

 

 

Dated: August 3, 2026 

 

 

By: /s/ Joshua D. Beard 

 

 

 

 

Joshua D. Beard (P73388) 

 

900 Monroe Avenue, NW 

 

Grand Rapids, MI 49503 

 

(616) 632-8000 

 

tax.tribunal.efile@mikameyers.com

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