Coughlin Partners LLC, Petitioner Vs. City Of Lansing, Respondent
- Petitioner
- Coughlin Partners LLC
- Respondent
- City Of Lansing
Case overview
- Docket number
- 25-001746-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Ingham
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 13 | Consent Judgment | Not recorded | 7 | 11/10/2025 | Not recorded | Download |
| 12 | Granted | PET | 7 | 11/10/2025 | Not recorded | Download |
| 11 | Order Updating Docket | Not recorded | Not recorded | 11/10/2025 | Not recorded | Download |
| 10 | Granted | PET | 6 | 11/10/2025 | Not recorded | Download |
| 9 | Order granting Motion. | Not recorded | 6 | 11/10/2025 | Not recorded | Download |
| 8 | Answer was received | RESP | Not recorded | 09/25/2025 | Not recorded | Download |
| 7 | A Stipulation has been received. | PET | Not recorded | 11/05/2025 | $50.00 | Download |
| 6 | Motion to Amend was received. | PET | Not recorded | 11/05/2025 | $50.00 | Download |
| 5 | Proof of service of petition was received. | PET | Not recorded | 08/27/2025 | Not recorded | Download |
| 4 | Petition has been verified | PET | 2 | 07/23/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 07/23/2025 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 05/29/2025 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 05/29/2025 | $475.00 | 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 Coughlin Partners LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001746 City of Lansing, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING PETITIONER’S MOTION TO AMEND ORDER CORRECTING DOCKET ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT On November 5, 2025, Petitioner filed a Motion to Amend. In the motion, Petitioner states that the petition filed on May 29, 2025, correctly identified the subject property as consisting of four parcels of property and correctly listed the parcel numbers. However, after the petition was filed, Respondent combined the four parcels of property and assigned Parcel No. 33-01-01-17-226-292 to this new parcel. Given this, the docket needs to be corrected to reflect the new parcel number. In its answer, filed September 25, 2025, Respondent acknowledges that the parcels have been combined and that Respondent assigned Parcel No. 33-01-01-17-226-292 to the combined parcel. Therefore, the Tribunal finds that good cause exists to grant Petitioner’s motion and to update the subject property’s parcel number. The Tribunal has reviewed the Stipulation and finds that it comports with the mandates of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. IT IS FURTHER ORDERED that the docket shall be updated to reflect the change in the subject property’s parcel number, as indicated herein. IT IS FURTHER ORDERED that the Joint Stipulation for Entry of Consent Judgment including all attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise indicated. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax years at issue shall correct or cause the assessment rolls to be 1 See MCL 211.27a.
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MTT Docket No. 25-001746 Page 2 of 2 corrected to reflect the property’s true cash and taxable values as provided in this Consent Judgment within 20 days of the entry of the Consent Judgment.2 IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund as required by the Consent Judgment within 28 days of the entry of the Consent Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a proportionate share of any property tax administration fees paid and of penalty and interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless otherwise indicated, bear interest from the date of payment to the date of judgment and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, and (viii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%. This Consent Judgment resolves all pending claims in this matter and closes this case. See docket look up for a copy of stipulation and for any possible refund paragraph. By _____________________________ Entered: November 10, 2025 sb 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
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1 4903-4007-2823.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, Petitioner, MTT Docket No 25-001746-TT v CITY OF LANSING, Respondent. _____________________________________________/ STIPULATION FOR ENTRY OF CONSENT JUDGMENT 1. The case is pending in the X Entire Tribunal OR __ Small Claims Division. 2. Property Parcel No: 33-01-01-17-226-292 3. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-01-17-226- 292 $1,099,400 $549,700 $549,700 4. The values for the property identified above as stipulated by the parties for settlement purposes are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-01-17-226- 292 $550,000 $275,000 $275,000 5. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years: 6. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc.:
