Reign Co2 Propco LLC Petitioner Vs. City Of Sterling Heights 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

Reign CO2 Propco LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 26-000483

City Of Sterling Heights,

Respondent.

NOTICE OF NO ACTION

TAKE NOTICE that the Tribunal has reviewed the file in the above-captioned case and 

finds that:

The Tribunal has received an Amended Petition (document). You were, however, 

required to file proof demonstrating the service of that document on the opposing party 

(proof of service) and no proof of service has been filed. As such, the document is not 

properly pending, and no action will be taken unless the required proof of service is filed 

within 14 days of the issuance of this notice. If the required proof of service is not filed 

within 14 days, you will be required to refile the document with the appropriate filing fee, 

if required, and proof that the refiled document was served on the opposing party. The 

refiled document will be considered filed as of the date of the refiling.

Entered: October 14, 2026

By: Tribunal Clerk

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

Reign CO2 Propco LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 26-000483

City Of Sterling Heights,

Respondent.

NOTICE OF NO ACTION

TAKE NOTICE that the Tribunal has reviewed the file in the above-captioned case and 

finds that:

The Tribunal has received an Amended Petition (document). You were, however, 

required to file proof demonstrating the service of that document on the opposing party 

(proof of service) and no proof of service has been filed. As such, the document is not 

properly pending, and no action will be taken unless the required proof of service is filed 

within 14 days of the issuance of this notice. If the required proof of service is not filed 

within 14 days, you will be required to refile the document with the appropriate filing fee, 

if required, and proof that the refiled document was served on the opposing party. The 

refiled document will be considered filed as of the date of the refiling.

Entered: October 14, 2026

By: Tribunal Clerk

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

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. 26-000483 

Sterling Heights 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 10-10-34-101-132 

(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. 26-000483 

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 Macomb 

County. The 

property or properties’ address is: 

34480 Van Dyke Ave 

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

local governmental unit): 

10 City of Sterling Heights 

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. 26-000483 

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 

3630400 

1815200 

1815200 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

181520 

90760 

90760 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

3630400 

1815200 

1815200 

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. 26-000483 

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: 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: 26-000483

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

Party Filing Document 

Petitioner

Files

Document Type: Amended Petition

Attachment File Name: ATT Sterling Heights ET Petition Prop fillable - Amended

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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

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

 

Petitioner, 

 

v 

 

 

 

 

 

 

Docket No. 26-000483 

 

 

 

 

 

 

 

 

 

Parcel No. 10-10-34-101-132 

CITY OF STERLING HEIGHTS, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TED KUCH 

Kroll, LLC 

Representative for Petitioner 

285 Fulton St., 31st Floor 

New York, NY 10007 

(212) 833-3211 

Ted.kuch@kroll.com 

 

MARC D. KASZUBSKI (P60333) 

O’Reilly Rancilio P.C. 

Attorney for Respondent 

12900 Hall Road, Suite 350 

Sterling Heights, MI 48313-1151 

(586) 726-1000 

mkaszubski@orlaw.com 

 

ANSWER TO PETITION 

 

Respondent, CITY OF STERLING HEIGHTS (“Respondent”), submits the following as 

its Answer to the Petition in this matter: 

1. 

Admit. 

2. 

Admit. 

3. 

Admit. 

4. 

Admit. 

5. 

No response required. 

6. 

Admit. 

7. 

No response required. 

8. 

No response required. 

9. 

No response required.

Page 2

2 

 

10. 

Admit. 

11. 

Admit. 

12. 

Neither admit nor deny as Respondent is without sufficient information upon 

which to form a belief as to the truth of the matter asserted. 

13. 

Admit. 

14. 

Admit. 

15. 

No response required. 

16. 

No response required. 

17. 

Denied as untrue. 

18. 

Denied as untrue. 

19. 

Respondent requests the Michigan Tax Tribunal deny Petitioner’s request. 

20. 

Denied as untrue. 

 

 

 

 

 

 

O’REILLY RANCILIO P.C. 

 

 

 

 

 

 

 

By: /s/ Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 Marc D. Kaszubski (P60333) 

 

 

 

 

 

 

 Attorney for Respondent 

Dated: August 28, 2026

Page 3

3 

 

RESPONDENT’S AFFIRMATIVE DEFENSES 

 

 

NOW COMES, Respondent, CITY OF STERLING HEIGHTS, by and through its 

attorneys, O’REILLY RANCILIO P.C. and states for its Affirmative Defenses as follows: 

1. 

