400 Trade Centre LLC Petitioner Vs. City Of Portage Respondent
- Petitioner
- 400 Trade Centre LLC
- Respondent
- City Of Portage
Case overview
- Docket number
- 26-002649-TT
- Status
- Ready Sched Prehearing Date Certain
- CaseType
- ET Property
- Division
- ET
- County
- Kalamazoo
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 6 | Prehearing General Call | Not recorded | Not recorded | 09/01/2026 | Not recorded | Download |
| 5 | Answer was received | RESP | Not recorded | 08/06/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 08/04/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 07/13/2026 | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 07/13/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/15/2026 | $600.00 | Download |
Documents
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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 NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE 400 Trade Centre LLC, Petitioner, v City Of Portage, Respondent. MTT Docket No. 26-002649 Please be advised that 26-002649 has been placed on a two-week Prehearing General Call commencing August 02, 2027. Unless ordered otherwise, parties will be notified at least 28 days before they are scheduled to appear. Scheduling will not necessarily occur in the order in which the cases are listed below. Parties are required to submit a valuation disclosure or written notification that no valuation disclosure is required by the dates indicated herein. A “valuation disclosure” is defined as documentary or other tangible evidence in a property tax proceeding that a party relies upon in support of the party’s contention as to the true cash value of the subject property or any portion thereof and contains the party’s value conclusion and data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241. Users who file documents with the Tribunal are advised that filed documents are public records and will appear for public viewing on the Tribunal’s Tax Docket Lookup. If a user wishes to file a document for consideration by the Tribunal and prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents covered by the order will not be published. Documents filed prior to the issuance of a Protective Order will be published. In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or redacting personal identifying information (PII) from all documents filed with or offered to the Tribunal rests solely with the parties and their attorneys. The Tribunal is not responsible for or required to review, redact, or screen documents at the time of filing for PII whether filed electronically or on paper. A party, representative, or interested person (i.e. third party not part of an appeal) may request that the Tribunal redact PII contained in a previously filed document by submitting a Request for Redactions. The Request for Redactions form is available on the Entire Tribunal and Small Claims pages of the Tribunal’s website. Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s website for more information.
Page 2
MTT Docket No. 26-002649 Page 2 of 3 IT IS ORDERED that the parties shall: a. If no valuation disclosure is required, notify the Tribunal and the opposing parties in writing within 21 days of entry of this order that no valuation disclosure is being filed. The notice shall indicate the reason or reasons why no valuation disclosure is required (i.e., exemption claim, etc.). b. If a valuation disclosure is required, file and exchange their valuation disclosures by April 5, 2027. Valuation disclosures will not be admitted into evidence unless disclosed and furnished in accordance with this order (even though admissible) except upon a finding of good cause by the Tribunal. IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing Statements by April 5, 2027. Witnesses, with the exception of rebuttal witnesses, will not be allowed to testify unless disclosed in the Prehearing Statement and the Prehearing Statement is furnished in accordance with this order except upon a finding of good cause by the Tribunal. Failure to file the Prehearing Statement may result in holding a party or parties in default. See TTR 237. IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on April 5, 2027, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. Discovery relative to the valuation disclosure prepared for purposes of litigating this case or the valuation expert that prepared that valuation disclosure is not permitted during “Pre-Valuation Disclosure” discovery. IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on August 2, 2027, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation disclosure, the opposing party’s valuation expert, and the witnesses identified on the opposing party’s Prehearing Statement. IT IS FURTHER ORDERED that if this case is not scheduled for a date certain prehearing conference during the time frame indicated it may be scheduled for a date certain prehearing conference at any time subsequent to the completion date for this Prehearing General Call. Parties will, however, be notified in writing approximately one week before they are scheduled to appear. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: September 1, 2026
Page 3
MTT Docket No. 26-002649 Page 3 of 3 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
Page 4
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 NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE 400
Page 5
MT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 400 Trade Center, LLC, Petitioner, v City of Portage, Respondent. MTT Docket No. 26-002649 Parcel No. 39-10-01900-150-E _____________________________________________________________________________/ DANIEL L STANLEY (P57052) HONIGMAN LLP Attorney for Petitioner 222 N. Washington Square Lansing, MI 48933 (517) 377-0714 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ ANSWER TO PETITION AND AFFIRMATIVE DEFENSES ANSWER Respondent City of Portage, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent admits the allegations in Paragraph 1 as to the parcel number and address of property, but lacks the information to respond to the remaining allegations in Paragraph 1 and leaves Petitioner to its proofs. There is only 1 parcel at issue in this case. 2. Respondent admits the allegations in Paragraph 2. 3. Respondent admits the allegations in Paragraph 3.
