Medical Behavioral Hospital Of Mi LLC Dba Kalamazoo Bh Hospital, Petitioner Vs. Township Of Texas, Respondent
- Petitioner
- Medical Behavioral Hospital Of Mi LLC Dba Kalamazoo Bh Hospital
- Respondent
- Township Of Texas
Case overview
- Docket number
- 25-002004-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Kalamazoo
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 11 | Consent Judgment | Not recorded | Not recorded | 03/10/2026 | Not recorded | Download |
| 10 | Granted | PET | 9 | 03/10/2026 | Not recorded | Download |
| 9 | A Stipulation has been received. | PET | Not recorded | 03/09/2026 | $50.00 | Download |
| 8 | Prehearing General Call | Not recorded | Not recorded | 01/02/2026 | Not recorded | Download |
| 7 | Answer was received | Not recorded | Not recorded | 08/19/2025 | Not recorded | Download |
| 6 | ET Case Info Sheet | Not recorded | Not recorded | 08/19/2025 | Not recorded | Download |
| 5 | Proof of service of petition was received. | PET | Not recorded | 06/06/2025 | Not recorded | Download |
| 4 | Petition has been verified | PET | 2 | 08/05/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 08/05/2025 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 05/30/2025 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 05/30/2025 | $600.00 | 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 Medical Behavioral Hospital of MI LLC MICHIGAN TAX TRIBUNAL dba Kalamazoo BH Hospital, Petitioner, v MTT Docket No. 25-002004 Texas Township, Presiding Judge Respondent. Jason C. Grinnell ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT 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 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 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 1 See MCL 211.27a. 2 See MCL 205.755.
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MTT Docket No. 25-002004 Page 2 of 2 shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, (ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, and (xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 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: March 10, 2026 am 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 DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Medical Behavioral Hospital of Michigan LLC, d/b/a Kalamazoo Behavioral Health Hospital, Petitioner, v MTT Docket No. 25-002004 Texas Twp., Respondent. / Stipulation for Entry of Consent Judgment 1. The parcel is located in Kalamazoo County. 2. The case is pending in the X Entire Tribunal OR ___ Small Claims Division. 3. Property Parcel No: 09-02-376-002. 4. The values for the property identified above as established by Respondent’s Board of Review are: Tax True Cash Assessed Taxable Year Value Value Value 2025 $15,417,800 $7,708,900 $7,417,117 5: The values for the property identified above as stipulated by the parties for settlement purposes are: Tax True Cash State Equalized Taxable Year Value Value Value 2025 $11,800,000 $5,900,000 $5,900,000 6. If stipulation addresses tax years other than the tax year originally appealed or tax years
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March 9, 2026 7. 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.: IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable jointly to Petitioner named herein and its counsel, Honigman LLP, and sent to Jackie J. Cook, Honigman LLP, 2290 First National Building, 660 Woodward, Detroit, MI 48226. Calculations of the refund amount shall also be sent to Petitioner’s counsel at the same address. All interest due hereunder is waived if, and only if, all refunds otherwise due are paid within 60 days of the entry of the consent judgment, however, otherwise interest shall be paid as provided in the Tax Tribunal Act, including MCL 205.737. Bauckham, Thall, Seeber, Kaufman & Honigman LLP Koches, P.C. Attorneys for Petitioner Attorneys for Responde: By: ; Py ot By: ne 74 Ja . Cook (P6&781) Robert E. Thall (P46421) §60-Woodward Avenue 470 W. Centre Avenue, Ste. A 2290 First National Bldg. Portage, MI 49024-5362 Detroit, MI 48226-3506 (269) 382-4500 (313) 465-7270 thall@michigantownshiplaw.com jcook@honigman.com Dated: March 9, 2026 Dated: Hoe. [ 7 2026
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Medical Behavioral Hospital of Michigan LLC, d/b/a Kalamazoo Behavioral Health Hospital, Petitioner, v MTT Docket No. 25-002004 Texas Twp., Respondent. / Stipulation for Entry of Consent Judgment 1. The parcel is located in Kalamazoo County. 2. The case is pending in the X Entire Tribunal OR ___ Small Claims Division. 3. Property Parcel No: 09-02-376-002. 4. The values for the property identified above as established by Respondent’s Board of Review are: Tax True Cash Assessed Taxable Year Value Value Value 2025 $15,417,800 $7,708,900 $7,417,117 5: The values for the property identified above as stipulated by the parties for settlement purposes are: Tax True Cash State Equalized Taxable Year Value Value Value 2025 $11,800,000 $5,900,000 $5,900,000 6. If stipulation addresses tax years other than the tax year originally appealed or tax years
