2600 Horizon LLC, Petitioner Vs. Township Of Cascade, Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

2600 Horizon LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002407

Township Of Cascade,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: September 5, 2025

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

2600 Horizon LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002407

Township Of Cascade,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: September 5, 2025

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

2600 Horizon LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002407

Township Of Cascade,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: September 5, 2025

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

61905560.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

2600 HORIZON, LLC, 

 

 

 

 

Petitioner, 

 

 

v. 

 

CASCADE CHARTER TOWNSHIP, 

 

Respondent.

 

 

 

MTT Docket No. 25-002407 

 

 

___________________________________________________________________________/ 

 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

Laura J. Genovich (P72278) 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, P.C. 

Attorneys for Respondent 

1700 E. Beltline Avenue NE 

Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258) 

lgenovich@fosterswift.com 

tdillon@fosterswift.com 

__________________________________________________________________________/ 

 

 

JOINT MOTION TO WITHDRAW APPEAL 

 

Petitioner desires to withdraw its Petition and files this Motion pursuant to Tax Tribunal 

Rule 237(4), R 792.10237(4). Respondent’s counsel has advised Petitioner’s representative that 

Respondent concurs in the Tribunal’s granting the relief requested herein. 

 

WHEREFORE, the parties request that the Tribunal enter an order allowing the Petition 

to be withdrawn, or dismissing this case, with each party bearing its own costs.

Page 2

2 

61905560.1 

HONIGMAN LLP 

 

 

 

 FOSTER SWIFT COLLINS & SMITH, P.C. 

 

By: 

 

 

 

 

 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

By: 

 

 

 

 

 

Laura J. Genovich (P72278) 

Thomas K. Dillon (P81136) 

1700 E. Beltline Avenue NE 

Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258) 

lgenovich@fosterswift.com 

tdillon@fosterswift.com 

 

Dated: _______________ 

 

 

 Dated: ____________________ 

 

 

PROOF OF SERVICE 

 

 

Lisa Joseph hereby affirms that on ____________, 2025, she served a copy of the 

foregoing on Respondent’s counsel of record, via electronic mail. 

 

 

Dated: ___________, 2025 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Lisa Joseph 

 

/s/ Daniel L. Stanley 

 

 

 /s/ Thomas K. Dillon (w/permission)

September 5, 2025 

 

 

 

 September 5, 2025

September 5

September 5

/s/ Lisa Joseph

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

2600 HORIZON, LLC, 

MTT Docket No. 25-002407 

Petitioner, 

Parcel ID Nos. 41-19-07-376-031 & 

41-19-07-376-037 

Vv. 

CASCADE CHARTER TOWNSHIP, 

Respondent. 

Michael B. Shapiro (P20282) 

Laura J. Genovich (P72278) 

Daniel L. Stanley (P57052) 

Thomas K. Dillon (P81136) 

HONIGMAN LLP 

FOSTER SWIFT COLLINS & SMITH, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

660 Woodward Avenue 

1700 East Beltline Avenue NE, Suite 200 

2290 First National Bldg. 

Grand Rapids, MI 49525 

Detroit, MI 48226-3506 

(616) 726-2258 

(313) 465-7622 

Igenovich@fosterswift.com 

mshapiro@honigman.com 

tdillon@fosterswift.com 

dstanley@honigman.com 

PROOF 

OF SERVICE 

On July 11, 2025, I served a copy of Respondent Cascade Charter Township’s Answer 

and Affirmative Defenses to Entire Tribunal Property Tax Petition, along with a copy of this 

Proof of Service, upon the parties of record at their last known business address, by first class U.S. 

mail, postage prepaid. 

I declare that the statements above are true to the best of my information, knowledge, and 

belief. 

Date: 

July 11,2025 

87192:00032:201736581-1

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

______________________ 

 

2600 HORIZON, LLC, 

 

 

Petitioner, 

 

v. 

 

CASCADE CHARTER TOWNSHIP, 

 

 

Respondent. 

MTT Docket No. 25-002407 

 

Parcel ID Nos. 41-19-07-376-031 & 

 41-19-07-376-037 

______________________________________________________________________________ 

 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

660 Woodward Avenue 

2290 First National Bldg. 

Detroit, MI 48226-3506 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

Laura J. Genovich (P72278) 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, P.C. 

Attorneys for Respondent 

1700 East Beltline Avenue NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

lgenovich@fosterswift.com 

tdillon@fosterswift.com 

______________________________________________________________________________ 

 

RESPONDENT CASCADE CHARTER TOWNSHIP’S ANSWERS & AFFIRMATIVE 

DEFENSES TO ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

Respondent, Cascade Charter Township, by and through its attorneys, Foster, Swift, 

Collins & Smith, P.C., states as follows for its Answers to Petitioner’s Entire Tribunal Property 

Tax Petition: 

1. 

