Bc Equities LP, Petitioner Vs. City Of Battle Creek, Respondent

Page 1

RECEIVED 

MAY 27 2095 De 

STATE OF MICHIGAN 

MICHIGAN TAX TRigy, 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

wr 

MICHIGAN TAX TRIBUNAL 

BC Equities LP, 

Petitioner, 

\2 

MTT Docket No. 25-001696 

Battle Creek, 

TranInfosqé06 26125061-1 

05/26/26 

Chkil: 

040746 

Antz $300.00 

Respondent. 

ID: 

HONIGHAN LLP 

/ 

Daniel L. Stanley (P57052) 

C. Marcel Stoetzel, III (P61912) 

Honigman LLP 

City Attorney’s Office 

Attorneys for Petitioner 

Attorney for Respondent 

222 North Washington Square 

10 North Division Street 

Suite 400 

Suite 216 

Lansing, MI 48933-1800 

Battle Creek, M1 49014 

(517) 377-0714 

(269) 966-3385 

dstanley@honigman.com 

cmstoetzal@battlecreekmi.gov 

/ 

Motion to Amend Petition to Contest 

2026 Assessed and Taxable Values 

Petitioner, BC Equities LP, through its attorneys, Honigman LLP, moves to amend the 

Petition in this matter to include the following: 

I. 

In 2026, Respondent determined the taxable value of Petitioner’s Property 

to be $2,539,200 and Respondent assessed Petitioner’s Property at $2,539,200 

, which will result 

in a state equalized value of the same amount, based upon the tentative equalization factor. 

2 

The 2026 assessment, including state equalized value and taxable value,

Page 2

(b) 

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

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

applicable statutes; 

(c) 

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

is 

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

Property that is taxable under Michigan law and is 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. 

WHEREFORE, Petitioner moves that this Motion be granted, and Petitioner requests that 

the Tribunal enter an Order: 

(i) reducing the 2026 assessed and state equalized value from 

$2,539,200 

to $1,500,000 

; (ii) reducing the 2026 taxable value from $2,539,200 

to $1,500,000 ; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

/s/ Daniel L. Stanley 

Daniel L. Stanley (P57052) 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517)377-0714 

By:

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BC EQUITIES LP, 

Petitioner, 

\2 

MTT Docket No. 25-001696 

BATTLE CREEK, 

Respondent. 

/ 

Proof of Service 

Lisa Joseph affirms that on May 27, 2026 she served a copy of Petitioner's Motion to 

Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service 

in 

connection with the above-entitled cause upon the following: 

C. Marcel Stoetzel, IIT 

Cmstoetzel@battlecreekmi.gov 

via electronic mail. 

Dated: May 27, 2026 

/s/ Lisa Joseph 

Lisa Joseph

Page 4

Hownigman LLP 

COSTS ADVANCED AGCOUNT 

040744 

Invoice Date 

Invoice Number 

Invoice Narrative 

5/27/26 

24559387.1 

040744 

DLS/230134/511265 

Motion to Amend 

Filing fee # 25-001696 

BC Equities-Battle Creek 

Payment Amount 

300.00 

RECEIVED 

MAY 27 2026 

MICHIGAN TAX TRIBUNAL

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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 

BC Equities LP, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001696 

 

City of Battle Creek, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

ORDER REMOVING CASE FROM JULY 1-15, 2026 PREHEARING GENERAL CALL 

 

On October 6, 2025, the parties filed a joint motion requesting that the Tribunal hold this 

case in abeyance pending resolution of Docket No. 24-001329, which is currently 

pending before the Tribunal. In the motion, the parties state that, “[w]ith the exception 

of the tax year at issue, the parties, property, and issues raised in the above captioned 

appeal are, based on the pleadings, in essence identical to those at issue in MTT 

Docket No. 24-001329 . . . .” The motion further stated that “[t]he above captioned 2025 

appeal has been placed on a two-week Prehearing General Call commencing July 1, 

2026, with valuation disclosures due March 4, 2026.” 

 

The Tribunal has considered the motion and the case file and finds that placing this 

case in abeyance pending resolution of Docket No. 24-001329 will facilitate the efficient 

administration of justice, as that resolution may have a direct bearing on the outcome of 

the instant appeal. Therefore, 

 

IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that this case is REMOVED from the July 1-15, 2026 

Prehearing General Call. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of the resolution of Docket No. 24-001329 as to the need for further proceedings in 

this matter. 

 

 

Entered: October 20, 2025 

 

 

By _____________________________ 

kac/jcr

Page 2

MTT Docket No. 25-001696 

Page 2 of 2 

 

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

62356418.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

BC EQUITIES LP, 

 

 

 

Petitioner, 

 

v 

 

CITY OF BATTLE CREEK, 

 

Respondent.

