500 Trade Centre Way LLC Petitioner Vs. City Of Portage 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

NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

500 Trade Centre Way LLC,

Petitioner,

v

 

 

City Of Portage,

Respondent.

 MTT Docket No. 26-002648

Please be advised that 26-002648 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covered by the order will not be published.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. 26-002648

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. 26-002648

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

Page 5

MTT Docket

Page 6

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

500 Trade Center Way, LLC. 

 

 

 

Petitioner, 

 

v 

 

City of Portage, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-002648 

 

Parcel No. 39-10-01900-150-G 

 

_____________________________________________________________________________/ 

 

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

Page 6

6

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Page 1

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. 26-002648

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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

500 Trade Centre Way LLC, 

Petitioner, 

v 

MTT Docket No. Ab 00244 o) 

[Parcel No(s). 39-10-01900-150-G] 

Portage, 

Respondent. 

PROOF OF SERVICE 

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

that on 

3/ 4 [ot 

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

the parties named on the attached list. 

/5/ Es Jeph 

Lisa Joseph 

26-0018 

75543089.1

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 

26-0018 

75543089.1

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-002648

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: 500 Trade Centre POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

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

500 Trade Centre Way LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-002648

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

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

500 Trade Centre Way LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-002648

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

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Page 1

500 Trade Centre Way LLC, 

Petitioner, 

Portage, 

Respondent. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

[Parcel No(s). 39-10-01900-150-G] 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorney for Petitioner 

222 N. Washington Square 

Suite 400 

Lansing, MI 48933 

(517) 377-0714 

dstanley@honigman.com 

PETITION 

RECEIVED 

MAY 15 2026 W\~ 

MICHIGAN Tax TRIBUNAL 

Traninfo:d606 

261224761 

05/18/26 

Cis 

040710 

Ant: $600.00 

HONTGHAN LLP 

500 Trade Centre Way LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

I. 

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-G ("Petitioner's Property"), at 500 Trade Centre Way located in Kalamazoo County, 

Michigan. 

If this petition includes more than one (1) real property tax parcel, the tax parcels are 

contiguous.

Page 2

2. 

Respondent, Portage, assesses and collects property taxes on Petitioner's Property. 

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$4,957,200 and assessed Petitioner's Property at $4,957,200, 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 Portage 

Hilton Homewood Suites. 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. 

Ts 

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 for cost purposes when Petitioner’s 

property is Class D. 

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

Page 3

properties in Michigan, 114% higher than a brand new nearby similar property in Kalamazoo, and 

141% higher than a similar newly-renovated Radisson hotel in Kalamazoo. 

11. 

Respondent’s assessment 

is 

a clear statistical 

outlier. Petitioner’s property 

is 

assessed at approximately $55,080 per room, 125% higher than the average of other comparable 

Hilton Homewood Suites across Michigan, 114% higher than a brand-new Hilton property on I- 

94, and 141% higher than a newly renovated Radisson hotel in Kalamazoo. These figures far 

exceed all local and statewide limited-service hotel benchmarks. 

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

Page 4

(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. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 

taxable value of Petitioner's Property from $4,957,200 to $3,880,000, and reducing the 2026 

assessed and state equalized value of Petitioner's Property from $4,957,200 to $3,880,000, 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

Page 5

Docusign Envelope ID: 6E84223C-3000-8F17-81FD-CB78816A7TATA 

PORTAGE 

A 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. 

500 Trade Centre Way LLC (Roger Hinman & Joe Gesmundo) , 

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 

2026 

valuation for, 

for property 

| (we) own addressed as: 

Year 

500 Trade Centre Way 

Portage 

Mi 

49002 

Address 

3G ~ [OD ~ 

City

Page 6

Michiga

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

500 Trade Centre Way LLC, 

Petitioner, 

Portage, 

Respondent. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

[Parcel No(s). 39-10-01900-150-G] 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorney for Petitioner 

222 N. Washington Square 

Suite 400 

Lansing, MI 48933 

(517) 377-0714 

dstanley@honigman.com 

PETITION 

RECEIVED 

MAY 15 2026 W\~ 

MICHIGAN Tax TRIBUNAL 

Traninfo:d606 

261224761 

05/18/26 

Cis 

040710 

Ant: $600.00 

HONTGHAN LLP 

500 Trade Centre Way LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

I. 

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-G ("Petitioner's Property"), at 500 Trade Centre Way located in Kalamazoo County, 

Michigan. 

If this petition includes more than one (1) real property tax parcel, the tax parcels are 

contiguous.

Page 2

2. 

Respondent, Portage, assesses and collects property taxes on Petitioner's Property. 

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$4,957,200 and assessed Petitioner's Property at $4,957,200, 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 Portage 

Hilton Homewood Suites. 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. 

Ts 

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 for cost purposes when Petitioner’s 

property is Class D. 

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

Page 3

properties in Michigan, 114% higher than a brand new nearby similar property in Kalamazoo, and 

141% higher than a similar newly-renovated Radisson hotel in Kalamazoo. 

11. 

Respondent’s assessment 

is 

a clear statistical 

outlier. Petitioner’s property 

is 

assessed at approximately $55,080 per room, 125% higher than the average of other comparable 

Hilton Homewood Suites across Michigan, 114% higher than a brand-new Hilton property on I- 

94, and 141% higher than a newly renovated Radisson hotel in Kalamazoo. These figures far 

exceed all local and statewide limited-service hotel benchmarks. 

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

Page 4

(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. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2026 

taxable value of Petitioner's Property from $4,957,200 to $3,880,000, and reducing the 2026 

assessed and state equalized value of Petitioner's Property from $4,957,200 to $3,880,000, 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

Page 5

Docusign Envelope ID: 6E84223C-3000-8F17-81FD-CB78816A7TATA 

PORTAGE 

A 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. 

500 Trade Centre Way LLC (Roger Hinman & Joe Gesmundo) , 

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 

2026 

valuation for, 

for property 

| (we) own addressed as: 

Year 

500 Trade Centre Way 

Portage 

Mi 

49002 

Address 

3G ~ [OD ~ 

City

Page 6

Michiga

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