Michigan

K & N Falcon LLC, Petitioner Vs. City Of Bay City Respondent

Petitioner: K & N Falcon LLC,
Respondent: City Of Bay City

Case overview

Docket number: 26-000984-TT
Status: Default Respondent
CaseType: ET Property
Division: ET
County: Bay
Judge: No judge assigned

Docket history

Line #	Subject	Filer	Line Ref	Enter Date/Post Mark	Fee	Related Item
6	Answer was received	RESP	Not recorded	09/09/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
5	Order Holding Party in Default	Not recorded	Not recorded	08/28/2026	Not recorded	Download
4	Proof of service of petition was received.	PET	Not recorded	07/21/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
3	Petition has been verified	PET	1	07/08/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
2	Notice of Docket Number ET	Not recorded	Not recorded	07/08/2026	Not recorded	Download
1	A petition was received.	PET	Not recorded	05/14/2026	$450.00	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download

Documents

Answer to Complaint _Bay City- K_N_(34834409.2).pdfRead complete document text →

Read document text excerpt

Page 1

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

____________________ 

 

 

K & N Falcon LLC, 

 

Plaintiff, 

v 

 

City of Bay City, 

 

Defendant. 

_____________________________________/

 

MTT Docket No. 26-000984 

 

Parcel No. 160-016-101-009-00 

 160-016-101-018-00 

 160-016-103-001-00 

 

 

Joshua T. Shillair (P72674) 

COLLIERS INTERNATIONAL 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

248.226.1632 

Attorneys for Petitioner

Thomas M. Amon (P72351) 

WARNER NORCROSS + JUDD LLP 

150 Ottawa Avenue NW, Suite 1500 

Grand Rapids, MI 49503 

616.752.2000 

Attorneys for Respondent

 

 

 

RESPONDENT’S ANSWER TO 2026 ENTIRE TRIBUNAL 

PROPERTY TAX PETITION 

 

City of Bay City ("Respondent"), through its attorneys, Warner Norcross + Judd LLP, 

states for its Answer as follows: 

 

1. 

The Petitioner in this matter, K & N Falcon LLC, has the legal residence or 

principal office address of 34550 Commerce rd. Fraser MI 48026. Petitioner is a party in interest 

with respect to property taxes on property parcel no(s). (hereinafter referenced as the Subject 

Property) 160-016-101-009-00 , 160-016-101-018-00 , 160-016-103-001-00. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous.

Page 2

2 

ANSWER: Admitted that the three parcels are contiguous. Respondent lacks sufficient 

knowledge and/or information to admit or deny the remaining allegations in this 

paragraph. 

2. 

The Subject Property is located in Bay County. 

ANSWER: 

Admitted. 

3. 

Respondent, City of Bay City of Bay County, assesses and collects property taxes on 

the Subject Property. 

ANSWER: 

Admitted. 

4. 

The Subject Property is real property and is classified as Commercial. 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. 

ANSWER: 

Admitted that some of the parcels are classified as 201 Commercial Improved 

and one of the parcels is classified as 202 commercial vacant. Respondent lacks sufficient 

knowledge and/or information to admit or deny the remaining allegations in this 

paragraph. 

5. 

Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

ANSWER: 

Admitted that protest was not required but only to the extent this appeal 

raises issues that are exempt from the board of review protest requirement under MCL 

205.735a. To the extent further response is required, Respondent lacks sufficient knowledge 

and/or information to admit or deny the remaining allegations in this paragraph. 

6. 

The Subject Property’s address is: 

915 Sibley, Bay City, MI 48706

Page 3

3 

4050 Wilder, Bay City, MI 48706 

4100 Wilder, Bay City, MI 48706 

ANSWER: 

Admitted as to the addresses, with the modification that the Wilder addresses 

are on E Wilder Road. 

7. 

This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

ANSWER: 

Respondent lacks sufficient knowledge and/or information to admit or deny 

the allegations in this paragraph. 

8. 

The tax year(s) at issue are: 2026. 

ANSWER: 

Admitted that this is the tax year the petition purports to challenge. 

9. 