 

 

 

MTT Docket No. 25-001696 

 

 

 

_____________________________________________________________________________/ 

 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

222 N. Washington Square, Suite 400 

Lansing, MI 48933 

(517) 377-0714 

DStanley@honigman.com

C. MARCEL STOETZEL, III (P61912) 

CITY ATTORNEY’S OFFICE 

Attorneys for Respondent 

10 North Division Street, Suite 207 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-001329 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of an office property – 

Parcel No. 0253-00-037-1- located in the City of Kalamazoo. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-001329 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal has been placed on a two-week Prehearing 

General Call commencing July 01, 2026, with valuation disclosures due March 4, 2026.

Page 2

62356418.1 

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-001329) has not yet been resolved. A Prehearing Conference is scheduled for 

December 1-15, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

001329 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

001329 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

001329. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-001329.

Page 3

62356418.1 

3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ DANIEL L. STANLEY _ 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

222 N. Washington Square, Suite 400 

Lansing, MI 48933 

(517) 377-0714 

DStanley@honigman.com 

 

 

Dated: October 6, 2025

CITY ATTORNEY’S OFFICE 

 

/s/ C. MARCEL STOETZEL, III __ 

C. MARCEL STOETZEL, III (P61912) 

Attorneys for Respondent 

10 North Division Street, Suite 207 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov 

 

Dated: October 6, 2025

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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 

BC Equities LP, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001696 

 

City of Battle Creek, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

ORDER REMOVING CASE FROM JULY 1-15, 2026 PREHEARING GENERAL CALL 

 

On October 6, 2025, the parties filed a joint motion requesting that the Tribunal hold this 

case in abeyance pending resolution of Docket No. 24-001329, which is currently 

pending before the Tribunal. In the motion, the parties state that, “[w]ith the exception 

of the tax year at issue, the parties, property, and issues raised in the above captioned 

appeal are, based on the pleadings, in essence identical to those at issue in MTT 

Docket No. 24-001329 . . . .” The motion further stated that “[t]he above captioned 2025 

appeal has been placed on a two-week Prehearing General Call commencing July 1, 

2026, with valuation disclosures due March 4, 2026.” 

 

The Tribunal has considered the motion and the case file and finds that placing this 

case in abeyance pending resolution of Docket No. 24-001329 will facilitate the efficient 

administration of justice, as that resolution may have a direct bearing on the outcome of 

the instant appeal. Therefore, 

 

IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that this case is REMOVED from the July 1-15, 2026 

Prehearing General Call. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of the resolution of Docket No. 24-001329 as to the need for further proceedings in 

this matter. 

 

 

Entered: October 20, 2025 

 

 

By _____________________________ 

kac/jcr

Page 2

MTT Docket No. 25-001696 

Page 2 of 2 

 

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

62356418.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

BC EQUITIES LP, 

 

 

 

Petitioner, 

 

v 

 

CITY OF BATTLE CREEK, 

 

Respondent.

 

 

 

MTT Docket No. 25-001696 

 

 

 

_____________________________________________________________________________/ 

 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

222 N. Washington Square, Suite 400 

Lansing, MI 48933 

(517) 377-0714 

DStanley@honigman.com

C. MARCEL STOETZEL, III (P61912) 

CITY ATTORNEY’S OFFICE 

Attorneys for Respondent 

10 North Division Street, Suite 207 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-001329 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of an office property – 

Parcel No. 0253-00-037-1- located in the City of Kalamazoo. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-001329 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal has been placed on a two-week Prehearing 

General Call commencing July 01, 2026, with valuation disclosures due March 4, 2026.

Page 2

62356418.1 

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-001329) has not yet been resolved. A Prehearing Conference is scheduled for 

December 1-15, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

001329 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

001329 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

001329. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-001329.

Page 3

62356418.1 

3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ DANIEL L. STANLEY _ 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

222 N. Washington Square, Suite 400 

Lansing, MI 48933 

(517) 377-0714 

DStanley@honigman.com 

 

 

Dated: October 6, 2025

CITY ATTORNEY’S OFFICE 

 

/s/ C. MARCEL STOETZEL, III __ 

C. MARCEL STOETZEL, III (P61912) 

Attorneys for Respondent 

10 North Division Street, Suite 207 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov 

 

Dated: October 6, 2025

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

ACTING 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 JULY 1 - 15, 2026 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

BC Equities LP,

Petitioner,

v

 

 

City Of Battle Creek,

Respondent.

 MTT Docket No. 25-001696

Please be advised that 25-001696 has been placed on a two-week Prehearing General 

Call commencing July 01, 2026. Parties will be notified at least one week before they 

are scheduled to appear.

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, as provided by TTR 237.