Petitioner lacks an interest in the property or standing to bring this action. 

2. 

Lack of jurisdiction. 

3. 

Res Judicata and Collateral Estoppel. 

4. 

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

against Respondent. 

5. 

The Petition is improper because it asks this Tribunal to grant a preference by 

application of a self-chosen method of assessment contrary to the laws of the 

State of Michigan. 

6. 

The Petition is improper because its effect would be to shift the burden of the city, 

school and county taxes to other property owners within the City of Sterling 

Heights. 

7. 

Petitioner has failed to join any and all claims arising out of the same transaction 

or occurrence subject to this action. 

8. 

Respondent reserves the right to raise any additional affirmative defenses as they 

arise during the pendency of this matter. 

 

WHEREFORE, Respondent respectfully requests this Honorable Tribunal dismiss the 

Petition with prejudice and on the merits and further award Respondent any and all other relief in 

its favor as is deemed just and appropriate under the circumstances.

Page 4

4 

 

 

 

 

 

 

 

O’REILLY RANCILIO P.C. 

 

 

 

 

 

 

 

By: /s/ Marc D. Kaszubski 

 

 

 

 

 

 

 

 

 

Marc D. Kaszubski (P60333) 

 

 

 

 

 

 

 

Attorney for Respondent 

Dated: August 28, 2026 

 

 

PROOF OF SERVICE 

 

I served Respondent’s Answer to Petition and Affirmative 

Defenses upon the attorneys of record and/or parties in this case on 

August 28, 2026. I declare the foregoing statement to be true to 

the best of my information, knowledge and belief. 

 

 

 U.S. Mail 

 

 Fax 

 

 Hand Delivered 

 

 Messenger 

 

 Express Mail Private 

 Other 

 

 

 

/s/ Teresa A. Walsh 

 

 

Teresa A. Walsh

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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. 26-000483

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Sterling Heights (MACOMB)

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

Marc

M.I.

D

Last Name

Kaszubski

Firm Name (if any)

O'Reilly Rancilio P.C.

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

12900 Hall Rd., Ste. 350

City or Town

Sterling Heights

State

 Michigan

ZIP Code

48313

Telephone Number

5867261000

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

mkaszubski@orlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Marc D. Kaszubski

/s/

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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. 26-000483

City Of Sterling Heights,

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. 26-000483

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

RECEIVED 

ER 

JUL 102026 

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), 

v 

MOAHR Docket No. 26 000483 

City of Sterling Heights 

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): 

40555 Utica Rd, Sterling Heights, MI 48313 

2. 

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

40555 Utica Rd, Sterling Heights, MI 48313 

3. 

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

1 

8S Main St, Mount Clemens, MI 48043 

4. 

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

40 N Main St, Mount Clemens, Mi 48043 

5. 

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

11303 Greendale Dr, Sterling Heights, MI 48312 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan

Page 2

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Page 1

p=, 

5 

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. 

Sterling Heights 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 10-10-34-101-132 

(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 Macomb 

County. The 

property or properties’ address is: 

34480 Van Dyke Ave 

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

local governmental unit): 

10 City of Sterling Heights 

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 

1,089,120 

544,560 

544,560 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

3,630,400 

1,815,200 

1,815,200 

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: 

Le” 

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.: 26-000483

City Of Sterling Heights, 

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

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Page 1

p=, 

5 

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. 

Sterling Heights 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 10-10-34-101-132 

(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 Macomb 

County. The 

property or properties’ address is: 

34480 Van Dyke Ave 

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

local governmental unit): 

10 City of Sterling Heights 

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 

1,089,120 

544,560 

544,560 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

3,630,400 

1,815,200 

1,815,200 

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: 

Le” 

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]

34480 Van Dyke Avenue

Sterling Heights

Michigan

48312

Taxing Authority (City or Township)

City Of Sterling Heights (MACOMB)

County

Macomb

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:

10-10-34-101-132

Classification of Property: Real 

Commercial

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

1815200

Current Taxable Value as established by the Board of Review:

1815200

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

1089120

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

544560

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.