Lansing Everett Apartments LLC Petitioner Vs. City Of Lansing Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF AUGUST 16- 31, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Lansing Everett Apartments LLC,

Petitioner,

v

 

 

City Of Lansing,

Respondent.

 MTT Docket No. 26-001398

Please be advised that 26-001398 has been placed on a two-week Prehearing General 

Call commencing August 16, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

Users who file documents with the Tribunal are advised that filed documents are 

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the Tribunal and 

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 26-001398

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by April 19, 2027. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

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

Statements by April 19, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

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

April 19, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

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

August 16, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: September 16, 2026

Page 3

MTT Docket No. 26-001398

Page 3 of 3

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF AUGUST 16- 31, 2027 PREHEARING GENERAL CALL AND ORDER

Page 5

MTT

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Page 1

RECEIVED 

JUL 2 92026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

LANSING EVERETT APARTMENTS LLC 

Petitioner 

Vv 

MOAHR Docket 26-001398 

Parcel No. 33-01-01-33-127-052 

CITY OF LANSING, 

Respondent 

Jennifer Hendrix, 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 Hendrix, hereby responds 

to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the allegations 

in Paragraph 

1. 

The owner of record is Lansing Everett Apartments LLC, 

, 41127 

Scarborough Lane, Novi, MI 48375. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

MTT Docket # 26-001398 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

Respondent admits the allegations in Paragraph 8. 

Respondent admits the allegations in Paragraph 9. 

Respondent neither admits nor denies the allegations in Paragraph 10 for reason that 

they do not have sufficient knowledge to for a belief as to the truth of the allegations and 

leaving Petitioner to their strictest proofs. 

Respondent neither admits nor denies the allegations in Paragraph 11 for reason that 

they do not have sufficient knowledge to for a belief as to the truth of the allegations and 

leaving Petitioner to their strictest proofs. 

Respondent admits the allegations in Paragraph 12. 

Respondent denies the allegations in Paragraph 13 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 vatues and 

Respondent’s mode of assessment are constitutional. Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year and leaving Petitioner to their 

strictest proofs. 

The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

33-01-01-33-127-052 

Taxable Value 

$1,152,300 

True Cash Value | Assessed Value 

$2,304,600 

$1,152,300 

Respondent contends that the 2026 values for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-33-127-052 

$2,304,600 

$1,152,300 

$1,152,300 

The 2026 values in dispute for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-33-127-052 

$0 

$0 

$0

Page 3

MTT Docket # 26-001398 

OFFICE OF THE CITY ASSESSOR 

CITY OF LANSING 

Dated: Tl24fze 

By.) all QA awd 

ay 

Jennifer Hendrix, MMAO 

City Assessor, City of Lansing 

3d Floor, City Hall 

124 

W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov

Page 4

‘MTT Docket # 26-001398 

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 

Respondents 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

Page 5

MTT Docket # 26-001398 

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 other properties in the Respondent’s 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

L 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

I. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

K. 

Respondent reserves the right to add affirmative defenses which may become 

known during the course of informal or formal discovery proceedings. 

WHEREFORE, Respondent denies that the Petitioner 

is entitled 

to any relief and 

respectfully requests that the Respondent’s assessed and taxable values for the year under appeal 

be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be 

granted all attorney fees

Page 6

STAT

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Page 1

26-0014 

75538370.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lansing Everett Apartments LLC, 

Petitioner, 

v 

City of Lansing,

Respondent. 

MTT Docket No. ________ 

Parcel No. 33-01-01-33-127-052 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

Lansing Everett Apartments LLC (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1.

Petitioner's principal office address is 6631 Commerce Parkway, Suite N, Dublin, 

OH 43017. 

2.

The subject real property, parcel number 33-01-01-33-127-052, is located at 3518 

Davidson Dr., Lansing, MI, in Ingham County ("Petitioner's Property"). 

3.

Respondent, City of Lansing, assesses and collects property taxes on Petitioner's 

Property. 

4.

In 2026, Respondent’s Board of Review set the taxable value of Petitioner's 

Property at $1,152,300 and assessed Petitioner's Property at $1,152,300.

Page 2

2 

75538370.1 

5.

Respondent’s board of review assessing Petitioner’s Property will result in a state 

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

6.

Petitioner's Property is classified as commercial real. 

7.

Petitioner's Property is presently used or available for use for commercial purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

commercial purposes. 

9.

Petitioner’s Property is a multifamily residential property subject to Housing 

Assistance Payments Contracts and subsidies. 

10.

This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

11.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

12.

No board of review protest was required for Petitioner’s Property. 

13.