In accordance with MCR 1.109(D)(9), as of January 1, 2021, 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. Please refer to the 

Tribunal’s FAQs and Glossary of Terms pages on our website for more information.

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 March 4, 2026. 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.

Page 2

MTT Docket No. 25-001696

Page 2 of 2

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by March 4, 2026. 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, as provided by 

TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 4, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, 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 

July 1, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, 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

Page 3

ST

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Page 1

RECEIVED Ne 5 

wo 

JUN 06 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BC Equities LP, 

Petitioner, 

| \o AZ 

v. 

MTT Docket No. 

2 5 OC 

[Parcel No(s). 0253-00-037-1] 

Battle Creek, 

Respondent. 

PROOF OF SERVICE 

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

that on 

5 / 30] 2S 

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

the parties named on the attached list. 

/ s/ FT ~~ 

paca 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

BATTLE CREEK 

10 N. DIVISION 

BATTLE CREEK, MI 49037 

ASSESSOR 

BATTLE CREEK 

10 N. DIVISION 

BATTLE CREEK, MI 49037 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

CALHOUN COUNTY 

315 W. GREEN STREET 

MARSHALL, MI 49068-1518 

DIRECTOR OF EQUALIZATION 

CALHOUN COUNTY 

315 W. GREEN STREET 

MARSHALL, MI 49068-1518 

SECRETARY OF SCHOOL BOARD 

BATTLE CREEK SCHOOL DISTRICT 

VAN BUREN STREET W. 

BATTLE CREEK, MI 49017-3079 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0092

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Page 1

25-0092 

60686512.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BC Equities LP, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 0253-00-037-1] 

Battle Creek, 

Respondent. 

_________________________/ 

PETITION 

BC Equities LP (“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). 0253-

00-037-1 ("Petitioner's Property"), at 67 W. Michigan Avenue located in Calhoun County, 

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

contiguous. 

2. 

Respondent, Battle Creek, assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$2,523,376 and assessed Petitioner's Property at $3,205,900, 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 Office purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for Office purposes.

Page 2

2 

60686512.1 

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. 

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 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.

Page 3

3 

60686512.1 

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

taxable value of Petitioner's Property from $2,523,376 to $1,500,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $3,205,900 to $1,500,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

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 

 

 

May 29, 2025

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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

BC Equities LP, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001696

City Of Battle Creek, 

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 22, 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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BC Equities LP, 

 

 

Petitioner, 

 

 

 

 

 

 

 

MTT Docket No. 25-001696 

 

v. 

 

 

 

 

 

 

Parcel No. 0253-00-037-1 

 

 

 

 

 

 

 

 

City of Battle Creek, 

 

 

Respondent. 

 

 

HONIGMAN LLP 

Daniel L. Stanley 

Attorney for Petitioner 

222 North Washington Square, Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

 

 

CITY ATTORNEY’S OFFICE 

C. Marcel Stoetzel, III (P61912) 

Attorney for Respondent 

10 North Division Street, Suite 216 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov 

 

 

PROOF OF SERVICE 

 

 

Jenna Bagent deposes and says that on the 2nd day of July 2025, she served a copy of an 

Appearance, Respondent’s Answer and Affirmative Defenses, and a Proof of Service in the 

above-captioned matter on behalf of Respondent City by email, pursuant to MCR 2.107(G) as 

amended by Administrative Order 2020-08 effective July 26, 2021, upon Petitioner’s agent. 

 

 

Daniel L. Stanley at email: dstanley@honigman.com 

 

I declare that the above information is true to the best of my information, knowledge and belief. 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: July 02, 20205 

 

 

/s/ Jenna Bagent 

 

Jenna Bagent 

Legal Assistant

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BC Equities LP, 

 

 

Petitioner, 

 

 

 

 

 

 

 

MTT Docket No. 25-001696 

 

v. 

 

 

 

 

 

 

Parcel No. 0253-00-037-1 

 

 

 

 

 

 

 

 

City of Battle Creek, 

 

 

Respondent. 

 

 

HONIGMAN LLP 

Daniel L. Stanley 

Attorney for Petitioner 

222 North Washington Square, Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

 

 

CITY ATTORNEY’S OFFICE 

C. Marcel Stoetzel, III (P61912) 

Attorney for Respondent 

10 North Division Street, Suite 216 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov 

 

 

APPEARANCE 

 

 

 

Pursuant to MCR 7.204(G), C. Marcel Stoetzel, III, hereby enters his Appearance as 

counsel of record on behalf of Respondent City of Battle Creek in the above-captioned civil 

litigation. 

