Reo Gateway, LLC Petitioner Vs. City Of Lansing 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 JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

REO Gateway, LLC,

Petitioner,

v

 

 

City Of Lansing,

Respondent.

 MTT Docket No. 26-000731

Please be advised that 26-000731 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covered by the order will not be published.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. 26-000731

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. 26-000731

Page 3 of 3

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N GRAND RIVER AVE, LANSING, MI 48906

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

PROCEDURE

REO Gateway,

Page 5

MTT

Page 6

MTT

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

NB

RECEIVED 

JUL 2 8 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

REO GATEWAY, LLC 

Petitioner 

v 

MOAHR Docket 26-000731 

Parcel No. 33-01-01-21-301-021 

CITY OF LANSING, 

Respondent 

Jennifer Hendrix, MMAO 

City Assessor 

124 W, Michigan Avenue 

3rd Floor, City Hall 

Lansing, MI 48933 

(517) 483-4136 

Jennifer .czeiszperger@lansingmi.gov 

RESPONDENT’S ANSWER TO PETITIONER'S PETITION 

AND AFFIRMATIVE DEFENSES 

RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby 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 admits the allegations in Paragraph 3.

Page 2

MTT Docket # 26-000731 

7. 

9. 

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

in Paragraph 7. 

The mailing address on record is 503 Mall Ct, Suite 312, Lansing, MI 

48912. 

. 

Respondent neither admits nor denies the allegations in Paragraph 8 for reason that they 

do not have sufficient knowledge to for a belief as to the truth of the allegations, and 

[eaving Petitioner to their strictest proofs. 

Respondent admits the allegations in Paragraph 9. 

10. The 2026 values for the property identified above as established by Respondent's Board 

11. 

of Review are: 

Parcel Number 

True Cash Value | Assessed Value 

Taxable Value 

33-01-01-21-203-021 | $8,208,600 

$4,104,300 

$4,104,300 

Respondent contends that the 2026 values for the propeity identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-21-203-021 | $8,208,600 

$4,104,300 

$4,104,300 

12. The 2026 values in dispute for the property identified above ate: 

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

33-01-01-21-203-021 | 

$0 

$0 

$0 

13. Respondent acknowledges Petitioner's beliefs as to the issues in this appeal but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief. 

Further, the subject property did not have any “additions” or “losses” for the 2026 tax 

year. 

14. Respondent denies the allegations in Paragraph 14 for the reason that it is untrue, In further 

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

amounts, do not exceed the percentage of true cash value permitted by law, were correctly 

determined and are based upon correct application of proper principles, and the values and 

Respondent’s mode of assessment are constitutional. Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year.

Page 3

MTT Docket # 26-000731 

OFFICE OF THE CITY ASSESSOR 

fo 34 OF LANSING 

ate 

Tul 

/5 AOR 

bred: _SU415,28 

ud once ay 

Jennifer Hendix, MMAO 

City Assessor, City of Lansing 

31d Floor, City Hall 

124 W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov

Page 4

MTT Docket # 26-000731 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the 

following affirmative defenses: 

A. 

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

against the Respondent and to support Petitioner’s claim for relief. 

B. 

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). 

C. 

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). 

B. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

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

its agents. 

C. 

Petitioner fails to allege the mode and method of assessing the subject property 

failed to conform to the mode and method applied in the case of all properties within the 

Respondent's taxing unit for the tax year in questions. 

D. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

E. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject property, as equalized, is at a level other than 50% and it also 

fails to allege specific and sufficient facts to support its allegations that the subject property’s

Page 5

MTT Docket ff 26-000731 

G. 

Petitioner asks this Tribunal to grant it illegal preference by application of a method 

of assessment different from that utilized in the assessment of other properties in the Respondent’s 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitioner, in essence, secks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

I 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

J. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

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

K. 

Respondent reserves the right to add affirmative defenses which may become 

known during the course of informal or formal discovery proceedings. 

WHEREFORE, Respondent denies that the Petitioner 

is entitled 

to any relief and 

respectfully requests that the Respondent’s assessed and taxable values for the year under appeal 

be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be 

granted all attorney fees and cost wrongfully sustained. 

OFFICE OF THE CITY ASSESSOR 

CITY OF LANSING

Page 6

WON

Page 7

CI

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Page 1

RECEIVED 

JUL 18 2026 

MICHIGA 

i 

STATE OF MICHIGAN 

N TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

REO GATEWAY, LLC 

Petitioner 

v 

MOAHR Docket 26-000731 

Parcel No. 33-01-01-21-301-021 

CITY OF LANSING, 

Respondent 

Jennifer Hendrix, MMAO 

City Assessor 

124 W., Michigan Avenue 

3rd Floor, City Hall 

Lansing, MI 48933 

(517) 483-4136 

Jennifer,czeiszperger@lansingmi.gov 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

AND AFFIRMATIVE DEFENSES 

RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds 

to the allegations made in Petitioners Petition as follows: 

— 

Respondent admits the allegations in Paragraph 1. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

MTT Docket # 26-000731 

7. 

