Cascade Office Park II LLC, Petitioner Vs. Township Of Cascade, Respondent
- Petitioner
- Cascade Office Park II LLC
- Respondent
- Township Of Cascade
Case overview
- Docket number
- 25-002353-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Kent
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 10 | Order of Dismissal | Not recorded | Not recorded | 09/05/2025 | Not recorded | Download |
| 9 | Motion to Withdraw Appeal was received. | PET | Not recorded | 09/05/2025 | $0.00 | Download |
| 8 | Prehearing General Call | Not recorded | Not recorded | 08/01/2025 | Not recorded | Download |
| 7 | Proof of Service of Misc Documents was received. | Not recorded | Not recorded | 07/11/2025 | Not recorded | Download |
| 6 | Answer was received | Not recorded | Not recorded | 07/11/2025 | Not recorded | Download |
| 5 | ET Case Info Sheet | Not recorded | Not recorded | 07/11/2025 | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 06/11/2025 | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 06/10/2025 | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 06/10/2025 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/27/2025 | $400.00 | 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 Cascade Office Park II LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002353 Township Of Cascade, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: September 5, 2025 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 Cascade Office Park II LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002353 Township Of Cascade, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: September 5, 2025 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 Cascade Office Park II LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 25-002353 Township Of Cascade, Respondent. ORDER GRANTING JOINT MOTION TO WITHDRAW ORDER OF DISMISSAL The Tribunal has reviewed the file in the above-captioned case and finds that the parties have filed a Joint Motion to Withdraw the appeal. Therefore, IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. IT IS FURTHER ORDERED that this case is DISMISSED. This order resolves all pending issues and closes the case. By:_____________________________________ Patricia L. Halm, Tribunal Chair Entered: September 5, 2025 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above to the parties or their attorneys or authorized representatives, if any, utilizing either the mailing or email addresses on file, as provided by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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61905709.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL CASCADE OFICE PARK II, LLC, Petitioner, v. CASCADE CHARTER TOWNSHIP, Respondent. MTT Docket No. 25-002353 ___________________________________________________________________________/ Michael B. Shapiro (P20282) Daniel L. Stanley (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com dstanley@honigman.com Laura J. Genovich (P72278) Thomas K. Dillon (P81136) FOSTER SWIFT COLLINS & SMITH, P.C. Attorneys for Respondent 1700 E. Beltline Avenue NE Suite 200 Grand Rapids, MI 49525 (616) 726-2258) lgenovich@fosterswift.com tdillon@fosterswift.com __________________________________________________________________________/ JOINT MOTION TO WITHDRAW APPEAL Petitioner desires to withdraw its Petition and files this Motion pursuant to Tax Tribunal Rule 237(4), R 792.10237(4). Respondent’s counsel has advised Petitioner’s representative that Respondent concurs in the Tribunal’s granting the relief requested herein. WHEREFORE, the parties request that the Tribunal enter an order allowing the Petition to be withdrawn, or dismissing this case, with each party bearing its own costs.
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2 61905709.1 HONIGMAN LLP FOSTER SWIFT COLLINS & SMITH, P.C. By: Michael B. Shapiro (P20282) Daniel L. Stanley (P57052) 39400 Woodward Avenue Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 mshapiro@honigman.com dstanley@honigman.com By: Laura J. Genovich (P72278) Thomas K. Dillon (P81136) 1700 E. Beltline Avenue NE Suite 200 Grand Rapids, MI 49525 (616) 726-2258) lgenovich@fosterswift.com tdillon@fosterswift.com Dated: __________________ Dated: ____________________ PROOF OF SERVICE Lisa Joseph hereby affirms that on _____________, 2025, she served a copy of the foregoing on Respondent’s counsel of record, via electronic mail. Dated: _______________, 2025 Lisa Joseph /s/ Daniel L. Stanley /s/ Thomas K. Dillon (w/permission) September 5, 2025 September 5, 2025 September 5 September 5 /s/ Lisa Joseph
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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 Cascade Office Park II LLC, Petitioner, v Township Of Cascade, Respondent. MTT Docket No. 25-002353 Please be advised that 25-002353 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.