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2 4903-4007-2823.1 IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable jointly to Petitioner named herein and its counsel, Foley & Lardner LLP, and sent in care of such counsel. Calculations of the refund amount shall also be sent to Petitioner’s counsel at the same address. IT IS FURTHER ORDERED AND ADJUDGED that all interest due hereunder is waived if, and only if, all refunds otherwise due are made within 120 days of the date of entry of the Consent Judgment. FOLEY & LARDNER LLP CITY OF LANSING ASSESSING DEPT. Attorneys for Petitioner Representative for Respondent By: /s/ Jason Conti By: /s/ Jennifer Czeiszperger Jason Conti (P55617) Jennifer Czeiszperger 500 Woodward Avenue, Suite 2700 124 W. Michigan Avenue, 3rd Floor Detroit, Michigan 48226 Lansing, Michigan 48933 (313) 234-7177 (517) 483-7624 Dated: November 5, 2025
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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 Coughlin Partners LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001746 City of Lansing, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING PETITIONER’S MOTION TO AMEND ORDER CORRECTING DOCKET ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT On November 5, 2025, Petitioner filed a Motion to Amend. In the motion, Petitioner states that the petition filed on May 29, 2025, correctly identified the subject property as consisting of four parcels of property and correctly listed the parcel numbers. However, after the petition was filed, Respondent combined the four parcels of property and assigned Parcel No. 33-01-01-17-226-292 to this new parcel. Given this, the docket needs to be corrected to reflect the new parcel number. In its answer, filed September 25, 2025, Respondent acknowledges that the parcels have been combined and that Respondent assigned Parcel No. 33-01-01-17-226-292 to the combined parcel. Therefore, the Tribunal finds that good cause exists to grant Petitioner’s motion and to update the subject property’s parcel number. The Tribunal has reviewed the Stipulation and finds that it comports with the mandates of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. IT IS FURTHER ORDERED that the docket shall be updated to reflect the change in the subject property’s parcel number, as indicated herein. IT IS FURTHER ORDERED that the Joint Stipulation for Entry of Consent Judgment including all attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise indicated. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax years at issue shall correct or cause the assessment rolls to be 1 See MCL 211.27a.
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MTT Docket No. 25-001746 Page 2 of 2 corrected to reflect the property’s true cash and taxable values as provided in this Consent Judgment within 20 days of the entry of the Consent Judgment.2 IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund as required by the Consent Judgment within 28 days of the entry of the Consent Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a proportionate share of any property tax administration fees paid and of penalty and interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless otherwise indicated, bear interest from the date of payment to the date of judgment and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, and (viii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%. This Consent Judgment resolves all pending claims in this matter and closes this case. See docket look up for a copy of stipulation and for any possible refund paragraph. By _____________________________ Entered: November 10, 2025 sb 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
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4918-3370-3287.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, Petitioner, MTT Docket No 25-001746-TT v CITY OF LANSING, Respondent. ______________________________________________________________________________/ FOLEY & LARDNER LLP CITY OF LANSING ASSESSING DEPT. Attorneys for Petitioner Representative for Respondent By: Jason Conti (P55617) By: Jennifer Czeiszperger, MMAO 500 Woodward Avenue, Suite 2700 124 W. Michigan Avenue, 3rd Floor Detroit, Michigan 48226 Lansing, Michigan 48933 (313) 234-7100 (517) 483-7624 jconti@foley.com _______________________________________________________________________________/ UNOPPOSED MOTION TO AMEND THE PARCEL ID NUMBER FOR THE SUBJECT PROPERTY PETITIONER moves to amend the parcel id number for the Subject Property, and states: 1. At the time of filing the Petition, Petitioner correctly identified the address and the four contiguous parcel numbers that made up the Subject Property, specifically tax parcel nos. 01-01-17-226- 291, 01-01-17-226-021, 01-01-17-226-011, and 01-01-17-226-001. 2. Sometime in 2025 Respondent administratively combined those four tax parcel identification numbers for the Subject Property into one brand new parcel number, identified as tax parcel no. 33-01-01-17-226-292, and issued 2025 assessed and taxable values for this new parcel number totaling $549,700 each. 2. As a result, Petitioner files this motion to amend in order to reflect that the current correct parcel number for the Subject Property is 33-01-01-17-226-292.
