Reign Co2 Propco LLC Petitioner Vs. City Of Kalamazoo Respondent

Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Reign CO2 Propco, LLC (by AT&T Services Inc., Tenant) 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

\ 

MTT Docket No. 26-000481 

Kalamazoo 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 06-22-125-001 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

X 

real personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? 

X Yes __ 

No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? 

X Yes No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201 Commercial-Improved 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent's 

March 

July 

December Board of Review. 

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

Page 2

MTT Docket No. 26-000481 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

14. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Kalamazoo 

County. The 

property or properties’ address is: 

133 

W Lovell Street 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): 00 City of Kalamazoo 

Petitioner's legal residence or principal office address is: 

AT&T Services, Inc., One AT&T Way, Bedminster, NJ, 07921. 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition orloss? Yes __ No 

uniformity of the property or properties’ assessment 

the property or the properties’ exemption from ad valorem taxation 

under MCL 

The tax year(s) at issue are: 2026

Page 3

MTT Docket No. 26-000481 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

The values for the property identified above as established by Respondent's 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

16562000 

8281000 

8281000 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

971200 

485600 

485600 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

16562000 

8281000 

8281000 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Petitioner requests reductions in the property's 2026 true cash and taxable values. 

The property was reassessed due to being part of a sale/leaseback financing 

transaction that was not a market transaction. 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

Petitioner contends that the 2026 true cash and taxable values significantly exceed 

the market value. 

This property was part of a sale/leaseback financing transaction 

that was not a market transaction.

Page 4

MTT Docket No. 26-000481 

Page 4 of 4 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Ted Kuch 

Email Address: ted.kuch@kroll.com 

Mailing Address: 

Telephone Number: 212.833.3211 

Date: 

9/2/2026

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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: 26-000481

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

Party Filing Document 

Petitioner

Files

Document Type: Amended Petition

Attachment File Name: ATT Kalamazoo ET Petition Prop Fillable - Amended

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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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

Reign CO2 Propco LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-000481

City Of Kalamazoo,

Respondent.

ORDER OF DEFAULT

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

Petitioner failed to file a complete petition. See TTR 233. Tribunal rules and 

information on Entire Tribunal petitions can be found on our website at 

www.michigan.gov/taxtrib. Further, although you paid a filing fee, it is not clear that the 

full required filing fee has been paid, as the petition does not provide the required 

contentions of value. As such, Petitioner must file an amended petition and pay the 

remainder of the filing fee, if any, within 14 days of the entry of this order. 

Unfortunately, the payment may not be made via e-filing. The amended petition shall 

note the docket number assigned by the Tribunal. 

Therefore,

IT IS ORDERED that Petitioner is HELD IN DEFAULT.

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

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

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

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

By: /s/ Patricia L. Halm

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

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

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

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

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

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

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

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

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

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

act, MCL 205.735a.” TTR 225(5).

Page 2

MTT Docket No. 26-000481

Page 2 of 2

Entered: August 24, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN

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 JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Reign CO2 Propco LLC,

Petitioner,

v

 

 

City Of Kalamazoo,

Respondent.

 MTT Docket No. 26-000481

Please be advised that 26-000481 has been placed on a two-week Prehearing General 

Call commencing July 01, 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. 26-000481

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 March 4, 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 March 4, 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 

March 4, 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 

July 1, 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: August 3, 2026

Page 3

MTT Docket No. 26-000481

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

Page 4

STATE OF

Page 5

MTT

Page 6

MTT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Reign CO2 Propco, LLC, 

 

 

 

Petitioner, 

 

v 

 

City of Kalamazoo, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000481 

Parcel No. 06-22-125-001 

 

 

_____________________________________________________________________________/ 

 

TED KUCH 

KROLL, LLC 

Representative for Petitioner 

285 Fulton Street, 31st Floor 

New York, New York 10007 

(212) 833-3211 

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, Michigan 48302 

(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. 

2. Respondent admits the allegations in Paragraph 2. 

3. Respondent denies the allegations in Paragraph 3 as there is only one parcel at issue. 

4. Respondent denies the allegations in Paragraph 4 as there is only one parcel at issue. 

5. Respondent neither admits nor denies the allegations from Paragraph 5 as no claim is made.

Page 2

6. Respondent admits the allegations in Paragraph 6. 

7. Respondent neither admits nor denies the allegations from Paragraph 7 as no claim is made. 

8. Respondent neither admits nor denies the allegations from Paragraph 8 as no claim is made. 

9. Respondent neither admits nor denies the allegations from Paragraph 9 as no claim is made. 

10. Respondent admits the allegations in Paragraph 10. 

11. Respondent admits the allegations in Paragraph 11. 

12. Respondent lacks the information necessary to respond to the allegations in Paragraph 12 

and leaves Petitioner to its proofs. 

13. Respondent acknowledges Petitioner’s belief that there exists a dispute relative to the 

Subject Property’s valuation but denies that Petitioner’s claims have merit and further 

denies that Petitioner is entitled to any relief. 

14. Respondent admits the allegations in Paragraph 14. 

15. Respondent neither admits nor denies the allegations from Paragraph 15 as no claim is 

made. 

16. For the 2026 tax year, Respondent established the Subject Property’s assessment for 

property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

$16,562,000 

$8,281,000 

$8,281,000 

 

17. Respondent contends that a lawful assessment of the Subject Property for the 2026 tax 

year is: 

 

True Cash Value 

Assessed Value 

Taxable Value 

$16,562,000 

$8,281,000 

$8,281,000 

18. The values in dispute for the property identified above are:

Page 3

True Cash Value 

Assessed Value 

Taxable Value 

$0 

$0 

$0 

 

19. Respondent acknowledges the relief requested by Petitioner in Paragraph 19, but denies 

that Petitioner is entitled to the requested relief due to the statements in the above 

Paragraphs. Furthermore, the assessed, state equalized and/or taxable values do not exceed 

permitted amounts, do not exceed the percentage for 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. 