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MTT Docket No. 25-002353 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 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: August 1, 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 provide by those parties, attorneys, or authorized representatives. By: Tribunal Clerk
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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 Cascade Office Park II LLC, Petitioner, v Township Of Cascade, Respondent. MTT Docket No. 25-002353 Please be advised that 25-002353 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
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M
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL CASCADE OFFICE PARK II, LLC, MTT Docket No. 25-002353 Petitioner, Parcel ID No. 41-19-07-376-034 v. CASCADE CHARTER TOWNSHIP, Respondent. Michael B. Shapiro (P20282) Laura J. Genovich (P72278) Daniel L. Stanley (P57052) Thomas K. Dillon (P81136) HONIGMAN LLP FOSTER SWIFT COLLINS & SMITH, P.C. Attorneys for Petitioner Attorneys for Respondent 660 Woodward Avenue 1700 East Beltline Avenue NE, Suite 200 2290 First National Bldg. Grand Rapids, MI 49525 Detroit, MI 48226-3506 (616) 726-2258 (313) 465-7622 Igenovich@fosterswift.com mshapiro@honigman.com tdillon@fosterswift.com dstanley@honigman.com PROOF OF SERVICE On July 11, 2025, I served a copy of Respondent Cascade Charter Township’s Answer and Affirmative Defenses to Entire Tribunal Property Tax Petition, along with a copy of this Proof of Service, upon the parties of record at their last known business address, by first class U.S. mail, postage prepaid. I declare that the statements above are true to the best of my information, knowledge, and belief. Date: July 11,2025 87192:00031:201736612-1
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN ADMINISTRATIVE HEARING SYSTEM
MICHIGAN TAX TRIBUNAL
______________________
CASCADE OFFICE PARK II, LLC,
Petitioner,
v.
CASCADE CHARTER TOWNSHIP,
Respondent.
MTT Docket No. 25-002353
Parcel ID No. 41-19-07-376-034
______________________________________________________________________________
Michael B. Shapiro (P20282)
Daniel L. Stanley (P57052)
HONIGMAN LLP
Attorneys for Petitioner
660 Woodward Avenue
2290 First National Bldg.
Detroit, MI 48226-3506
(313) 465-7622
mshapiro@honigman.com
dstanley@honigman.com
Laura J. Genovich (P72278)
Thomas K. Dillon (P81136)
FOSTER SWIFT COLLINS & SMITH, P.C.
Attorneys for Respondent
1700 East Beltline Avenue NE, Suite 200
Grand Rapids, MI 49525
(616) 726-2258
lgenovich@fosterswift.com
tdillon@fosterswift.com
______________________________________________________________________________
RESPONDENT CASCADE CHARTER TOWNSHIP’S ANSWERS & AFFIRMATIVE
DEFENSES TO ENTIRE TRIBUNAL PROPERTY TAX PETITION
Respondent, Cascade Charter Township, by and through its attorneys, Foster, Swift,
Collins & Smith, P.C., states as follows for its Answers to Petitioner’s Entire Tribunal Property
Tax Petition:
1.
Petitioner's principal office address is 750 Trade Center Way, Suite 1000,
Portage, MI 48002. Petitioner is a party in interest with respect to property taxes on tax parcel
no(s). 41-19-07-376-034 ("Petitioner's Property"), also known as Horizon Office Park at 2660
Horizon Drive SE located in Kent County, Michigan.Page 2
ANSWER: Respondent neither admits nor denies the allegations regarding Petitioner’s principal office address and whether Petitioner is a “party in interest” as Respondent is without sufficient knowledge or information to form a belief as to the allegations. Respondent leaves Petitioner to its proofs. 2. Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's Property. ANSWER: Respondent admits the allegation contained in paragraph 2 of the Petition. 3. In 2025, Respondent determined the taxable value of Petitioner's Property to be $531,908 and assessed Petitioner's Property at $875,000, which will result in a state equalized value in the same amount based upon the tentative equalization factor. ANSWER: Respondent admits the allegation contained in paragraph 3 of the Petition. 4. Petitioner's Property is classified as Commercial Real. Petitioner's Property is presently used or available for use for Office purposes. Petitioner believes that Petitioner's Property was originally designed to be used for Office purposes. ANSWER: Respondent admits that the property is classified as Commercial Real. Respondent neither admits nor denies the remaining allegations in paragraph 4 as Respondent is without sufficient knowledge or information to form a belief as to the remaining allegations in paragraph 4. Respondent leaves Petitioner to its proofs. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) uniformity. ANSWER: Respondent neither admits nor denies the allegations in paragraph 5 of the Petition and leaves Petitioner to its proofs. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. ANSWER: As Paragraph 6 pleads no facts, this Paragraph is insufficient to raise an issue for appeal (TTR 227(1)) and fails to state a claim on which relief can be granted (MCR 2.116 (C) (8)). The allegations are denied. 7. If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property,
