Mimg Xcv Bronco Club LLC Petitioner Vs. City Of Kalamazoo 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 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

MIMG XCV Bronco Club LLC,

Petitioner,

v

 

 

City Of Kalamazoo,

Respondent.

 MTT Docket No. 26-002589

Please be advised that 26-002589 has been placed on a two-week Prehearing General 

Call commencing August 02, 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covered by the order will not be published.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. 26-002589

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 5, 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 5, 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 5, 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 2, 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 1, 2026

Page 3

MTT Docket No. 26-002589

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 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF

Page 5

MTT Docket

Page 6

M

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MIMG XCV BRONCO CLUB, LLC, 

Petitioner, 

v 

CITY OF KALAMAZOO, 

Respondent. 

MTT Docket No. 26-002589 

Parcel No. 06-19-483-003 

_____________________________________________________________________________/ 

STEWART L. MANDELL (P33781) 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(313) 465-7270 

(248) 731-3089 

_____________________________________________________________________________/

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

ANSWER 

Respondent, City of Kalamazoo, by and through its attorneys, Hallahan & Associates, P.C., 

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

1. 

Respondent admits the allegations in Paragraph 1 as to parcel number and 

parcel address. Respondent lacks the knowledge and information necessary to respond to the 

remainder of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

2.

Respondent admits the allegations in Paragraph 2.

3.

Respondent admits the allegations in Paragraph 3.

Page 2

2

4. 

Respondent admits the subject property is classified as commercial improved. 

Respondent lacks the knowledge and information necessary to respond to the remainder of the 

allegations set forth in Paragraph 4 and, therefore, leaves Petitioner to its proofs. 

5. 

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

of the allegations set forth in Paragraph 5 and, therefore, leaves Petitioner to its proofs. 

6. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 6 but denies

that Petitioner’s claims have merit and further denies that Petitioner is entitled to any relief. 

7. 

Respondent denies any implication the subject property experienced a loss during 

the 2025 calendar year. 

[8]. 

Respondent neither admits nor denies the allegations in Petitioner’s 

second Paragraph 7 as the General Property Tax Act speaks for itself. 

[9]. 

Respondent denies the allegations in Petitioner’s Paragraph 8 [sic], 

including subparagraphs (a)-(d), for the reason that the same are 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 non-discriminatory and constitutional. 

[10]. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above paragraphs. 

WHEREFORE, Respondent, City of Kalamazoo, requests the Tribunal dismiss the 

Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, 

and award Respondent its costs and attorney fees.

Page 3

3

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan_____________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 7, 2026 

(248) 731-3089 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Kalamazoo, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

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). 

3. 

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). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question.

Page 4

4

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

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. 

10. 

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. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

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

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

13. 

Respondent reserves the right to raise additional affirmative defenses as the same 

may become

Page 5

5

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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 - Respondent

MTT DOCKET NO. 26-002589

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Kalamazoo (KALAMAZOO)

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

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

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

mtt@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

/s/Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MIMG XCV Bronco Club, LLC, 

Petitioner, 

MTT Docket No. 2 (p 

= 

© 0 25 89 

v 

Parcel No. 06-19-483-003 

City of Kalamazoo, 

Respondent. 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman, LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

jcook@honigman.com 

Proof of Service 

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

that on 

/ / [OD /2 & 

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

the parties named on the attached list. 

hr Les Qpouph 

~ 

Lisa Joseph 

{ 

7 

26-0010 

| 

75370621.2 

|

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

KALAMAZOO 

241 W. SOUTH STREET 

KALAMAZOO, MI 49007-4796 

ASSESSOR 

KALAMAZOO 

241 W. SOUTH STREET 

KALAMAZOO, MI 49007-4796 

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 

26-0010 

75370621.2

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

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: 26-002589

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: MIMG POS

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

WGC 

RECEIVED 

APR 29 2026 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MIMG XCV Bronco Club, LLC, 

Petitioner, 

MTT Docket No. 

Vv 

Parcel No. 06-19-483-003 

City of Kalamazoo, 

Respondent. 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman, LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

jcook@honigman.com 

Petition 

MIMG XCV Bronco Club, LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

L. 

Petitioner's principal 

office address 

is 2195 North Highway 

83, 

Suite 

14B, 

Franktown, CO 80116-9664. Petitioner is a party in interest with respect to property taxes on tax 

parcel number 06-19-483-003 ("Petitioner's Property"), with an address of 3201 Michigamme

Page 2

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$9,366,700 and assessed Petitioner's Property at $9,366,700, which will result in a state equalized 

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

4. 

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5. 

To the best knowledge of the undersigned, the multifamily units comprising 

Petitioner’s Property are not subject to a governmental regulatory agreement or a subsidy. 

6. 

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

value, and (d) uniformity, equal protection, and due process. 

7. 

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

relative to the value of a loss. 

7. 

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

8. 

The 2026 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

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, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and

Page 3

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and 

[C)]) 

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: (i) reducing the 

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

$9,366,700 to $7,000,000; (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. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

simandell@honigman.com 

Dated: April 29, 2026 

icook@honigman.com

Page 4

Honiaman LLP 

COSTS ADVANCED ACCOUNT 

040701 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

4129/26 

040701 

277710/540842/DLS 

#4%$600,00%%% 

Motion to Amend Filing Fee 

21074678.1

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

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

MIMG XCV Bronco Club LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-002589

City Of Kalamazoo, 

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 9, 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

Page 2

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

MIMG XCV Bronco Club LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-002589

City Of Kalamazoo, 

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 9, 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

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

MIMG XCV Bronco Club LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-002589

City Of Kalamazoo, 

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

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

WGC 

RECEIVED 

APR 29 2026 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MIMG XCV Bronco Club, LLC, 

Petitioner, 

MTT Docket No. 

Vv 

Parcel No. 06-19-483-003 

City of Kalamazoo, 

Respondent. 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman, LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

jcook@honigman.com 

Petition 

MIMG XCV Bronco Club, LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

L. 

Petitioner's principal 

office address 

is 2195 North Highway 

83, 

Suite 

14B, 

Franktown, CO 80116-9664. Petitioner is a party in interest with respect to property taxes on tax 

parcel number 06-19-483-003 ("Petitioner's Property"), with an address of 3201 Michigamme

Page 2

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$9,366,700 and assessed Petitioner's Property at $9,366,700, which will result in a state equalized 

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

4. 

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5. 

To the best knowledge of the undersigned, the multifamily units comprising 

Petitioner’s Property are not subject to a governmental regulatory agreement or a subsidy. 

6. 

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

value, and (d) uniformity, equal protection, and due process. 

7. 

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

relative to the value of a loss. 

7. 

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

8. 

The 2026 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

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, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and

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Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and 

[C)]) 

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: (i) reducing the 

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

$9,366,700 to $7,000,000; (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. 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

simandell@honigman.com 

Dated: April 29, 2026 

icook@honigman.com

Page 4

Honiaman LLP 

COSTS ADVANCED ACCOUNT 

040701 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

4129/26 

040701 

277710/540842/DLS 

#4%$600,00%%% 

Motion to Amend Filing Fee 

21074678.1

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