Page 2
2 4. Respondent admits that subject property is classified as commercial real. With respect to the remaining allegations in Paragraph 4, Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained therein and leaves Petitioner to its proofs. 5. Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies that Petitioner’s claims have merit or that Petitioner is entitled to any relief as to those issues. 6. Respondent denies the allegations in Paragraph 6. 7. Respondent admits the allegations in Paragraph 7. 8. Respondent denies the allegations in Paragraph 8 for the reason that the assessment is neither excessive nor erroneous and the property was correctly valued when the assessment was determined. 9. Respondent denies that the assessment is not uniform, and denies that comparing the subject to other properties, without identifying those properties, in the City of Portage is relevant and denies that the comparison to the undefined greater Kalamazoo area or Michigan is relevant, correct, or appropriate. 10. Respondent lacks the information necessary to respond to the allegations in Paragraph 10 for the reason that the properties are not identified with sufficient detail to respond, and also denies that comparing the subject’s assessment to those properties is relevant or appropriate. 11. Respondent denies that the subject’s assessment is incorrect or not-uniform. Respondent lacks the information necessary to respond to the remainder of the allegations in
Page 3
3 Paragraph 11 for the reason that the properties are not identified and denies that said comparisons are relevant or appropriate. 12. Respondent denies the allegations in Paragraph 12 for the reason that the same are 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 non-discriminatory and constitutional. 13. Respondent denies the allegations in Paragraph 13, including subparagraphs, for the reason that the same are 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 non-discriminatory and constitutional. 14. Respondent acknowledges the relief requested by Petitioner in the final paragraph of the Petition, but denies that Petitioner is entitled to the requested relief due to the statements in the above Paragraphs. WHEREFORE, Respondent City of Portage requests the Tribunal dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees.
Page 4
4 HALLAHAN & ASSOCIATES, P.C. /s/ Seth A. O’Loughlin______________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 Dated: August 6, 2026 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent City of Portage asserts the following affirmative defenses: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. 2. The Tribunal is charged with finding a property’s true cash value to determine the property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 3. 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). 4. Petitioner has failed to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles, or illegality on the part of Respondent or its agents. 5. Petitioner has failed to allege that the mode and method of assessing the subject property fails to conform to the mode and method applied in the case of all other properties in Respondent’s taxing unit for the year in question. 6. Petitioner has failed to show that any factor other than fifty percent (50%) was applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the
Page 5
5 respective assessments appearing on the roll, and also fails to allege specific and sufficient
Page 6
6
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Respondent MTT DOCKET NO. 26-002649 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Portage (KALAMAZOO) First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone 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 Laura M.I. Last Name Hallahan Firm Name (if any) Hallahan & Associates PC Address (No., Street, P.O. Box or Rural Route) 1750 S. Telegraph Road, Suite 202 City or Town Bloomfield Hills State Michigan ZIP Code 48302 Telephone Number 248-731-3089 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) mtt@hallahanlaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Seth A. O'Loughlin /s/
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 400 Trade Centre LLC, Petitioner, v. MTT Docket No. 2 -pOA 49 [Parcel No(s). 39-10-01900-150-E] Portage, Respondent. PROOF OF SERVICE Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and that on )) / Y /2 pe , she did serve a copy of Petitioner's Petition, with docket number, upon the parties named on the attached list. /5 pan Lisa J oseph 26-0017 75542408.1
Page 2
BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK PORTAGE 7900 S. WESTNEDGE AVENUE PORTAGE, MI 49002 ASSESSOR PORTAGE 7900 S. WESTNEDGE AVENUE PORTAGE, MI 49002 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK KALAMAZOO COUNTY 201 W. KALAMAZOO AVENUE KALAMAZOO, MI 49007-3726 DIRECTOR OF EQUALIZATION KALAMAZOO COUNTY 201 W. KALAMAZOO AVENUE KALAMAZOO, MI 49007-3726 SECRETARY OF SCHOOL BOARD PORTAGE PUBLIC SCHOOLS 8111 S. WESTNEDGE AVENUE PORTAGE, MI 49002-5433 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 26-0017 75542408.1
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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 MICHIGAN TAX TRIBUNAL Docket Number: 26-002649 Is this case currently pending in the Small Claims Division? No Party Filing Document Petitioner Files Document Type: Proof of Service: Petition Attachment File Name: 400 Trade Centre POS Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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RECEIVED
\ a
MAY 152026 \O
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
400 Trade Centre LLC,
Petitioner,
\2
MTT Docket No.