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March 9, 2026 7. 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.: IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable jointly to Petitioner named herein and its counsel, Honigman LLP, and sent to Jackie J. Cook, Honigman LLP, 2290 First National Building, 660 Woodward, Detroit, MI 48226. Calculations of the refund amount shall also be sent to Petitioner’s counsel at the same address. All interest due hereunder is waived if, and only if, all refunds otherwise due are paid within 60 days of the entry of the consent judgment, however, otherwise interest shall be paid as provided in the Tax Tribunal Act, including MCL 205.737. Bauckham, Thall, Seeber, Kaufman & Honigman LLP Koches, P.C. Attorneys for Petitioner Attorneys for Responde: By: ; Py ot By: ne 74 Ja . Cook (P6&781) Robert E. Thall (P46421) §60-Woodward Avenue 470 W. Centre Avenue, Ste. A 2290 First National Bldg. Portage, MI 49024-5362 Detroit, MI 48226-3506 (269) 382-4500 (313) 465-7270 thall@michigantownshiplaw.com jcook@honigman.com Dated: March 9, 2026 Dated: Hoe. [ 7 2026
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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 NOTICE OF DECEMBER 1 - 14, 2026 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Medical Behavioral Hospital of MI LLC dba Kalamazoo BH Hospital, Petitioner, v Township Of Texas, Respondent. MTT Docket No. 25-002004 Please be advised that 25-002004 has been placed on a two-week Prehearing General Call commencing December 01, 2026. 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.
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MTT Docket No. 25-002004 Page 2 of 3 Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 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 August 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. IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing Statements by August 4, 2026. 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 August 4, 2026, 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 December 1, 2026, 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
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MTT Docket No. 25-002004 Page 3 of 3 Entered: January 2, 2026 PROOF OF SERVICE I certify that a copy of the foregoing was sent on the entry date indicated above
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ST
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MEDICAL BEHAVIORAL HOSPITAL OF MICHIGAN LLC, D/B/A KALAMAZOO BEHAVIORAL HEALTH HOSPITAL, Petitioner, MTT Docket No. 25-002004-TT \% TEXAS TOWNSHIP, Respondent. Jackie J. Cook (P68781) Robert E. Thall (P46421) Honigman LLP Bauckham, Thall, Seeber, Attorney for Petitioner Kaufman & Koches, P.C. 39400 Woodward Ave., Ste. 101 Attorney for Respondent Bloomfield Hills, MI 48304 470 W. Centre Ave., Suite A 248-566-8474 Portage, MI 49024-5362 jcook@honigman.com 269-382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, Texas Township states the following in response to the respective paragraphs of the Petition filed in this matter: 1. In answer to paragraph 1 of the Petition, Respondent admits the allegation therein. 2. In answer to paragraph 2 of the Petition, Respondent admits the allegation therein. 3. In answer to paragraph 3 of the Petition, Respondent admits the allegation therein.
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8. In answer to paragraph 8 of the Petition, Respondent admits the allegation therein. 9. In answer to paragraph 9 of the Petition, Respondent admits the allegations therein. 10. In answer to paragraph 10 of the Petition, Respondent admits that the Petitioner has raised the issues identified therein. 11. In answer to paragraph 11 of the Petition, Respondent lacks knowledge or information sufficient to form a belief about the truth of the allegations therein. 12. In answer to paragraph 12 of the Petition, Respondent lacks knowledge or information sufficient to form a belief about the truth of the allegations therein. 13. Inanswer to paragraph 13 of the Petition, Respondent admits the allegation therein. 14. In answer to paragraph 14 (a) through (d) of the Petition, Respondent denies the allegations therein as untrue. WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying the relief requested by Petitioner and uphold and affirm the valuation as established by the Respondent and require Petitioner to pay Respondent’s costs and attorney fees. AFFIRMATIVE DEFENSES Please take notice that Respondent may rely on one or more of the following affirmative defenses: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 3. The service of process was insufficient.