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a board of review protest was filed in March, 2025. ANSWER: Paragraph 7 of the Petition does not contain a factual allegation requiring a response but is a hypothetical. To the extent that paragraph 7 contains a factual allegation, Respondent denies the allegation and leaves Petitioner to its proofs as to whether the Tribunal has jurisdiction. Respondent reserves its right to object to jurisdiction if Petitioner failed to comply to the requirements of MCL 205.735a. 8. The 2025 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; (c) The assessment, including taxable value and/or state equalized value, are based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and are based upon the application of wrong principles; and, (d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. ANSWER: Respondent denies the allegations contained in paragraph 8 of the Petition, including all allegations made in subparagraphs a. through d., and leaves Petitioner to its proofs as the assessed, state equalized and taxable values do not exceed permitted amounts, do not exceed the percentage for true cash value permitted by law, were correctly determined and are based upon the correct application of proper principals, and do not discriminate against Petitioner.
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AFFIRMATIVE DEFENSES Respondent, Cascade Charter Township, by and through its attorneys, Foster, Swift, Collins & Smith, P.C., and states that it may rely on one or all of the following Affirmative
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8.
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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. 25-002353 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Township Of Cascade (KENT) Local Unit of Government/First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State Michigan ZIP Code Telephone Number Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) Section 2: Attorney/Authorized Representative’s Contact Information First Name Tom M.I. Last Name Dillon Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 1700 E Beltline NE, Ste 200 City or Town Grand Rapids State Michigan ZIP Code 49525 Telephone Number 616-726-2258 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) tdillon@fosterswift.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Thomas K. Dillon /s/
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< RECEIVED On. © JUN 11205 MICHIGAN TAX TRIBUNAL STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Cascade Office Park II, LLC, Petitioner, v. MTT Docket No. 25-002353 [Parcel No(s). 41-19-07-376-034] Cascade Twp., Respondent. / PROOF OF SERVICE Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and that on June 11, 2025, she did serve a copy of Petitioner's Petition, with docket number, upon the /s/ fon Crap Lisd J oseph parties named on the attached list.
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BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK CASCADE TWP. 2865 THORNHILLS DRIVE SE GRAND RAPIDS, MI 49546-7192 ASSESSOR CASCADE TWP. 2865 THORNHILLS DRIVE SE GRAND RAPIDS, MI 49546-7192 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK KENT COUNTY 300 MONROE AVENUE, NW GRAND RAPIDS, MI 49503-2288 DIRECTOR OF EQUALIZATION KENT COUNTY 300 MONROE AVENUE, NW GRAND RAPIDS, MI 49503-2288 SECRETARY OF SCHOOL BOARD FOREST HILLS PUBLIC SCHOOLS 6590 CASCADE ROAD SE GRAND RAPIDS, MI 49546-6497 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 25-0100
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Page 1
D
aeCEVN®
RECEIVED
5
9, 10
JNO
MAY
29 2025
JRUNA
ia
TTR
CG
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
Cascade Office Park II, LLC,
Petitioner,
\2
MTT Docket No.
[Parcel No(s). 41-19-07-376-034]
Cascade Twp.,
Tranlnfo:d606 6O1983-1
05/30/25
Respamdent.
Chick:
40619
mt: $400.00
10:
HONTGHAN LLP
PETITION
Cascade Office Park IT, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says:
1.
Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage,
MI 48002.
Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 41-
19-07-376-034 ("Petitioner's Property"), also known as Horizon Office Park at 2660 Horizon Drive
SE located in Kent County, Michigan.
If this petition includes more than one (1) real property tax
parcel, the tax parcels are contiguous.
2.
Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's
Property.
3.