[Parcel No(s). 39-10-01900-150-E]
Portage,
Respondent.
Daniel L. Stanley (P57052)
franInfo: 606 26120476-1 5i/tey6
Honigman LLP
pu: 040711
Ant: $600.00
Attorney for Petitioner
HOHIGHAN LLP
222 N. Washington Square
Suite 400
Lansing, MI 48933
(517) 377-0714
dstanley@honigman.com
PETITION
400 Trade Centre LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says:
Ls
Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage,
MI 49002.
Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 39-
10-01900-150-E ("Petitioner's Property"), at 400 Trade Centre W. located in Kalamazoo County,
Michigan.
If this petition includes more than one (1) real property tax parcel, the tax parcels are
contiguous.Page 2
3. In 2026, Respondent determined the taxable value of Petitioner's Property to be $3,941,979 and assessed Petitioner's Property at $4,819,000, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 4. Petitioner's Property is classified as Commercial Real. Petitioner's Property is presently used or available for use for hotel purposes and is commonly referred to as the Marriott Courtyard Portage. Petitioner believes that Petitioner's Property was originally designed to be used for hotel purposes. 5. 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. Petitioner filed a board of review protest in March, 2026. A copy of Petitioner’s Board of Review protest is attached hereto as Exhibit A. 8 Respondent’s assessment of Petitioner’s property is excessive and erroneous because, among other reasons, the values in Respondent’s assessment are based upon a cost approach assuming that Petitioner’s property is a Class C Full Service Hotel for cost purposes when Petitioner’s property is a Class D Limited Service Hotel. 9. Respondent’s assessment of Petitioner’s property is much higher than comparable hotel properties in the City of Portage, the greater Kalamazoo area in which Petitioner’s hotel property competes, and the State of Michigan.
Page 3
Li, Respondent’s assessment is a clear statistical outlier. Petitioner’s property is assessed at approximately $53,544 per room, more than double the median assessed value of the 20 other comparable Marriott Courtyard hotels across Michigan ($25,895 per room). It also materially exceeds the assessed values of all other limited-service hotels in the City of Portage and the greater Kalamazoo market. 12. The 2026 assessment, including state equalized value and taxable value, imposed on Petitioner's Property are erroneous and excessive. 13. The 2026 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
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WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable value of Petitioner's Property from $3,941,979 to $2,700,000, and reducing the 2026 assessed and state equalized value of Petitioner's Property from $4,819,000 to $2,700,000, 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/ Daniel L. Stanley Daniel L. Stanley (P57052) 222 North Washington Square Suite 400 Lansing, MI 48933-1800 (517) 377-0714 dstanley@honigman.com Dated: May 15,2026
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Docusign Envelope ID; 6E84223C-3000-8F17-81FD-CB78816A7TATA BPORTAGE 818%) 4 Natural Place to Move Agent Authorization A completed Agent Authorization form or a letter of authorization must accompany all letters of appeal to the City of Portage Board of Review for which the property owner authorizes a third party to act as an agent on behalf of the property owner. Any communications will continue to be sent to the address of the property owner, not the Authorized Agent. 400 Trade Centre LLC (Roger Hinman & Joe Gesmundo) rs Printed Name(s) of Property Owner(s) of Record Rich MacDonald 750 Trade Centre Way, Suite 100, Portage MI 49002, 269-488-3651 Printed Name, Address and Telephone Number of Authorized Agent I (we). to act on my (our) behalf in the matter of protesting my (our) real and personal property assessed valuation for. 2026 for property | (we) own addressed as: Year 400 Trade Centre Way Portage MI 49002 Address 3Cp ~ fp City State Zip Code 01900-150-E 750 Trade Centre Way, Suite 100 Tax Parcel No. Property Owner Mailing Address 269-342-8600 Portage Mi 49002 Property Owner Telephone Number City State Zip Code 3/9/2026 Signatur BFPIEPEAy Owner Date pa : 3/9/2026 €. timan, Ra Date Letters of Appeal to the Board of Review and Agent Authorizations must be received in
Page 6
Mi
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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 400 Trade Centre LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002649 City Of Portage, 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: July 13, 2026 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
City Of Portage
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 400 Trade Centre LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002649 City Of Portage, 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: July 13, 2026 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 4
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 400 Trade Centre LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002649 City Of Portage, 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
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Page 1
RECEIVED
\ a
MAY 152026 \O
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
400 Trade Centre LLC,
Petitioner,
\2
MTT Docket No.