Petitioner's principal office address is 750 Trade Center Way, Suite 1000, 

Portage, MI 48002. Petitioner is a party in interest with respect to property taxes on tax parcel 

no(s). 41-19-07-376-031, 41-19-07-376-037 ("Petitioner's Property"), also known as Horizon 

Office Park at 2600-2610 Horizon Drive SE located in Kent County, Michigan. If this petition 

includes more than one (1) real property tax parcel, the tax parcels are contiguous.

Page 2

ANSWER: 

Respondent neither admits nor denies the allegations regarding Petitioner’s 

principal office address and whether Petitioner is a “party in interest” as Respondent is 

without sufficient knowledge or information to form a belief as to the allegations. 

Respondent leaves Petitioner to its proofs. 

2. 

Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's 

Property. 

ANSWER: 

Respondent admits the allegation contained in paragraph 2 of the Petition. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$1,063,816 ($531,908, $531,908) and assessed Petitioner's Property at $1,751,600 ($875,800, 

$875,800), which will result in a state equalized value in the same amount based upon the 

tentative equalization factor. 

ANSWER: Respondent admits the allegation contained in paragraph 3 of the Petition. 

4. 

Petitioner's Property is classified as Commercial Real. Petitioner's Property is 

presently used or available for use for Office purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for Office purposes. 

ANSWER: 

Respondent admits that the property is classified as Commercial Real. 

Respondent neither admits nor denies the remaining allegations in paragraph 4 as 

Respondent is without sufficient knowledge or information to form a belief as to the 

remaining allegations in paragraph 4. Respondent leaves Petitioner to its proofs. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value and (d) uniformity. 

ANSWER: 

Respondent neither admits nor denies the allegations in paragraph 5 of the 

Petition and leaves Petitioner to its proofs. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a 

dispute relative to the value of a loss. 

ANSWER: 

As Paragraph 6 pleads no facts, this Paragraph is insufficient to raise an 

issue for appeal (TTR 227(1)) and fails to state a claim on which relief can be granted 

(MCR 2.116 (C) (8)). The allegations are denied.

Page 3

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, 

a board of review protest was filed in March, 2025. 

ANSWER: 

Paragraph 7 of the Petition does not contain a factual allegation requiring 

a response but is a hypothetical. To the extent that paragraph 7 contains a factual 

allegation, Respondent denies the allegation and leaves Petitioner to its proofs as to 

whether the Tribunal has jurisdiction. Respondent reserves its right to object to 

jurisdiction if Petitioner failed to comply to the requirements of MCL 205.735a. 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and 

unlawful and operate as a fraud upon the taxpayer for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, are 

at higher percentages of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, are 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and are based upon the application of wrong 

principles; and, 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection and due process of law. 

ANSWER: 

Respondent denies the allegations contained in paragraph 8 of the Petition, 

including all allegations made in subparagraphs a. through d., and leaves Petitioner to its 

proofs as the assessed, state equalized and taxable values do not exceed permitted amounts, 

do not exceed the percentage for true cash value permitted by law, were correctly determined 

and are based upon the correct application of proper principals, and do not discriminate 

against Petitioner.

Page 4

AFFIRMATIVE DEFENSES

Page 5

8.

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002407

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Cascade (KENT)

Local Unit of Government/First Name

M.I.

Last Name

Home Address (No., Street, P.O. Box or Rural Route)

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Tom

M.I.

Last Name

Dillon

Firm Name (if any)

Address (No., Street, P.O. Box or Rural Route)

1700 E Beltline NE, Ste 200

City or Town

Grand Rapids

State

Michigan

ZIP Code

49525

Telephone Number

616-726-2258

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

tdillon@fosterswift.com

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

Thomas K. Dillon

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

2600 Horizon, LLC, 

Petitioner, 

a 

MTT Docket No. 

ho) = —O¢ P) ALO 

[Parcel No(s). 41-19-07-376-031, 41-19-07-376- 

037] 

Cascade Twp., 

Respondent. 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

that on 

b 

[ 

{ 3 

/ 257, she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

/s/ Fon 

Qraspl 

Lisa Joseph 

~

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

CASCADE TWP. 

2865 THORNHILLS DRIVE SE 

GRAND RAPIDS, MI 49546-7192 

ASSESSOR 

CASCADE TWP. 

2865 THORNHILLS DRIVE SE 

GRAND RAPIDS, MI 49546-7192 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

KENT COUNTY 

300 MONROE AVENUE, NW 

GRAND RAPIDS, MI 49503-2288 

DIRECTOR OF EQUALIZATION 

KENT COUNTY 

300 MONROE AVENUE, NW 

GRAND RAPIDS, MI 49503-2288 

SECRETARY OF SCHOOL BOARD 

FOREST HILLS PUBLIC SCHOOLS 

6590 CASCADE ROAD SE 

GRAND RAPIDS, MI 49546-6497 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0101

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Page 1

D 

RECENEY 

 pEcEIVED 

JON 02 2009 

\ 

MAY 29 2025 

U7 

UNA 

a 

ANTAX The 

MICHIG 

CHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

2600 Horizon, LLC, 

Petitioner, 

v. 

