Neptune Kalamazoo LLC Petitioner Vs. Township Of Alamo 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

Neptune Kalamazoo LLC,

Petitioner,

v

 

 

Township Of Alamo,

Respondent.

 MTT Docket No. 26-001135

Please be advised that 26-001135 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covered by the order will not be published.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. 26-001135

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

Page 3

MT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NEPTUNE KALAMAZOO, LLC, 

Petitioner, 

MTT Docket No. 26-001135-TT 

\4 

TOWNSHIP OF ALAMO, 

Respondent. 

Brian E. Etzel (P54905) 

Robert E. Thall (P46421) 

Williams, Williams, Rattner 

Bauckham, Thall, Seeber, 

& Plunkett, PC 

Kaufman & Koches, P.C. 

Attorney for Petitioner 

Attorney for Respondent 

380 N. Old Woodward Ave., Ste. 300 

470 W. Centre Ave., Suite A 

Birmingham, MI 48009 

Portage, MI 49024-5362 

(248) 642-0333 

269-382-4500 

bee@wwrplaw.com 

thall@michigantownshiplaw.com 

PROOF OF SERVICE 

Sandra L. Bosse states that on July 30, 2026, she served 

a copy of an Appearance, 

Answer to Petition and Multiple Parcel Form with Affirmative Defenses and Proof of Service in 

this matter by first-class mail, postage fully prepaid, upon the Petitioner at the above referenced 

| 

doi fo 

Sandra L. Bosse

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NEPTUNE KALAMAZOO, LLC, 

Petitioner, 

MTT Docket No. 26-001135-TT 

v 

TOWNSHIP OF ALAMO, 

Respondent. 

Brian E. Etzel (P54905) 

Robert E. Thall (P46421) 

Williams, Williams, Rattner 

Bauckham, Thall, Seeber, 

& Plunkett, PC 

Kaufman & Koches, P.C. 

Attorney for Petitioner 

Attorney for Respondent 

380 N. Old Woodward Ave., Ste. 300 

470 W. Centre Ave., Suite A 

Birmingham, MI 48009 

Portage, MI 49024-5362 

(248) 642-0333 

269-382-4500 

bee@wwrplaw.com 

thall@michigantownshiplaw.com 

APPEARANCE 

Attorney Robert E. Thall 

of the law firm 

of Bauckham, Thall, Seeber, Kaufman & 

Koches, P.C., enters this appearance for and on behalf of Respondent, Township of Alamo, in 

this matter. 

Respectfully submitted, 

BAUCKHAM, SPARKS, THALL, SEEBER 

& KAUFMAN; P.C. 

Date: July 30, 2026 

1r V4

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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: 26-001135

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

Party Filing Document 

Respondent

Files

Document Type: Appearance

Attachment File Name: NEPTUNE V ALAMO APP 26-001135-TT10003320260730100913

Document Type: Proof of Service: Misc Documents

Attachment File Name: NEPTUNE V ALAMO POS 26-001135-TT10003420260730100959

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NEPTUNE KALAMAZOO, LLC, 

Petitioner, 

MTT Docket No. 26-001135-TT 

v 

TOWNSHIP OF ALAMO, 

Respondent. 

Brian E. Etzel (P54905) 

Robert E. Thall (P46421) 

Williams, Williams, Rattner 

Bauckham, Thall, Seeber, 

& Plunkett, PC 

Kaufman & Koches, P.C. 

Attorney for Petitioner 

Attorney for Respondent 

380 N. Old Woodward Ave., Ste. 300 

470 W. Centre Ave., Suite A 

Birmingham, MI 48009 

Portage, MI 49024-5362 

(248) 642-0333 

269-382-4500 

bee@wwrplaw.com 

thall@michigantownshiplaw.com 

ANSWER TO PROPERTY TAX PETITION AND MULTIPLE PARCEL 

FORM 

WITH AFFIRMATIVE DEFENSES 

Respondent, Township of Alamo, 

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 allegations 

therein. 

2. 

In answer to paragraph 

2 

of the Petition, Respondent admits the allegations 

therein, except that the Township is a general law township and not a charter township.

Page 2

4. 

In answer to paragraph 

4 of the Petition, Respondent admits the allegations 

therein. 

5. 

In answer to paragraph 

5 

of the Petition, Respondent admits the allegations 

therein. 

6. 

In answer to paragraph 

6 

of the Petition, Respondent admits the allegations 

therein. 

7. 

In answer to paragraph 7 of the Petition and paragraph 

1 of the Multiple Parcel 

Form, Respondent admits the allegations therein. 

8. 

In answer to paragraph 8 of the Petition and paragraph 2 of the Multiple Parcel 

Form, Respondent denies the contended valuations therein as untrue. 

9. 