The 2026 assessment – including the state equalized and taxable values – imposed 

on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode 

of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, 

because they 

(a) 

Exceed amounts permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

(c) 

Are based on the application of wrong principles and an erroneous 

determination of the true cash value of that portion of Petitioner's Property that

Page 3

3 

75538370.1 

is taxable under Michigan law, if any; and 

(d) 

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: (i) reducing the 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property from 

$1,152,300 to $500,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 26, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Lansing Everett Apartments LLC

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

6631 Commerce Parkway

Suite N

City or Town

Dublin

State

Ohio

ZIP Code

43017

Telephone Number

3134657270

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

600 Woodward Ave

Suite 2290

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

(313) 465-7420

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

jcook@honigman.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

3518 Davidson Dr

Lansing

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48906

Taxing Authority (City or Township)

City Of Lansing (INGHAM) 

County

Ingham

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

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

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

33-01-01-33-127-052

Classification of Property: Real (check one)

Commercial (check one)

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

1152300

Current Taxable Value as established by the Board of Review:

1152300

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

1000000

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

500000

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

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jackie J. Cook

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686912632

Supporting Waiver 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

Lansing Everett Apartments LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001398

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: August 11, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lansing Everett Apartments LLC, 

Petitioner, 

no 

Q 

MTT Docket No. .~_(, ~OC / 34 1.25 

v 

Parcel No. 33-01-01-33-127-052 

City of Lansing, 

Respondent. 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com 

Proof of Service 

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

that on 

// [2 

/ 2 [4 

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

the parties named on the attached list. 

/</ wil rao 

Lisa Joseph 

26-0014 

75538370.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

LANSING 

124 W. MICHIGAN AVENUE, 9TH FLOOR 

LANSING, MI 48933-1694 

ASSESSOR 

LANSING 

124 W. MICHIGAN AVENUE, 9TH FLOOR 

LANSING, MI 48933-1694 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

INGHAM COUNTY 

341 S. JEFFERSON STREET 

MASON, MI 48854 

DIRECTOR OF EQUALIZATION 

INGHAM COUNTY 

341 S. JEFFERSON STREET 

MASON, MI 48854 

SECRETARY OF SCHOOL BOARD 

LANSING SCHOOL DISTRICT (INGHAM) 

519 W. KALAMAZOO STREET, ADM. BLDG. 

LANSING, MI 48915 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

75538370.1 

26-0014

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001398

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Lansing Everett POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

26-0014 

75538370.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lansing Everett Apartments LLC, 

Petitioner, 

v 

City of Lansing,

Respondent. 

MTT Docket No. ________ 

Parcel No. 33-01-01-33-127-052 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

Lansing Everett Apartments LLC (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1.

Petitioner's principal office address is 6631 Commerce Parkway, Suite N, Dublin, 

OH 43017. 

2.

The subject real property, parcel number 33-01-01-33-127-052, is located at 3518 

Davidson Dr., Lansing, MI, in Ingham County ("Petitioner's Property"). 

3.

Respondent, City of Lansing, assesses and collects property taxes on Petitioner's 

Property. 

4.

In 2026, Respondent’s Board of Review set the taxable value of Petitioner's 

Property at $1,152,300 and assessed Petitioner's Property at $1,152,300.

Page 2

2 

75538370.1 

5.

Respondent’s board of review assessing Petitioner’s Property will result in a state 

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

6.

Petitioner's Property is classified as commercial real. 

7.

Petitioner's Property is presently used or available for use for commercial purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

commercial purposes. 

9.

Petitioner’s Property is a multifamily residential property subject to Housing 

Assistance Payments Contracts and subsidies. 

10.

This matter involves issues relating to (a) valuation, (b) assessment, (c) taxable 

value, and (d) uniformity. 

11.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

12.

No board of review protest was required for Petitioner’s Property. 

13.

The 2026 assessment – including the state equalized and taxable values – imposed 

on Petitioner's Property, the taxes to be levied and collected on Petitioner’s Property, and the mode 

of assessment adopted by Respondent are invalid, unlawful, and operate as a fraud on Petitioner, 

because they 

(a) 

Exceed amounts permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

Are calculated at or derived from higher percentages of true cash value than 

permissible under the Michigan Constitution and applicable statutes; 

(c) 

Are based on the application of wrong principles and an erroneous 

determination of the true cash value of that portion of Petitioner's Property that

Page 3

3 

75538370.1 

is taxable under Michigan law, if any; and 

(d) 

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: (i) reducing the 

2026 taxable value, assessed value, and state equalized value of Petitioner's Property from 

$1,152,300 to $500,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 26, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Lansing Everett Apartments LLC

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

6631 Commerce Parkway

Suite N

City or Town

Dublin

State

Ohio

ZIP Code

43017

Telephone Number

3134657270

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

Honigman LLP

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

600 Woodward Ave

Suite 2290

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

(313) 465-7420

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

jcook@honigman.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

3518 Davidson Dr

Lansing

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48906

Taxing Authority (City or Township)

City Of Lansing (INGHAM) 

County

Ingham

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

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

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

33-01-01-33-127-052

Classification of Property: Real (check one)

Commercial (check one)

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

1152300

Current Taxable Value as established by the Board of Review:

1152300

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

1000000

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

500000

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

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jackie J. Cook

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686912632

Supporting Waiver Documents:

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