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

in Paragraph 7. 

The mailing address on record is 503 Mall Ct, Suite 312, Lansing, MI 

48912. 

8. 

Respondent neither admits nor denies the allegations in Paragraph 8 for reason that they 

do not have sufficient knowledge to for a belief as to the truth of the allegations, and 

leaving Petitioner to their strictest proofs. 

9. 

Respondent admits the allegations in Paragraph 9. 

10. The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

True Cash Value | Assessed Value 

Taxable Value 

33-01-01-21-203-021 | $8,208,600 

$4,104,300 

$4,104,300 

11. Respondent contends that the 2026 values for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-21-203-021 | $8,208,600 

$4,104,300 

$4,104,300 

12. The 2026 values in dispute for the property identified above are: 

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

33-01-01-21-203-021 

: 

$0 

$0 

$0 

13. Respondent acknowledges Petitionet’s beliefs as to the issues in this appeal but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief. 

Further, the subject property did not have any “additions” or “losses” for the 2026 tax 

year. 

14, Respondent denies the allegations in Paragraph 14 for the reason that it is untrue. In further 

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

amounts, do not exceed the percentage of true cash value permitted by law, were correctly 

determined and are based upon correct application of proper principles, and the values and 

Respondent’s mode of assessment are constitutional, Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year.

Page 3

MTT Docket # 26-000731 

Dated: | 8/2 

OFFICE OF THE CITY ASSESSOR 

CITY OF LANSING 

Condon Wiudae xy 

Jennifer Hendrix, MMAO 

’ 

City Assessor, City of Lansing 

3d Floor, City Hall 

124 W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer czeiszperger@lansingmi.gov

Page 4

MTT Docket # 26-000731 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the 

following affirmative defenses: 

A. 

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

against the Respondent and to support Petitioner’s claim for relief, 

B. 

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). 

C. 

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). 

B. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

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

its agents. 

C. 

Petitioner fails to allege the mode and method of assessing the subject property 

failed 

to conform to the mode and method applied 

in the case of all properties within the 

Respondent’s taxing unit for the tax year in questions, 

D. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

E. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject property, as equalized, is at a level other than 50% and it also 

fails to allege specific and sufficient facts to support its allegations that the subject property’s

Page 5

MTT Docket # 26-000731 

G. 

Petitioner asks this Tribunal to grant it illegal preference by application of a method 

of assessment different from that utilized in the assessment of other properties in the Respondent's 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

L 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden, 

J. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

propetty 

and 

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

K. 

Respondent reserves the right to add affirmative defenses which may become 

known during the course of informal or formal discovery proceedings. 

WHEREFORE, Respondent denies that the Petitioner 

is entitled 

to any relief and 

respectfully requests that the Respondent’s assessed and taxable values for the year under appeal 

be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be 

granted all attorney fees and cost wrongfully sustained. 

OFFICE OF THE CITY ASSESSOR 

ee 

CITY OF LANSING 

Dated:

Page 6

RECEI

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

_______________________________________________ 

 

REO GATEWAY, LLC 

 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000731 

CITY OF LANSING, 

 

 

 

Respondent. 

 

______________________________/ 

 

 

Michael F. Matheson (P52997) 

Matheson Law Firm 

Attorneys for Petitioner 

200 Woodland Pass, Suite F 

East Lansing, MI 48823 

(517) 993-6699 

 

______________________________/ 

 

PROOF OF SERVICE – ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

I declare that on the 23rd day of June 2026, I served a copy of the Entire Tribunal 

Property Tax Petition, with docket number, upon: 

 

Chris Swope 

City of Lansing Clerk 

124 W Michigan Avenue, 9th Floor 

Lansing, MI 48933 

 

Jennifer Czeiszperger 

City of Lansing Assessor 

124 W Michigan Avenue, 3rd Floor 

Lansing, MI 48933 

by depositing same in a United States Mail receptacle, certified mail, return receipt 

requested, with postage fully prepaid thereon and addressed to the same as above, and 

upon: 

 

 

 

 

Cirea Strode 

Secretary of School Board 

Lansing Public Schools 

519 West Kalamazoo Street 

Lansing, MI 48933 

 

 

 

 

State Treasurer 

Michigan Department of Treasury 

430 W Allegan St. 

Lansing, MI 48922

Page 2

2 

 

Rosemary Anger, Director 

Ingham County Equalization 

P.O. Box 319, Courthouse 

Mason, MI 48854 

 

Barb Byrum, Ingham County Clerk 

341 S Jefferson St 

Mason, MI 48854 

 

by depositing same in a United States Mail receptacle, with postage fully prepaid thereon 

and addressed to the same as above. 