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2 4918-3370-3287.1 3. Respondent stated that it does not oppose this Motion and the relief requested herein. WHEREFORE, Petitioner requests that this Tribunal enter an order: (i) granting the Motion, (ii) amending the Petition, and any amendments thereto, so that the parcel id number for the Subject Property is 33-01-01-17-226-292, and (iii) awarding Petitioner any additional relief this Tribunal deems necessary and just. Respectfully submitted, FOLEY & LARDNER LLP Attorneys for Petitioner By s/ Jason Conti_______ Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7100 jconti@foley.com Dated: November 5, 2025 CERTIFICATE OF SERVICE The undersigned states that on November 5, 2025, he had a copy of this Motion served on the following via email: Jennifer Czeisperger jennifer.czeiszperger@lansingmi.gov /s/ Jason Conti
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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 Coughlin Partners LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001746 City of Lansing, Presiding Judge Respondent. Patricia L. Halm ORDER GRANTING PETITIONER’S MOTION TO AMEND ORDER CORRECTING DOCKET ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT On November 5, 2025, Petitioner filed a Motion to Amend. In the motion, Petitioner states that the petition filed on May 29, 2025, correctly identified the subject property as consisting of four parcels of property and correctly listed the parcel numbers. However, after the petition was filed, Respondent combined the four parcels of property and assigned Parcel No. 33-01-01-17-226-292 to this new parcel. Given this, the docket needs to be corrected to reflect the new parcel number. In its answer, filed September 25, 2025, Respondent acknowledges that the parcels have been combined and that Respondent assigned Parcel No. 33-01-01-17-226-292 to the combined parcel. Therefore, the Tribunal finds that good cause exists to grant Petitioner’s motion and to update the subject property’s parcel number. The Tribunal has reviewed the Stipulation and finds that it comports with the mandates of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. IT IS FURTHER ORDERED that the docket shall be updated to reflect the change in the subject property’s parcel number, as indicated herein. IT IS FURTHER ORDERED that the Joint Stipulation for Entry of Consent Judgment including all attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise indicated. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax years at issue shall correct or cause the assessment rolls to be 1 See MCL 211.27a.
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MTT Docket No. 25-001746 Page 2 of 2 corrected to reflect the property’s true cash and taxable values as provided in this Consent Judgment within 20 days of the entry of the Consent Judgment.2 IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund as required by the Consent Judgment within 28 days of the entry of the Consent Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a proportionate share of any property tax administration fees paid and of penalty and interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless otherwise indicated, bear interest from the date of payment to the date of judgment and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, and (viii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%. This Consent Judgment resolves all pending claims in this matter and closes this case. See docket look up for a copy of stipulation and for any possible refund paragraph. By _____________________________ Entered: November 10, 2025 sb 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
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RECEIVED SEP 95 2025 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL Coughlin Partners, LLC Petitioner v MOAHR Docket 25-001746 Parcel No. 33-01-01-17-226-292 CITY OF LANSING, Respondent Jennifer Czeiszperger, MMAO City Assessor 124 W. Michigan Avenue 3rd Floor, City Hall Lansing, MI 48933 (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov RESPONDENT’S ANSWER TO PETITIONER’S PETITION AND AFFIRMATIVE DEFENSES RESPONDENT, the City of Lansing, through its Assessor, Jennifer Czeiszperger, hereby responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent denied the allegations in Paragraph 1, the parcel numbers listed have been combined for the 2025 tax year to parcel number 33-01-01-17-226-292. The listed parcel numbers are no longer active parcel numbers. Further the mailing address on records is 24500 Northwestern Hwy, Ste 100, Southfield, MI 48075. ’ 2. Respondent admits the allegations in Paragraph 2.
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MTT Docket # 25-001746 10. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies that those issues have merit and further denies that Petitioner is entitled to any relief. Further, the subject property did not have any “additions” or “losses” for the 2025 tax year. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies that those issues have merit and further denies that Petitioner is entitled to any relief. Further, the subject property did not have any “additions” or “losses” for the 2025 tax yeat. Respondent denies the allegations in paragraph 7. The Petitioner did not make a March Board of Review appeal for the 2025 assessment. This was not required for this property classification. Respondent denies the allegations in Paragraph 8 for the reason that it is 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 constitutional. Respondent contends that the 2025 values for the property identified above are: Parcel Number True Cash Value Assessed Value Taxable Value 33-01-01-17-226-292 | $ 1,099,400 $549,700 $549,7008 The 2025 values in dispute for the property identified above are: Parcel Number True Cash Value | Assessed Value | Taxable Value 33-01-01-17-226-292 $0 $0 $0 WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal dismiss the Petition; affirm Respondent’s assessed and taxable values, subject to county and state equalization., and award Respondent its cost and attorney fees.