[Parcel No(s). 39-10-01900-150-E]
Portage,
Respondent.
Daniel L. Stanley (P57052)
franInfo: 606 26120476-1 5i/tey6
Honigman LLP
pu: 040711
Ant: $600.00
Attorney for Petitioner
HOHIGHAN LLP
222 N. Washington Square
Suite 400
Lansing, MI 48933
(517) 377-0714
dstanley@honigman.com
PETITION
400 Trade Centre LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says:
Ls
Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage,
MI 49002.
Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 39-
10-01900-150-E ("Petitioner's Property"), at 400 Trade Centre W. located in Kalamazoo County,
Michigan.
If this petition includes more than one (1) real property tax parcel, the tax parcels are
contiguous.Page 2
3. In 2026, Respondent determined the taxable value of Petitioner's Property to be $3,941,979 and assessed Petitioner's Property at $4,819,000, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 4. Petitioner's Property is classified as Commercial Real. Petitioner's Property is presently used or available for use for hotel purposes and is commonly referred to as the Marriott Courtyard Portage. Petitioner believes that Petitioner's Property was originally designed to be used for hotel purposes. 5. 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. Petitioner filed a board of review protest in March, 2026. A copy of Petitioner’s Board of Review protest is attached hereto as Exhibit A. 8 Respondent’s assessment of Petitioner’s property is excessive and erroneous because, among other reasons, the values in Respondent’s assessment are based upon a cost approach assuming that Petitioner’s property is a Class C Full Service Hotel for cost purposes when Petitioner’s property is a Class D Limited Service Hotel. 9. Respondent’s assessment of Petitioner’s property is much higher than comparable hotel properties in the City of Portage, the greater Kalamazoo area in which Petitioner’s hotel property competes, and the State of Michigan.
Page 3
Li, Respondent’s assessment is a clear statistical outlier. Petitioner’s property is assessed at approximately $53,544 per room, more than double the median assessed value of the 20 other comparable Marriott Courtyard hotels across Michigan ($25,895 per room). It also materially exceeds the assessed values of all other limited-service hotels in the City of Portage and the greater Kalamazoo market. 12. The 2026 assessment, including state equalized value and taxable value, imposed on Petitioner's Property are erroneous and excessive. 13. The 2026 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
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WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 taxable value of Petitioner's Property from $3,941,979 to $2,700,000, and reducing the 2026 assessed and state equalized value of Petitioner's Property from $4,819,000 to $2,700,000, 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/ Daniel L. Stanley Daniel L. Stanley (P57052) 222 North Washington Square Suite 400 Lansing, MI 48933-1800 (517) 377-0714 dstanley@honigman.com Dated: May 15,2026
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Docusign Envelope ID; 6E84223C-3000-8F17-81FD-CB78816A7TATA BPORTAGE 818%) 4 Natural Place to Move Agent Authorization A completed Agent Authorization form or a letter of authorization must accompany all letters of appeal to the City of Portage Board of Review for which the property owner authorizes a third party to act as an agent on behalf of the property owner. Any communications will continue to be sent to the address of the property owner, not the Authorized Agent. 400 Trade Centre LLC (Roger Hinman & Joe Gesmundo) rs Printed Name(s) of Property Owner(s) of Record Rich MacDonald 750 Trade Centre Way, Suite 100, Portage MI 49002, 269-488-3651 Printed Name, Address and Telephone Number of Authorized Agent I (we). to act on my (our) behalf in the matter of protesting my (our) real and personal property assessed valuation for. 2026 for property | (we) own addressed as: Year 400 Trade Centre Way Portage MI 49002 Address 3Cp ~ fp City State Zip Code 01900-150-E 750 Trade Centre Way, Suite 100 Tax Parcel No. Property Owner Mailing Address 269-342-8600 Portage Mi 49002 Property Owner Telephone Number City State Zip Code 3/9/2026 Signatur BFPIEPEAy Owner Date pa : 3/9/2026 €. timan, Ra Date Letters of Appeal to the Board of Review and Agent Authorizations must be received in
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