 

 

/s/ Michael F. Matheson 

 

 

Michael F. Matheson (P52997)

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000731

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: 260623 POS - Petition

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 

_______________________________________________ 

 

REO GATEWAY, LLC 

 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-_______ 

CITY OF LANSING, 

 

 

 

Respondent. 

 

______________________________/ 

 

 

Michael F. Matheson (P52997) 

Matheson Law Firm 

Attorneys for Petitioner 

200 Woodland Pass, Suite F 

East Lansing, MI 48823 

(517) 993-6699 

 

 

______________________________/ 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: 33-01-01-21-203-021. 

 

2. 

The property identified above is X real __ personal. 

 

3. 

The property identified above is classified as Commercial-Improved. 

 

4. 

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

Respondent’s 

X 

 March 

 July 

 December 

Board 

of 

Review. 

 

5. 

The property at issue is located in Ingham County. The property address is: 825 S. 

Washington, Lansing, MI 48933. 

 

6. 

The assessment at issue was established by the (applicable local governmental 

unit): City of Lansing.

Page 2

MTT Docket No. 26-______ 

Entire Tribunal Property Tax Petition 

Page 2 of 3 

 

 

 

 

7. 

Petitioner’s legal residence or principal office address is: 503 Mall Ct, Suite 312, 

Lansing, MI 48912. 

 

8. 

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

XX 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 or loss? 

 Yes X 

 No 

___ 

uniformity of the property or properties’ assessment 

___ 

the property or the properties’ exemption from ad valorem taxation 

under MCL ______ 

 

9. 

The tax year(s) at issue are: 2026. 

 

10. 

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 

$8,208,600 

$4,104,300 

$4,104,300 

 

11. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$6,200,000 

$3,100,000 

$3,100,000 

 

12. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$2,008,600 

$1,004,300 

$1,004,300 

 

13. 

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

Determine the correct true cash value and lawfully assess the property in 

accordance with Michigan law. Petitioner further requests its costs, interest and 

reasonable attorney fees. 

 

 

14. 

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

requested (attach additional page if necessary):

Page 3

MTT Docket No. 26-______ 

Entire Tribunal Property Tax Petition 

Page 3 of 3 

 

 

 

 

 

The assessment by Respondent of the subject project is arbitrary and 

discriminatory, based on the wrong principles, and otherwise unlawful as being 

contrary to the General Property Tax Act and Tax Tribunal Act for the following 

reasons: 

 

a. 

Respondent has failed to identify the nature of the property being assessed; 

 

b. 

The subject property is assessed in an amount greater than 50% of its true 

cash value; 

 

c. 

Respondent did not assess the subject property taking into account the 

accepted methods of determining true cash value; 

 

d. 

The subject property is subject to restrictions, and said restrictions severely 

restrict the market value of the project. However, the restrictions were not 

taken into account by Respondent in making the assessment, even though 

Respondent was clearly required to do so, pursuant to Michigan law; and 

 

e. 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection and due process of law. 

 

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

 

 

/s/ Michael F. Matheson 

 

 

Michael F. Matheson (P52997) 

 

Address: 

Matheson Law Firm 

 

 

 

 

 

200 Woodland Pass, Suite F 

 

 

 

 

 

 

 

 

 

East Lansing, MI 48823 

 

 

Email Address: michael@mathesonlawfirm.com 

 

 

 

 

 

 

Telephone Number: (517) 993-6699 

Date: May 6, 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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

REO Gateway, LLC

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

503 Mall Ct

Suite 312

City or Town

Lansing

State

Michigan

ZIP Code

48912

Telephone Number

517-993-6699

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

michael@mathesonlawfirm.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Michael

M.I.

Last Name

Matheson

Firm Name (if any)

Matheson Law Firm

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

200 Woodland Pass

Suite F

City or Town

East Lansing

State

22

ZIP Code

48823

Telephone Number

5179936699

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

michael@mathesonlawfirm.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

825 S Washington

Lansing

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

48933

Taxing Authority (City or Township)

City Of Lansing (INGHAM) 

County

Ingham

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.)