In answer to paragraph 9 of the Petition and paragraph 3 of the Multiple Parcel 

Form, Respondent admits the allegations therein. 

10. 

In answer to paragraph 

10 of the Petition, Respondent admits the allegations 

therein. 

11. 

In answer to paragraph 11 of the Petition, Respondent denies the allegations as 

untrue. 

12. 

In answer to paragraph 12 of the Petition, Respondent denies that the Respondent 

overestimated the subject properties values as untrue. 

WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying 

the relief requested by Petitioner and uphold and affirm the valuations as established by the

Page 3

AFFIRMATIVE DEFENSES 

Please take notice that Respondent may rely on one or more of the following affirmative 

defenses: 

1. 

2. 

3. 

4. 

Petitioner has failed to state a claim upon which relief may be granted. 

The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 

The service of process was insufficient. 

The subject property is under assessed and/or the taxable value and/or state equalized 

value of the subject property 

is too low, and should therefore be appropriately increased to 

comply with the mandate of the applicable provisions of law. 

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, 

KAUFMANy& 

KOCHES P.C. 

Date: July 30, 2026 

lf 

By: 

5 

/ Robert E. Thall 

Attorney for Respondent

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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. 26-001135

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Alamo (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

Robert

M.I.

E

Last Name

Thall

Firm Name (if any)

Bauckham, Thall, et al

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

470 W Centre Ave Suite A

City or Town

Kalamazoo

State

 Michigan

ZIP Code

49024

Telephone Number

2693824500

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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NEPTUNE KALAMAZOO, LLC, 

Docket No. 26-001135 

Parcel Nos. 

39-01-13-476-020 

Petitioner, 

39-01-13-476-040 

\2 

CHARTER TOWNSHIP OF ALAMO, 

Respondent. 

Brian E. Etzel (P54905) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

PROOF OF SERVICE OF PETITION AND NOTICE OF DOCKET NUMBER

Page 2

PROOF OF SERVICE OF PETITION AND NOTICE OF DOCKET NUMBER 

Sarah Conner states that she served copies of the Entire Tribunal Property Tax Petition, Notice 

of Docket Number and this Proof of Service, on the persons listed below, by placing copies of those 

documents in a duly stamped, addressed envelope and placing the envelope in the United States mail 

on July 23, 2026. 

PERSONS SERVED: 

VIA CERTIFIED MAIL 

Charter Township of Alamo 

Office of the Assessor 

7901 North 6th Street 

Kalamazoo, MI 49009 

Charter Township of Alamo 

Office of the Township Clerk 

7901 North 6th Street 

Kalamazoo, MI 49009 

VIA FIRST CLASS US MAIL 

Kalamazoo County Clerk 

~~ Plainwell Community School District 

201 W. Kalamazoo Ave. 

Secretary of the School Board 

Kalamazoo, MI 49007 

600 School Drive 

Plainwell, MI 49080 

Kalamazoo County 

State Treasurer 

Director of Equalization 

Michigan Department of Treasury 

201 W. Kalamazoo Ave, 

Austin Building 

Room 404 

430 W. Allegan 

Kalamazoo, MI 49007 

Lansing, MI 

48922 

Jind & Down 

Sarah Conner

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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: 26-001135

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: Proof of Service-Petition-Notice of Docket Number

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

Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NEPTUNE KALAMAZOO, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 39-01-13-476-020 

Petitioner, 

 

 

 

 

 

 

 

39-01-13-476-040 

 

v. 

 

CHARTER TOWNSHIP OF ALAMO, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner NEPTUNE KALAMAZOO, LLC, by and through its attorneys, Williams 

Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner NEPTUNE KALAMAZOO, LLC, is a Michigan limited liability 

company with its registered office located at 1411 Third Street, Port Huron, MI 48060. 

2. 

Respondent Charter Township of Alamo is a Michigan township with its primary 

offices located at 7901 North 6th Street, Kalamazoo, MI 49009. 

The Subject Properties 

3. 

Petitioner owns properties identified as follows:

Page 2

Petition Page 2 

Parcel Number 

Property Address 

39-01-13-476-020 

8213 Neptune 

39-01-13-476-040 

8233 Neptune 

 

These parcels are physically contiguous to each other. They are referred to collectively in this 

Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Kalamazoo County and are within the 

Plainwell Community school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Properties. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as commercial 

real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ assessments 

for property taxes in the amounts set forth in paragraph 1 of the attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties for the 2026 

tax year cannot exceed the amounts set forth in paragraph 2 of the attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in paragraph 3 of the 

attached Multiple Parcel Form. 

10. 

This Petition presents issues involving the Subject Properties’ valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), 

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available.