In 2025, Respondent determined the taxable value of Petitioner's Property to be
$531,908 and assessed Petitioner's Property at $875,000, which will result in a state equalized
value in the same amount based upon the tentative equalization factor.Page 2
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; ®) 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; (©) 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
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WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 taxable value of Petitioner's Property from $531,908 to $365,000, and reducing the 2025 assessed and state equalized value of Petitioner's Property from $875,000 to $3,365,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: /s/ Michael B. Shapiro Michael B. Shapiro (P20282) Daniel L. Stanley (P57052 39400 Woodward Avenue Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 Dated: May 29, 2025 mshapiro@honigman.com dstanley@honigman.com
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Honigman LLP COSTS ADVANCED ACCOUNT Invoice Date Invoice Number Invoice Narrative Payment Amount 5/29/25 040619 278318/547672/DLS #EEGA00,00% Filing Fee for Petition — Cascade Office Park 15106939.1
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Envelc Recycle
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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 Cascade Office Park II LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002353 Township Of Cascade, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this Notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this Notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this Notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the Notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: __Tribunal Clerk________ Entered: June 10, 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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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 Cascade Office Park II LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002353 Township Of Cascade, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this Notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this Notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this Notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the Notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority over the petition or that the petition complies with statutory requirements or the Tribunal’s rules. By: __Tribunal Clerk________ Entered: June 10, 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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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 Cascade Office Park II LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002353 Township Of Cascade, Respondent. NOTICE OF DOCKET NUMBER TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted docket number has been assigned to that petition. This docket number shall be noted on the petition and the petition shall be served within 45 days of the issuance of this Notice, as required by TTR 227 and MCL 205.735a, even if the petition was served when filed. A proof of service shall also be filed with the Tribunal within 45 days of the issuance of this Notice evidencing the service of the petition. If you submitted a proof of service with the petition, you must still serve the petition and file a second proof of service including the docket number, pursuant to this Notice. Failure to serve the petition and file a proof of service within 45 days of the issuance of the Notice may result in the dismissal of this case. Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 days after the date of service of the petition with noted docket number.” Failure to do so will result in Respondent being placed in default. The docket number also needs to be noted on all other documents submitted in this case. Further, the assignment of the docket number does not mean that the Tribunal has authority
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D
aeCEVN®
RECEIVED
5
9, 10
JNO
MAY
29 2025
JRUNA
ia
TTR
CG
MICHIGAN TAX TRIBUNAL
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
Cascade Office Park II, LLC,
Petitioner,
\2
MTT Docket No.
[Parcel No(s). 41-19-07-376-034]
Cascade Twp.,
Tranlnfo:d606 6O1983-1
05/30/25
Respamdent.
Chick:
40619
mt: $400.00
10:
HONTGHAN LLP
PETITION
Cascade Office Park IT, LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says:
1.
Petitioner's principal office address is 750 Trade Center Way, Suite 1000, Portage,
MI 48002.
Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 41-
19-07-376-034 ("Petitioner's Property"), also known as Horizon Office Park at 2660 Horizon Drive
SE located in Kent County, Michigan.
If this petition includes more than one (1) real property tax
parcel, the tax parcels are contiguous.
2.
Respondent, Cascade Twp., assesses and collects property taxes on Petitioner's
Property.
3.
In 2025, Respondent determined the taxable value of Petitioner's Property to be
$531,908 and assessed Petitioner's Property at $875,000, which will result in a state equalized
value in the same amount based upon the tentative equalization factor.Page 2
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; ®) 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; (©) 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
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WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 taxable value of Petitioner's Property from $531,908 to $365,000, and reducing the 2025 assessed and state equalized value of Petitioner's Property from $875,000 to $3,365,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: /s/ Michael B. Shapiro Michael B. Shapiro (P20282) Daniel L. Stanley (P57052 39400 Woodward Avenue Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7622 Dated: May 29, 2025 mshapiro@honigman.com dstanley@honigman.com
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Honigman LLP COSTS ADVANCED ACCOUNT Invoice Date Invoice Number Invoice Narrative Payment Amount 5/29/25 040619 278318/547672/DLS #EEGA00,00% Filing Fee for Petition — Cascade Office Park 15106939.1
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Envelc Recycle
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