The values for the Subject Property as established by Respondent’s Board of 

Review are: 

Tax Year

Parcel Number

True Cash Value

Assessed Value

Taxable 

Value 

2026

160-016-101- 

009-00 

$119,900.00 

$59,950.00 

$59,950.00 

2026

160-016-101- 

018-00 

$2,711,300.00 

$1,355,650.00 

$1,276,099.0 

0 

2026

160-016-103- 

001-00 

$3,508,500.00 

$1,754,250.00 

$1,619,904.0 

0 

 

ANSWER: 

Admitted that the assessments for 2026 are accurately set forth in this 

paragraph. 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of 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:

Page 4

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

exceeds the amounts permitted by the Michigan Constitution, applicable statutes and case law;

The assessment, assessed value, state equalized value and/or taxable value are

at higher percentages of true cash value than permissible under the Michigan Constitution,

applicable statutes and case law;

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

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

the mode of assessment adopted by Respondent, discriminate against Petitioner and denies

Petitioner its constitutional rights to uniformity, equal protection and dues process of law.

ANSWER:

Denied as untrue.

11. Petitioner contends that the actual values for the Subject Property are:

Tax Year

Parcel Number

True Cash Value

Assessed Value

Taxable Value

2026

160-016-101-

009-00

$60,000.00

$30,000.00

2026

160-016-101-

018-00

$2,000,000.00

$1,000,000.00

2026

160-016-103-

001-00

$2,700,000.00

$1,350,000.00

ANSWER:

Admit that these are Petitioner’s contentions, denied as untrue that those

contentions are accurate or reflect the value of the property.

12.

The amount of value in contention for the Subject Property is:

Page 5

5 

Tax Year

Parcel Number

Assessed Value in Contention

2026

160-016-101-009-00 

$29,950.00 

2026

160-016-101-018-00

$355,650.00

2026

160-016-103-001-00 

$404,250.00 

 

ANSWER: 

Admitted that these amounts, and the difference between any other amount 

asserted by Petitioner that is lower than the present value(s) established by Respondent, are 

in dispute. 

13. 

Petitioner relies on the following specific facts to

Page 6

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

EntireTribunalCaseISAnswer.pdfRead complete document text →

Read document text excerpt

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000984

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Bay City (BAY)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Thomas

M.I.

M

Last Name

Amon

Firm Name (if any)

Warner Norcross + Judd LLP

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

150 Ottawa Ave NW

Suite 1500

City or Town

Grand Rapids

State

 Michigan

ZIP Code

49503

Telephone Number

(616)752-2727

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

tamon@wnj.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Thomas M. Amon

/s/

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Order_Holding_Party_in_Default.2026-08-28_15-25-15.pdfRead complete document text →

Read document text excerpt

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

K & N Falcon LLC,,

Petitioner, MICHIGAN TAX TRIBUNAL

ENTIRE TRIBUNAL

MTT Docket No. 26-000984

City Of Bay City,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an

answer to the petition and file proof demonstrating service of the answer within 14 days

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated

above, within 14 days of the entry of this order.1

Failure to comply with this order will result in the defaulted party being required to file a

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: August 28, 2026

1 “A submission by mail is considered filed on the date indicated by the United States Postal Service

postmark on the envelope containing the submission. A submission without a postmark or with an illegible

postmark is considered filed on the date the submission is received by the tribunal. A submission by

commercial delivery service is considered filed on the date the submission is given to the commercial

service for delivery to the tribunal as indicated by the receipt date on the package containing the

submission. A submission by personal service is considered filed on the date the submission is received.

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m.

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal

act, MCL 205.735a.” TTR 225(5).

Page 2

MTT Docket No. 26-000984

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

K & N Falcon LLC,,

Petitioner, MICHIGAN TAX TRIBUNAL

ENTIRE TRIBUNAL

MTT Docket No. 26-000984

City Of Bay City,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an

answer to the petition and file proof demonstrating service of the answer within 14 days

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib.

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated

above, within 14 days of the entry of this order.2

Failure to comply with this order will result in the defaulted party being required to file a

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: August 28, 2026

2 “A submission by mail is considered filed on the date indicated by the United States Postal Service