Page 3

Petition Page 3 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, 

the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are 

based on the misapplication of valuation principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments are not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed 

Petitioner’s contentions of value set forth on the attached Multiple Parcel Form and granting 

Petitioner all other relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Brian E. Etzel 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 19, 2026 

 

 

Attorneys for Petitioner

Page 4

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NEPTUNE KALAMAZOO, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 39-01-13-476-020 

Petitioner, 

 

 

 

 

 

 

 

39-01-13-476-040 

 

v. 

 

CHARTER TOWNSHIP OF ALAMO, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s March 2026 

Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

39-01-13-476-020 

 1,157,800 

 578,900

Page 5

Multiple

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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

NEPTUNE KALAMAZOO, LLC

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

1411 Third Street, , MI

City or Town

Port Huron

State

Michigan

ZIP Code

48060

Telephone Number

2486420333

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

beetzel@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

E

Last Name

Etzel

Firm Name (if any)

Williams Williams Rattner & Plunkett PC

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

380 N. Old Woodward Ave., Ste. 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

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

BEEtzel@wwrplaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

2

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

8213 Neptune

Kalamazoo

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

49009

Taxing Authority (City or Township)

Township Of Alamo (KALAMAZOO) 

County

Kalamazoo

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.)

Yes

 

 

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:

39-01-13-476-020

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:

578900

Current Taxable Value as established by the Board of Review:

552533

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

700000

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

350000

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

350000

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

39-01-13-476-040

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:

483200

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

367664

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

500000

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

250000

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

250000

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/ Brian E. Etzel

Payment Information

Amount: 425

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051986177950

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

Neptune Kalamazoo LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001135

Township Of Alamo, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 23, 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

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

Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NEPTUNE KALAMAZOO, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 39-01-13-476-020 

Petitioner, 

 

 

 

 

 

 

 

39-01-13-476-040 

 

v. 

 

CHARTER TOWNSHIP OF ALAMO, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner NEPTUNE KALAMAZOO, LLC, by and through its attorneys, Williams 

Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner NEPTUNE KALAMAZOO, LLC, is a Michigan limited liability 

company with its registered office located at 1411 Third Street, Port Huron, MI 48060. 

2. 

Respondent Charter Township of Alamo is a Michigan township with its primary 

offices located at 7901 North 6th Street, Kalamazoo, MI 49009. 

The Subject Properties 

3. 

Petitioner owns properties identified as follows:

Page 2

Petition Page 2 

Parcel Number 

Property Address 

39-01-13-476-020 

8213 Neptune 

39-01-13-476-040 

8233 Neptune 

 

These parcels are physically contiguous to each other. They are referred to collectively in this 

Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Kalamazoo County and are within the 

Plainwell Community school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Properties. 

The 2026 Assessments 

6. 

For the 2026 tax year, Respondent classified the Subject Properties as commercial 

real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ assessments 

for property taxes in the amounts set forth in paragraph 1 of the attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties for the 2026 

tax year cannot exceed the amounts set forth in paragraph 2 of the attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in paragraph 3 of the 

attached Multiple Parcel Form. 

10. 

This Petition presents issues involving the Subject Properties’ valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”), 

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available.

Page 3

Petition Page 3 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, 

the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are 

based on the misapplication of valuation principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments are not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed 

Petitioner’s contentions of value set forth on the attached Multiple Parcel Form and granting 

Petitioner all other relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Brian E. Etzel 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 19, 2026 

 

 

Attorneys for Petitioner

Page 4

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NEPTUNE KALAMAZOO, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 39-01-13-476-020 

Petitioner, 

 

 

 

 

 

 

 

39-01-13-476-040 

 

v. 

 

CHARTER TOWNSHIP OF ALAMO, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s March 2026 

Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

39-01-13-476-020 

 1,157,800 

 578,900

Page 5

Multiple

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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

NEPTUNE KALAMAZOO, LLC

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

1411 Third Street, , MI

City or Town

Port Huron

State

Michigan

ZIP Code

48060

Telephone Number

2486420333

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

beetzel@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

E

Last Name

Etzel

Firm Name (if any)

Williams Williams Rattner & Plunkett PC

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

380 N. Old Woodward Ave., Ste. 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

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

BEEtzel@wwrplaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

2

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

8213 Neptune

Kalamazoo

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

49009

Taxing Authority (City or Township)

Township Of Alamo (KALAMAZOO) 

County

Kalamazoo

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.)

Yes

 

 

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:

39-01-13-476-020

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:

578900

Current Taxable Value as established by the Board of Review:

552533

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

700000

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

350000

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

350000

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

39-01-13-476-040

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:

483200

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

367664

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

500000

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

250000

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

250000

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/ Brian E. Etzel

Payment Information

Amount: 425

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051986177950

Supporting Waiver Documents:

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