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MTT Docket # 25-001746 AFFIRMATIVE DEFENSES PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the following affirmative defenses: A. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against the Respondent and to support Petitioner’s claim for relief. B. 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). C. 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). B. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, and application of wrong principles or illegality on the part of the Respondent or its agents. C. Petitioner fails to allege the mode and method of assessing the subject property failed to conform to the mode and method applied in the case of all properties within the Respondent’s taxing unit for the tax year in questions. D. Petitioner fails to allege specific and sufficient facts needed to establish the true cash value, assessed and taxable value for the subject property. E. Petitioner fails to allege specific and sufficient facts to support its allegations that the assessed value of the subject property, as equalized, is at a level other than 50% and it also fails to allege specific and sufficient facts to support its allegations that the subject property’s
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MTT Docket # 25-001746 G. Petitioner asks this Tribunal to grant it illegal preference by application of a method of assessment different from that utilized in the assessment of
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STATE
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C
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1 4903-4007-2823.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, Petitioner, MTT Docket No 25-001746-TT v CITY OF LANSING, Respondent. _____________________________________________/ STIPULATION FOR ENTRY OF CONSENT JUDGMENT 1. The case is pending in the X Entire Tribunal OR __ Small Claims Division. 2. Property Parcel No: 33-01-01-17-226-292 3. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-01-17-226- 292 $1,099,400 $549,700 $549,700 4. The values for the property identified above as stipulated by the parties for settlement purposes are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-01-17-226- 292 $550,000 $275,000 $275,000 5. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years: 6. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc.:
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2 4903-4007-2823.1 IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable jointly to Petitioner named herein and its counsel, Foley & Lardner LLP, and sent in care of such counsel. Calculations of the refund amount shall also be sent to Petitioner’s counsel at the same address. IT IS FURTHER ORDERED AND ADJUDGED that all interest due hereunder is waived if, and only if, all refunds otherwise due are made within 120 days of the date of entry of the Consent Judgment. FOLEY & LARDNER LLP CITY OF LANSING ASSESSING DEPT. Attorneys for Petitioner Representative for Respondent By: /s/ Jason Conti By: /s/ Jennifer Czeiszperger Jason Conti (P55617) Jennifer Czeiszperger 500 Woodward Avenue, Suite 2700 124 W. Michigan Avenue, 3rd Floor Detroit, Michigan 48226 Lansing, Michigan 48933 (313) 234-7177 (517) 483-7624 Dated: November 5, 2025
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4918-3370-3287.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, Petitioner, MTT Docket No 25-001746-TT v CITY OF LANSING, Respondent. ______________________________________________________________________________/ FOLEY & LARDNER LLP CITY OF LANSING ASSESSING DEPT. Attorneys for Petitioner Representative for Respondent By: Jason Conti (P55617) By: Jennifer Czeiszperger, MMAO 500 Woodward Avenue, Suite 2700 124 W. Michigan Avenue, 3rd Floor Detroit, Michigan 48226 Lansing, Michigan 48933 (313) 234-7100 (517) 483-7624 jconti@foley.com _______________________________________________________________________________/ UNOPPOSED MOTION TO AMEND THE PARCEL ID NUMBER FOR THE SUBJECT PROPERTY PETITIONER moves to amend the parcel id number for the Subject Property, and states: 1. At the time of filing the Petition, Petitioner correctly identified the address and the four contiguous parcel numbers that made up the Subject Property, specifically tax parcel nos. 01-01-17-226- 291, 01-01-17-226-021, 01-01-17-226-011, and 01-01-17-226-001. 2. Sometime in 2025 Respondent administratively combined those four tax parcel identification numbers for the Subject Property into one brand new parcel number, identified as tax parcel no. 33-01-01-17-226-292, and issued 2025 assessed and taxable values for this new parcel number totaling $549,700 each. 2. As a result, Petitioner files this motion to amend in order to reflect that the current correct parcel number for the Subject Property is 33-01-01-17-226-292.