 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

 

Dated: July 02, 20205 

 

 

/s/ C. Marcel Stoetzel, III 

C. Marcel Stoetzel, III 

Deputy City Attorney 

City of Battle Creek 

10 North Division Street, Suite 216 

Battle Creek, MI 49014

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BC Equities LP, 

 

 

Petitioner, 

 

 

 

 

 

 

 

MTT Docket No. 25-001696 

 

v. 

 

 

 

 

 

 

Parcel No. 0253-00-037-1 

 

 

 

 

 

 

 

 

City of Battle Creek, 

 

 

Respondent. 

 

 

HONIGMAN LLP 

Daniel L. Stanley 

Attorney for Petitioner 

222 North Washington Square, Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

 

 

 

CITY ATTORNEY’S OFFICE 

C. Marcel Stoetzel, III (P61912) 

Attorney for Respondent 

10 North Division Street, Suite 216 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov 

 

 

 

ANSWER TO PETITION and AFFIRMATIVE DEFENSES 

 

ANSWER 

 

 

NOW COMES RESPONDENT, City of Battle Creek, by and through its attorneys, and in 

answer to Petitioners’ Petition responds as follows: 

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). 

0253-00-037-1 (“Petitioner’s Property”), at 67 W. Michigan Avenue located in Calhoun 

County, Michigan. If this petition includes more than one (1) real property tax parcel, the 

tax parcels are contiguous. 

 

ANSWER: Respondent admits the parcel number is correct. Respondent neither 

admits nor denies Petitioner’s remaining allegations in Paragraph 1 and leaves 

Petitioner to its proofs. 

 

2. Respondent, Battle Creek, assesses and collects property taxes on Petitioner’s Property. 

 

ANSWER: Respondent admits Petitioner’s allegation in Paragraph 2 of its Petition.

Page 2

2 

 

3. In 2025, Respondent determined the taxable value of Petitioner’s Property to be $2,523,376 

and assessed Petitioner’s Property at $3,205,900, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

 

ANSWER: Respondent admits Petitioner’s allegation in Paragraph 3 of its 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 Petitioner’s allegation in Paragraph 4 of its Petition. 

 

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

(d) uniformity. 

 

ANSWER: Respondent neither admits nor denies what Petitioner alleges in 

Paragraph 5 of its 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: Respondent neither admits nor denies what Petitioner alleges in 

Paragraph 6 of its Petition. Respondent states further that no loss has been reported 

to the Assessor’s office. 

 

 

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: Respondent admits Petitioner’s allegation in Paragraph 7 of its Petition. 

 

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; 

 

ANSWER: Respondent denies as untrue Petitioner’s allegations in Paragraph 

8(a) of its Petition. 

 

(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; 

 

ANSWER: Respondent denies as untrue Petitioner’s allegations in Paragraph 

8(b) of its Petition.

Page 3

3 

 

(c) The assessment, including taxable value and/or state equalized value, are based upon 

an erroneous

Page 4

4

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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. 25-001696

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Battle Creek (CALHOUN)

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

C.

M.I.

Marcel

Last Name

Stoetzel

Firm Name (if any)

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

10 N. Division St

Suite 207

City or Town

Battle Creek

State

Michigan

ZIP Code

49014

Telephone Number

269-966-3385

Fax Number

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

cmstoetzel@battlecreekmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

C. Marcel Stoetzel, III

/s/

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Page 1

25-0092 

60686512.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BC Equities LP, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 0253-00-037-1] 

Battle Creek, 

Respondent. 

_________________________/ 

PETITION 

BC Equities LP (“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). 0253-

00-037-1 ("Petitioner's Property"), at 67 W. Michigan Avenue located in Calhoun County, 

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

contiguous. 

2. 

Respondent, Battle Creek, assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$2,523,376 and assessed Petitioner's Property at $3,205,900, 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 Office purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for Office purposes.

Page 2

2 

60686512.1 

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. 

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 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.

Page 3

3 

60686512.1 

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

taxable value of Petitioner's Property from $2,523,376 to $1,500,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $3,205,900 to $1,500,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

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 

 

 

May 29, 2025

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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 - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

BC Equities LP

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

750 Trade Center Way

City or Town

Portage

State

Michigan

ZIP Code

48002

Telephone Number

2485668300

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Daniel

M.I.

Last Name

Stanley

Firm Name (if any)

Honigman LLP

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

222 N. Washington Sq

Suite 400

City or Town

Lansing

State

Michigan

ZIP Code

48933

Telephone Number

517-377-0714

Fax Number

517-364-9514

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

DStanley@Honigman.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

Michigan

Taxing Authority (City or Township)

City Of Battle Creek (CALHOUN)

County

Calhoun

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

0253-00-037-1

Classification of Property: Real 

Commercial

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

3205900

Current Taxable Value as established by the Board of Review:

2523376

What do you believe is the fair market value (also known as True Cash Value)?

3000000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

1500000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest 

State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special

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