Kyron Homes - Answer to Petition.pdf
Kyron Homes LLC, Petitioner Vs. City Of Grand Rapids, Respondent · 25-002331-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL KYRON HOMES, LLC, Docket No. 25-002331 Petitioner, v. Parcel No. 41-13-36-306-002 CITY OF GRAND RAPIDS, Respondent. / Jon Aylsworth Property Tax Consultants Representative for Petitioner 861 Pinecrest Ave SE, Grand Rapids, MI 49506 (269) 366-0300 jack@skylinepropertytax.com Elizabeth J. Fossel (P41430) Kendall R. O’Connor (P84036) City of Grand Rapids Law Department Attorneys for Respondent 300 Monroe, NW, Suite 620 Grand Rapids, MI 49503 (616) 456-3802 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 enter their Appearance of Counsel on behalf of Respondent City of Grand Rapids, and answers Petitioner’s Petition as follows: 1. Petitioner is Kyron Homes LLC whose principal office or address is PO Box 453, Grandville, MI 49418. ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations, and leaves Petitioner to its proofs. 2. Respondent, City of Grand Rapids, levies and collects the property taxes on the subject property. ANSWER: Admitted.
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3. The property identification is # 41-13-36-306-002, and the subject property address is 1035 SW Godfrey Ave, Grand Rapids, MI 49503. The property is classified as commercial, real property. Petitioner’s Property is presently used for commercial. Petitioner believes that Petitioner’s Property was originally designed to be used for commercial. ANSWER: Respondent admits the stated parcel number and address, and that the Subject Property is classified as Commercial-Improved. Respondent neither admits nor denies the remaining allegations for the reason that Respondent lacks knowledge or sufficient information to form a belief as to the truth of the allegations regarding use and intended use of the property. 4. The subject property is located in Kent County and the school districts of Grand Rapids Public and the Kent Intermediate School District and Grand Rapids Community College. ANSWER: Respondent admits the Subject Property is located in Kent County and the Grand Rapids City School district. 5. This matter involves issues relating to the true cash and taxable values for the parcel referenced above for the 2025 tax year. ANSWER: Respondent neither admits nor denies the allegations in paragraph 5 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. 6. For tax year 2025, Respondent’s Board of Review determined an assessed value of $1,080,800, a state equalized value of $1,080,800 and a taxable value of $1,080,000. ANSWER: Admitted. 7. While a protest to the March Board of Review was not required by MCL 205.735a, petitioner timely protested to the March Board of Review but the requested relief was denied. ANSWER: Respondent admits Petitioner protested to the March Board of Review. Paragraph 7’s remaining allegations contain legal conclusions to which no response is required. 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. ANSWER: Paragraph 8 contains legal conclusions to which no response is required. To the extent a response is required, Respondent denies the allegations as untrue. 9. Petitioner contends the true cash value of the subject property is $1,200,000 which would yield a state equalized value of $600,000 and the taxable value is $600,000. The amount in
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contention is $480,800 for assessed value, state equalize and $480,800 for taxable value, and the amount in contention is $961,600 for the true cash value. ANSWER: Respondent denies as untrue the allegations and corresponding values as set forth in paragraph 9 of Petitioner’s Petition with respect to True Cash Value, State Equalized Value and Taxable Value. Respondent admits the allegations and corresponding values in contention as alleged in paragraph 9 of Petitioner’s Petition. 10. Petitioner requests that the Tribunal reduce the assessed value and the taxable value of the subject parcel from $1,080,800 and $1,080,800 respectively to $600,000 and order a refund with interest, as provided by the Tax Tribunal Act. ANSWER: Paragraph 10 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. 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 11, 2025 By: /s/ Kendall R. O’Connor Kendall R. O’Connor (P84036) Assistant City Attorney Attorney for Respondent
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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 11, 2025, she served true and complete copies of Respondent’s Appearance and Answer to Petition via email and first class mail, upon: Jon Aylsworth Property Tax Consultants Representative for Petitioner 861 Pinecrest Ave SE, Grand Rapids, MI 49506 jack@skylinepropertytax.com /s/ Alma Echeverria . Alma Echeverria