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2 4918-3370-3287.1 3. Respondent stated that it does not oppose this Motion and the relief requested herein. WHEREFORE, Petitioner requests that this Tribunal enter an order: (i) granting the Motion, (ii) amending the Petition, and any amendments thereto, so that the parcel id number for the Subject Property is 33-01-01-17-226-292, and (iii) awarding Petitioner any additional relief this Tribunal deems necessary and just. Respectfully submitted, FOLEY & LARDNER LLP Attorneys for Petitioner By s/ Jason Conti_______ Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7100 jconti@foley.com Dated: November 5, 2025 CERTIFICATE OF SERVICE The undersigned states that on November 5, 2025, he had a copy of this Motion served on the following via email: Jennifer Czeisperger jennifer.czeiszperger@lansingmi.gov /s/ Jason Conti
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4935-7523-1075.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, MTT Docket No. 25-001746 Parcel Nos. 01-01-17-226-291 Petitioner, 01-01-17-226-021 01-01-17-226-011 v 01-01-17-226-001 CITY OF LANSING, Respondent. ________________________________________/ FOLEY & LARDNER LLP Attorneys for Petitioner By: Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7100 jconti@foley.com _____________________________________________/ PROOF OF SERVICE On August 26, 2025, I caused to be served, via the methods listed below, a copy of Petitioner’s Petition for the 2025 Tax Year, Notice of Docket Number, and this Proof of Service on: Ingham County Clerk 341 S. Jefferson Street Mason, Michigan 48854 via U.S. mail Ingham County Equalization Director P.O. Box 319 Courthouse Mason, Michigan 48854-0319 via U.S. mail Secretary of the Local School Board Lansing Public Schools 519 West Kalamazoo Street Lansing, Michigan 48933 via U.S. mail State Treasurer Michigan Dep’t of Treasury Treasury Building 430 W. Allegan Street Lansing, Michigan 48922 via U.S. mail Lansing City Clerk or Township Supervisor/Clerk 124 W. Michigan Avenue 9th Floor Lansing, Michigan 48933 via Certified Mail City of Lansing Assessor 124 W. Michigan Avenue 3rd Floor Lansing, Michigan 48933 via Certified Mail
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2 4935-7523-1075.1 FOLEY & LARDNER LLP Attorneys for Petitioner By: /s/ Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7100 jconti@foley.com
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1 4902-7256-8902.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, MTT Docket No. _____________ Parcel Nos. 01-01-17-226-291 Petitioner, 01-01-17-226-021 01-01-17-226-011 V 01-01-17-226-001 CITY OF LANSING, Respondent. ________________________________________/ PETITION FOR THE 2025 TAX YEAR COUGHLIN PARTNERS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, states: 1. Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, Michigan 48075. Petitioner is a party in interest with respect to property taxes on contiguous real property tax parcel nos. 01-01-17-226-291, 01-01-17-226-021, 01-01-17-226-011, and 01-01-17-226-001 (collectively, the “Subject Property”), also known as 1019 W Saginaw St, Lansing, Michigan. 2. Respondent City of Lansing (“Respondent”) assesses and collects property taxes on the Subject Property. 3. In 2025, Respondent determined the taxable and assessed values of the Subject Property to be as follows (which will result in a state equalized value in the same amount based upon the tentative equalization factor): Parcel No. AV TV 01-01-17-226-291 $416,700 $416,700 01-01-17-226-021 $5,800 $5,800 01-01-17-226-011 $5,000 $5,000
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2 4902-7256-8902.1 01-01-17-226-001 $18,200 $18,200 4. The Subject Property is classified as Commercial Real. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a board of review protest was filed in March, 2025. 8. The 2025 assessment, including state equalized value and taxable value, imposed on the Subject 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 the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and
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3 4902-7256-8902.1 (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 2024 taxable values and state equalized values of the Subject Property as follows: Parcel No. AV TV 01-01-17-226-291 $100,000 $100,000 01-01-17-226-021 $1,000 $1,000 01-01-17-226-011 $1,000 $1,000 01-01-17-226-001 $2,000 $2,000 and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully submitted, FOLEY & LARDNER LLP Attorneys for Petitioner By: /s/ Jason Conti Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7177 jconti@foley.com Dated: May 29, 2025