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5. Respondent reserves the right to file such additional affirmative defenses as may become apparent pursuant to discovery procedures during the pendency of this matter. WHEREFORE Respondent requests that the Tribunal enter a determination of no cause in its favor, and such other and further relief as is appropriate including costs and attorney fees. Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN & KOCHES, P.C. Date: August 19, 2025 By: /s/ Kobert £ Thal Robert E. Thall Attorney for Respondent
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MEDICAL BEHAVIORAL HOSPITAL OF MICHIGAN LLC, D/B/A KALAMAZOO BEHAVIORAL HEALTH HOSPITAL, Petitioner, MTT Docket No. 25-002004-TT Vv TEXAS TOWNSHIP, Respondent. Jackie J. Cook (P68781) Robert E. Thall (P46421) Honigman LLP Bauckham, Thall, Seeber, Attorney for Petitioner Kaufman & Koches, P.C. 39400 Woodward Ave., Ste. 101 Attorney for Respondent Bloomfield Hills, MI 48304 470 W. Centre Ave., Suite A 248-566-8474 Portage, MI 49024-5362 jcook@honigman.com 269-382-4500 thall@michigantownshiplaw.com APPEARANCE The law firm of Bauckham, Thall, Seeber, Kaufman & Koches, P.C., enters this appearance for and on behalf of Respondent, Texas Township, in this matter. Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN & KOCHES, P.C.
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MEDICAL BEHAVIORAL HOSPITAL OF MICHIGAN LLC, D/B/A KALAMAZOO BEHAVIORAL HEALTH HOSPITAL, Petitioner, MTT Docket No. 25-002004-TT \Y% TEXAS TOWNSHIP, Respondent. Jackie J. Cook (P68781) Robert E. Thall (P46421) Honigman LLP Bauckham, Thall, Seeber, Attorney for Petitioner Kaufman & Koches, P.C. 39400 Woodward Ave., Ste. 101 Attorney for Respondent Bloomfield Hills, MI 48304 470 W. Centre Ave., Suite A 248-566-8474 Portage, MI 49024-5362 jcook@honigman.com 269-382-4500 thall@michigantownshiplaw.com PROOF OF SERVICE Sandra L. Bosse states that on August 19, 2025, she served a copy of an Appearance, Answer to Petition with Affirmative Defenses and Proof of Service in this matter by first-class mail, postage fully prepaid, upon the representative for Petitioner at the address shown above. A, a, Sandra L. Bosse
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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. 25-002004 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Township Of Texas (KALAMAZOO) 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 Robert M.I. E Last Name Thall Firm Name (if any) Address (No., Street, P.O. Box or Rural Route) 470 W. Centre Ave., Suite A City or Town Portage State Michigan ZIP Code 49024-5362 Telephone Number 269-382-4500 Fax Number 269-382-2040 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) thall@michigantownshiplaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Robert E Thall /s/
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RECEIVED JUN 06 2025 & Q *® STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Medical Behavioral Hospital of Michigan LLC, D/B/A Kalamazoo Behavioral Health Hospital, Petitioner, MTT Docket No. Pes Koi oO 200 i Parcel No. 09-02- 376-002 002 Vv. Texas Township. Respondent, Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (313) 465-7420 jcook@honigman.com Proof of Service Lisa Joseph states that she is employed by Honigman LLP, attorneys for Petitioner, and that on 7) [2 [25 ~, she did serve a copy of Petitioner's Entire Tribunal Property Tax Petition, with docket number, upon the parties named on the attached list. Lisa Joséph Dated: b[2[>5 Z. a (acy h
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BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: CLERK TEXAS TWP. 7110 W. Q AVE. KALAMAZOO, MI 49009-9705 ASSESSOR TEXAS TWP. 7110 W. Q AVE. KALAMAZOO, MI 49009-9705 AND BY FIRST-CLASS UNITED STATES MAIL: CLERK KALAMAZOO COUNTY 201 W. KALAMAZOO AVENUE KALAMAZOO, MI 49007-3726 DIRECTOR OF EQUALIZATION KALAMAZOO COUNTY 201 W. KALAMAZOO AVENUE KALAMAZOO, MI 49007-3726 SECRETARY OF SCHOOL BOARD KALAMAZOO SCHOOL DISTRICT 1220 HOWARD STREET KALAMAZOO, MI 49008-1882 STATE TREASURER MICHIGAN DEPARTMENT OF TREASURY TREASURY BUILDING 430 W. ALLEGAN ST. LANSING, MI 48922 25-0105
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60714748.1
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
Medical Behavioral Hospital of Michigan LLC,
D/B/A Kalamazoo Behavioral Health Hospital,
Petitioner,
v.