N/A

 

 

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:

33-01-01-21-203-021

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:

4104300

Current Taxable Value as established by the Board of Review:

4104300

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

6200000

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

3100000

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

3100000

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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/ Michael Matheson

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26050684199437

Supporting Waiver Documents:

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

REO Gateway, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000731

City Of Lansing, 

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: June 10, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 2

Michael F Matheson

Matheson Law Firm

200 Woodland Pass Suite F

East Lansing , MI 48823

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 

_______________________________________________ 

 

REO GATEWAY, LLC 

 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-_______ 

CITY OF LANSING, 

 

 

 

Respondent. 

 

______________________________/ 

 

 

Michael F. Matheson (P52997) 

Matheson Law Firm 

Attorneys for Petitioner 

200 Woodland Pass, Suite F 

East Lansing, MI 48823 

(517) 993-6699 

 

 

______________________________/ 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: 33-01-01-21-203-021. 

 

2. 

The property identified above is X real __ personal. 

 

3. 

The property identified above is classified as Commercial-Improved. 

 

4. 

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

Respondent’s 

X 

 March 

 July 

 December 

Board 

of 

Review. 

 

5. 

The property at issue is located in Ingham County. The property address is: 825 S. 

Washington, Lansing, MI 48933. 

 

6. 

The assessment at issue was established by the (applicable local governmental 

unit): City of Lansing.

Page 2

MTT Docket No. 26-______ 

Entire Tribunal Property Tax Petition 

Page 2 of 3 

 

 

 

 

7. 

Petitioner’s legal residence or principal office address is: 503 Mall Ct, Suite 312, 

Lansing, MI 48912. 

 

8. 

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

XX 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 or loss? 

 Yes X 

 No 

___ 

uniformity of the property or properties’ assessment 

___ 

the property or the properties’ exemption from ad valorem taxation 

under MCL ______ 

 

9. 

The tax year(s) at issue are: 2026. 

 

10. 

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 

$8,208,600 

$4,104,300 

$4,104,300 

 

11. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$6,200,000 

$3,100,000 

$3,100,000 

 

12. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$2,008,600 

$1,004,300 

$1,004,300 

 

13. 

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

Determine the correct true cash value and lawfully assess the property in 

accordance with Michigan law. Petitioner further requests its costs, interest and 

reasonable attorney fees. 

 

 

14. 

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

requested (attach additional page if necessary):

Page 3

MTT Docket No. 26-______ 

Entire Tribunal Property Tax Petition 

Page 3 of 3 

 

 

 

 

 

The assessment by Respondent of the subject project is arbitrary and 

discriminatory, based on the wrong principles, and otherwise unlawful as being 

contrary to the General Property Tax Act and Tax Tribunal Act for the following 

reasons: 

 

a. 

Respondent has failed to identify the nature of the property being assessed; 

 

b. 

The subject property is assessed in an amount greater than 50% of its true 

cash value; 

 

c. 

Respondent did not assess the subject property taking into account the 

accepted methods of determining true cash value; 

 

d. 

The subject property is subject to restrictions, and said restrictions severely 

restrict the market value of the project. However, the restrictions were not 

taken into account by Respondent in making the assessment, even though 

Respondent was clearly required to do so, pursuant to Michigan law; and 

 

e. 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection and due process of law. 

 

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

 

 

/s/ Michael F. Matheson 

 

 

Michael F. Matheson (P52997) 

 

Address: 

Matheson Law Firm 

 

 

 

 

 

200 Woodland Pass, Suite F 

 

 

 

 

 

 

 

 

 

East Lansing, MI 48823 

 

 

Email Address: michael@mathesonlawfirm.com 

 

 

 

 

 

 

Telephone Number: (517) 993-6699 

Date: May 6, 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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

REO Gateway, LLC

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

503 Mall Ct

Suite 312

City or Town

Lansing

State

Michigan

ZIP Code

48912

Telephone Number

517-993-6699

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

michael@mathesonlawfirm.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Michael

M.I.

Last Name

Matheson

Firm Name (if any)

Matheson Law Firm

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

200 Woodland Pass

Suite F

City or Town

East Lansing

State

22

ZIP Code

48823

Telephone Number

5179936699

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

michael@mathesonlawfirm.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

825 S Washington

Lansing

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

48933

Taxing Authority (City or Township)

City Of Lansing (INGHAM) 

County

Ingham

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.)

N/A

 

 

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:

33-01-01-21-203-021

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:

4104300

Current Taxable Value as established by the Board of Review:

4104300

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

6200000

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

3100000

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

3100000

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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/ Michael Matheson

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26050684199437

Supporting Waiver Documents:

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.