MTT Docket No. 

[Parcel No(s). 41-19-07-376-031, 41-19-07-376- 

037] 

TranInfo:qb0f 

 26019836-1 

05/30/25 

Cascade Twp., 

Chit: 

40620 

Amt: $625.00 

ID: 

HONIGHAN LLP 

Respondent. 

PETITION 

2600 Horizon, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage, 

MI 48002. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 41- 

19-07-376-031, 41-19-07-376-037 ("Petitioner's Property"), also known as Horizon Office Park at 

2600 -2610 Horizon Drive SE located in Kent County, Michigan. 

If this petition includes more 

than one (1) real property tax parcel, the tax parcels are contiguous. 

2; 

Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's 

Property. 

3 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$1,063,816 ($531,908, $531,908) and assessed Petitioner's Property at $1,751,600 ($875,800,

Page 2

4. 

Petitioner's Property is classified as Commercial Real. 

Petitioner's Property 

is 

presently used or available for use for Office purposes. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for Office purposes. 

S. 

This matter involves issues relating to: 

(a) valuation, (b) assessment, (c) taxable 

value and (d) uniformity. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner's Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

and operate as a fraud upon the taxpayer for the reasons that: 

(a) 

The assessment, including 

state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, are 

based upon an etroneous determination of the true cash value of that portion of Petitioner's 

Property that 

is taxable under Michigan law, and are based upon the application of wrong

Page 3

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode 

of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner ifs constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value 

of Petitioner's Property from $1,063,816 ($531,908, $531,908) 

to $730,000 

($365,000, $365,000), and reducing the 2025 assessed and state equalized value of Petitioner's 

Property from $1,751,600 ($875,800, $875,800) to $730,000 ($365,000, $365,000), and requiring 

Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:/s/ Michael B. Shapiro 

Michael B. Shapiro (P20282) 

Daniel L Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

Dated: May 29, 2025 

mshapiro@henigman.com 

dstanley@honigman.com

Page 4

rlonigman LLF 

COSTS ADVANCED ACCOUNT 

ne 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

5/29/25 

[| 

278319/547674/DLS 

*EX$625.00%** 

Filing Fee for Petition — 2600 Horizon 

LLC 

15106939.1

Page 5

> 

Envelc 

Recycle

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

2600 Horizon LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002407

Township Of Cascade, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this Notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this Notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this Notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the Notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: June 13, 2025

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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Page 1

D 

RECENEY 

 pEcEIVED 

JON 02 2009 

\ 

MAY 29 2025 

U7 

UNA 

a 

ANTAX The 

MICHIG 

CHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

2600 Horizon, LLC, 

Petitioner, 

v. 

MTT Docket No. 

[Parcel No(s). 41-19-07-376-031, 41-19-07-376- 

037] 

TranInfo:qb0f 

 26019836-1 

05/30/25 

Cascade Twp., 

Chit: 

40620 

Amt: $625.00 

ID: 

HONIGHAN LLP 

Respondent. 

PETITION 

2600 Horizon, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage, 

MI 48002. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 41- 

19-07-376-031, 41-19-07-376-037 ("Petitioner's Property"), also known as Horizon Office Park at 

2600 -2610 Horizon Drive SE located in Kent County, Michigan. 

If this petition includes more 

than one (1) real property tax parcel, the tax parcels are contiguous. 

2; 

Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's 

Property. 

3 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$1,063,816 ($531,908, $531,908) and assessed Petitioner's Property at $1,751,600 ($875,800,

Page 2

4. 

Petitioner's Property is classified as Commercial Real. 

Petitioner's Property 

is 

presently used or available for use for Office purposes. 

Petitioner believes that Petitioner's 

Property was originally designed to be used for Office purposes. 

S. 

This matter involves issues relating to: 

(a) valuation, (b) assessment, (c) taxable 

value and (d) uniformity. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner's Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

and operate as a fraud upon the taxpayer for the reasons that: 

(a) 

The assessment, including 

state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, are 

based upon an etroneous determination of the true cash value of that portion of Petitioner's 

Property that 

is taxable under Michigan law, and are based upon the application of wrong

Page 3

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode 

of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner ifs constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value 

of Petitioner's Property from $1,063,816 ($531,908, $531,908) 

to $730,000 

($365,000, $365,000), and reducing the 2025 assessed and state equalized value of Petitioner's 

Property from $1,751,600 ($875,800, $875,800) to $730,000 ($365,000, $365,000), and requiring 

Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:/s/ Michael B. Shapiro 

Michael B. Shapiro (P20282) 

Daniel L Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

Dated: May 29, 2025 

mshapiro@henigman.com 

dstanley@honigman.com

Page 4

rlonigman LLF 

COSTS ADVANCED ACCOUNT 

ne 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

5/29/25 

[| 

278319/547674/DLS 

*EX$625.00%** 

Filing Fee for Petition — 2600 Horizon 

LLC 

15106939.1

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> 

Envelc 

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