Texas Township,
Respondent,
MTT Docket No. ________
Parcel No. 09-02-376-002
Jackie J. Cook (P68781)
Honigman LLP
Attorneys for Petitioner
39400 Woodward Avenue, Suite 101
Bloomfield Hills, MI 48304-5151
(248) 566-8474
jcook@honigman.com
Entire Tribunal Property Tax Petition
Medical Behavioral Hospital of Michigan LLC, D/B/A Kalamazoo Behavioral Health
Hospital (“Petitioner”), through its attorneys, Honigman LLP, says:
1.
Petitioner's principal office address is 112 W. Jefferson Blvd., Suite 600, South
Bend, IN 46601.
2.
Petitioner is a party in interest with respect to property taxes on tax parcel number
09-02-376-002 ("Petitioner's Property")
3.
Petitioner’s Property has an address of 5802 S. 9th St., Kalamazoo, MI 49009
4.
Petitioner’s Property is located in Kalamazoo County, Michigan.
5.
Respondent, Texas Twp., assesses and collects property taxes on Petitioner's
Property.Page 2
2 60714748.1 6. Respondent’s Board of Review set the 2025 taxable value of Petitioner's Property at $7,417,117 and set the 2025 assessed value of Petitioner's Property at $7,708,900, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 7. Petitioner's Property is classified as commercial real. 8. Petitioner's Property is presently used or available for use for commercial purposes. 9. Petitioner believes that Petitioner's Property was originally designed to be used for commercial purposes. 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 the calculation of taxable value, that there is a dispute relative to the value of any losses under MCL 211.27a(2)(a). 12. At this time, Petitioner believes, as it relates to the calculation of taxable value, that there is a dispute relative to the value of any additions under MCL 211.27a(2)(a). 13. A board of review protest was not required for Petitioner’s Property. 14. The 2025 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected on Petitioner’s Property, are invalid and unlawful for the following reasons: (a) The 2025 assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 2025 assessment, including state equalized value and/or taxable value, is at a higher percentage of true cash value than permissible under the Michigan Constitution and applicable statutes;
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3 60714748.1 (c) The 2025 assessment, including taxable value and/or state equalized value, is based on an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and is based on the application of wrong principles; and (d) The 2025 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: (i) reducing the 2025 taxable value of Petitioner's Property from $7,417,117 to $5,500,000; (ii) reducing the 2025 assessed and state equalized value of Petitioner's Property from $7,708,900 to $5,500,000; (iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iv) awarding Petitioner any other relief to which it is entitled. Dated: May 30, 2025 HONIGMAN LLP Attorneys for Petitioner By: _______________________________________ Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com
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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 Medical Behavioral Hospital of MI LLC dba Kalamazoo BH Hospital, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-002004 Township Of Texas, 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 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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60714748.1
STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
Medical Behavioral Hospital of Michigan LLC,
D/B/A Kalamazoo Behavioral Health Hospital,
Petitioner,
v.
Texas Township,
Respondent,
MTT Docket No. ________
Parcel No. 09-02-376-002
Jackie J. Cook (P68781)
Honigman LLP
Attorneys for Petitioner
39400 Woodward Avenue, Suite 101
Bloomfield Hills, MI 48304-5151
(248) 566-8474
jcook@honigman.com
Entire Tribunal Property Tax Petition
Medical Behavioral Hospital of Michigan LLC, D/B/A Kalamazoo Behavioral Health
Hospital (“Petitioner”), through its attorneys, Honigman LLP, says:
1.