20. Respondent denies the allegations in Paragraph 20 as the same are untrue. The assessed, 

state equalized and/or taxable values do not exceed permitted amounts, do not exceed the 

percentage for 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. 

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. 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Seth A. O’Loughlin____________ 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

Attorneys for Respondent 

Date: July 30, 2026

Page 4

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. 

6. 

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

applied

Page 5

9

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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. 26-000481

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: 

Seth A. O'Loughlin

/s/

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Page 1

RECEIVED 

JUL 1 02026 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

Reign CO2 Propco LLC, 

Petitioner(s), 

M 

MOAHR Docket No. 26 000481 

City of Kalamazoo 

Respondent(s). 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Ted Kuch 

states that on 7/9/2026 

he/she 

[Name of person serving/mailing petition} 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. 

Assessor (via certified mail): 

241 W South St, Kalamazoo, MI 49007 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

241 W South St, Kalamazoo, MI 49007 

3. 

County Equalization Director (via first class mail or personal service): 

201 W. Kalamazoo Ave, Room 404, Kalamazoo, Mi 49007 

4. 

County Clerk (via first class mail or personal service): 

201 W. Kalamazoo Ave, Kalamazoo, Mt 49007 

5. 

Secretary of the local school board (via first class mail or personal service): 

1220 Howard St, Kalamazoo, MI 49008 

6. 

State Treasurer (via first class mait): 

Michigan Department of Treasury, State Treasurer 

430 W. Aliegan

Page 2

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Page 1

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STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Reign CO2 Propco, LLC (by AT&T Services Inc., Tenant) 

i 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

\ 

MTT Docket No. 

Kalamazoo 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 06-22-125-001 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

X 

real personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? 

X Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? 

X Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201 Commercial-Improved 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent's 

March 

July 

December Board of Review. 

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

Page 2

MTT Docket No. 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

14. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Kalamazoo 

County. The 

property or properties’ address is: 

133 

W Lovell Street 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): 00 City of Kalamazoo 

Petitioner's legal residence or principal office address is: 

AT&T Services, Inc., One AT&T Way, Bedminster, NJ, 07921. 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition orloss? ___ Yes ___ No 

uniformity of the property or properties’ assessment 

the property or the properties’ exemption from ad valorem taxation 

under MCL 

The tax year(s) at issue are: 2026

Page 3

MTT Docket No. 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

The values for the property identified above as established by Respondent's 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

971,200 

485,600 

485,600 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

16,562,000 

8,281,000 

8,281,000 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Petitioner requests reductions in the property's 2026 true cash, and taxable values. 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

Petitioner contends that the 2026 true cash and taxable values significantly exceed 

market value.

Page 4

MTT Docket No. 

Page 4 of 4 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Ted Kuch 

Email Address: ted.kuch@kroll.com 

Mailing Address: 

Kroll, LLC, 285 Fulton Street, 31st Floor, New York, NY 10007 

Telephone Number: 212.833.3211 

Date: 4/2/2026

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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

Reign CO2 Propco LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000481

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: May 27, 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

p=, 

pe 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Reign CO2 Propco, LLC (by AT&T Services Inc., Tenant) 

i 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

\ 

MTT Docket No. 

Kalamazoo 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 06-22-125-001 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

X 

real personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? 

X Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? 

X Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201 Commercial-Improved 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent's 

March 

July 

December Board of Review. 

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

Page 2

MTT Docket No. 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

14. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Kalamazoo 

County. The 

property or properties’ address is: 

133 

W Lovell Street 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): 00 City of Kalamazoo 

Petitioner's legal residence or principal office address is: 

AT&T Services, Inc., One AT&T Way, Bedminster, NJ, 07921. 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition orloss? ___ Yes ___ No 

uniformity of the property or properties’ assessment 

the property or the properties’ exemption from ad valorem taxation 

under MCL 

The tax year(s) at issue are: 2026

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MTT Docket No. 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

The values for the property identified above as established by Respondent's 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

971,200 

485,600 

485,600 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

16,562,000 

8,281,000 

8,281,000 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Petitioner requests reductions in the property's 2026 true cash, and taxable values. 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

Petitioner contends that the 2026 true cash and taxable values significantly exceed 

market value.

Page 4

MTT Docket No. 

Page 4 of 4 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Ted Kuch 

Email Address: ted.kuch@kroll.com 

Mailing Address: 

Kroll, LLC, 285 Fulton Street, 31st Floor, New York, NY 10007 

Telephone Number: 212.833.3211 

Date: 4/2/2026

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

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

Sullivan

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

208 S Akard St

Room 1850.14

City or Town

Dallas 

State

Georgia

ZIP Code

75202

Telephone Number

314.795.7776

Fax Number

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

bs061a@att.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Edward

M.I.

James

Last Name

Kuch

Firm Name (if any)

Kroll, LLC

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

285 Fulton Street

Fl 31

City or Town

New York

State

New York

ZIP Code

10007

Telephone Number

212-833-3211

Fax Number

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

ted.kuch@kroll.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]

133 W Lovell Street

Kalamazoo

Michigan

49007

Taxing Authority (City or Township)

City Of Kalamazoo (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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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:

06-22-125-001

Classification of Property: Real 

Commercial

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

8281000

Current Taxable Value as established by the Board of Review:

8281000

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

971200

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

485600

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?

Page 3

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/ Ted Kuch

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.