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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 Coughlin Partners LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-001746 City Of Lansing, 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 23, 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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1 4902-7256-8902.1 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COUGHLIN PARTNERS, LLC, MTT Docket No. _____________ Parcel Nos. 01-01-17-226-291 Petitioner, 01-01-17-226-021 01-01-17-226-011 V 01-01-17-226-001 CITY OF LANSING, Respondent. ________________________________________/ PETITION FOR THE 2025 TAX YEAR COUGHLIN PARTNERS, LLC (“Petitioner”), through its attorneys, Foley & Lardner LLP, states: 1. Petitioner’s principal office address is 24500 Northwestern Hwy., Suite 100, Southfield, Michigan 48075. Petitioner is a party in interest with respect to property taxes on contiguous real property tax parcel nos. 01-01-17-226-291, 01-01-17-226-021, 01-01-17-226-011, and 01-01-17-226-001 (collectively, the “Subject Property”), also known as 1019 W Saginaw St, Lansing, Michigan. 2. Respondent City of Lansing (“Respondent”) assesses and collects property taxes on the Subject Property. 3. In 2025, Respondent determined the taxable and assessed values of the Subject Property to be as follows (which will result in a state equalized value in the same amount based upon the tentative equalization factor): Parcel No. AV TV 01-01-17-226-291 $416,700 $416,700 01-01-17-226-021 $5,800 $5,800 01-01-17-226-011 $5,000 $5,000
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2 4902-7256-8902.1 01-01-17-226-001 $18,200 $18,200 4. The Subject Property is classified as Commercial Real. The Subject Property is presently used or available for use for Commercial purposes. Petitioner believes that the Subject Property was originally designed to be used for Commercial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. If P.A. 174 of 2006 requires a board of review protest for the Subject Property, then a board of review protest was filed in March, 2025. 8. The 2025 assessment, including state equalized value and taxable value, imposed on the Subject 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 the Subject Property that is taxable under Michigan law, and are based upon the application of wrong principles; and
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3 4902-7256-8902.1 (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 2024 taxable values and state equalized values of the Subject Property as follows: Parcel No. AV TV 01-01-17-226-291 $100,000 $100,000 01-01-17-226-021 $1,000 $1,000 01-01-17-226-011 $1,000 $1,000 01-01-17-226-001 $2,000 $2,000 and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Respectfully submitted, FOLEY & LARDNER LLP Attorneys for Petitioner By: /s/ Jason Conti Jason Conti (P55617) 500 Woodward Avenue, Suite 2700 Detroit, Michigan 48226 (313) 234-7177 jconti@foley.com Dated: May 29, 2025
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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 - Petitioner MOAHR DOCKET NO. Section 1: Petitioner’s Contact Information Filer type: Organization First Name/Company Name M.I. Last Name Coughlin Partners, LLC Home Address (No., Street, P.O. Box or Rural Route) 24500 Northwestern Hwy. Suite 100 City or Town Southfield State Michigan ZIP Code 48075 Telephone Number 3132347177 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jconti@foley.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Jason M.I. Last Name Conti Firm Name (if any) Foley & Lardner LLP Address (No., Street, P.O. Box or Rural Route) 500 Woodward Ave, Ste 2700 City or Town Detroit State Michigan ZIP Code 48226 Telephone Number 313-234-7177 Fax Number 313-234-2800 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jconti@foley.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?4 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 1019 W. Saginaw Street Lansing Michigan Taxing Authority (City or Township) City Of Lansing (INGHAM) County Ingham If you are appealing more than one parcel, are they contiguous or adjoining? Yes (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)
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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: 01-01-17-226-291 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 416700 Current Taxable Value as established by the Board of Review: 416700 What do you believe is the fair market value (also known as True Cash Value)? 200000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 100000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Parcel Number: 01-01-17-226-021 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 5800 Current Taxable Value as established by the Board of Review: 5800 What do you believe is the fair market value (also known as True Cash Value)? 2000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 1000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Parcel Number: 01-01-17-226-011 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 5000 Current Taxable Value as established by the Board of Review: 5000 What do you believe is the fair market value (also known as True Cash Value)? 2000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR 1000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Parcel Number: 01-01-17-226-001 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 18200 Current Taxable Value as established by the Board of Review: 18200 What do you believe is the fair market value (also known as True Cash Value)? 4000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 2000 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
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