Petitioner's principal office address is 112 W. Jefferson Blvd., Suite 600, South
Bend, IN 46601.
2.
Petitioner is a party in interest with respect to property taxes on tax parcel number
09-02-376-002 ("Petitioner's Property")
3.
Petitioner’s Property has an address of 5802 S. 9th St., Kalamazoo, MI 49009
4.
Petitioner’s Property is located in Kalamazoo County, Michigan.
5.
Respondent, Texas Twp., assesses and collects property taxes on Petitioner's
Property.Page 2
2 60714748.1 6. Respondent’s Board of Review set the 2025 taxable value of Petitioner's Property at $7,417,117 and set the 2025 assessed value of Petitioner's Property at $7,708,900, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 7. Petitioner's Property is classified as commercial real. 8. Petitioner's Property is presently used or available for use for commercial purposes. 9. Petitioner believes that Petitioner's Property was originally designed to be used for commercial purposes. 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 the calculation of taxable value, that there is a dispute relative to the value of any losses under MCL 211.27a(2)(a). 12. At this time, Petitioner believes, as it relates to the calculation of taxable value, that there is a dispute relative to the value of any additions under MCL 211.27a(2)(a). 13. A board of review protest was not required for Petitioner’s Property. 14. The 2025 assessment, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected on Petitioner’s Property, are invalid and unlawful for the following reasons: (a) The 2025 assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The 2025 assessment, including state equalized value and/or taxable value, is at a higher percentage of true cash value than permissible under the Michigan Constitution and applicable statutes;
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3 60714748.1 (c) The 2025 assessment, including taxable value and/or state equalized value, is based on an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and is based on the application of wrong principles; and (d) The 2025 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: (i) reducing the 2025 taxable value of Petitioner's Property from $7,417,117 to $5,500,000; (ii) reducing the 2025 assessed and state equalized value of Petitioner's Property from $7,708,900 to $5,500,000; (iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iv) awarding Petitioner any other relief to which it is entitled. Dated: May 30, 2025 HONIGMAN LLP Attorneys for Petitioner By: _______________________________________ Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com
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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 Medical Behavioral Hospital of Michigan LLC, d/b/a Kalamazoo Behavioral Health Hospital Home Address (No., Street, P.O. Box or Rural Route) 112 W. Jefrerson City or Town South Bend State Indiana ZIP Code 49544 Telephone Number 2485668300 Fax Number 46601 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) ljoseph@honigman.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Jackie M.I. J. Last Name Cook Firm Name (if any) Honigman LLP Address (No., Street, P.O. Box or Rural Route) 39400 Woodward Avenue Suite 101 City or Town Bloomfield Hills State Michigan ZIP Code 48304 Telephone Number 248-566-8474 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) jcook@honigman.com Section 5: Issue Please designate one: Valuation – Fill out Sections 4, 5, & 6 below Section 6: Subject Property Information How many parcels are you appealing?1 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] Michigan Taxing Authority (City or Township) Township Of Texas (KALAMAZOO) County Kalamazoo If you are appealing more than one parcel, are they contiguous or adjoining?
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.) 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: 09-02-376-002 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 7708900 Current Taxable Value as established by the Board of Review: 7417117 What do you believe is the fair market value (also known as True Cash Value)? 11000000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 5500000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. Section 9: Assessment Information Type of Tax Assessment(s): Assessment Number(s): Check all that is being appealed: Check what action prompted this appeal: If “other,” please explain: Section 10: Special Assessment Information Type of Special Assessment: Did you protest the special assessment at the hearing held to confirm the special assessment roll? If Yes, what was the date of the hearing held to confirm the special assessment roll? If No, please explain: Section 11: Classification Information Parcel Number: Current Classification of Property as established by Board of Review: What do you believe is the property’s classification?
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR If improved property, how is the property currently being used? If improved property, for what use was the property designed? Fee Information The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed. If the State Equalized Value or Taxable Value in contention is: Your filing fee is: $100,000.00 and under $250.00 $100,000.01 to $500,000.00 $400.00 $Over $500,000.00 $600.00 * Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00. A fee of $250.00 is required for the filing of a Special 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
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