Tmt Lansing LLC, Petitioner Vs. City Of Lansing, Respondent
- Petitioner
- Tmt Lansing LLC
- Respondent
- City Of Lansing
Case overview
- Docket number
- 25-001768-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Ingham
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 10 | Consent Judgment | Not recorded | Not recorded | 11/18/2025 | Not recorded | Download |
| 9 | Granted | PET | 8 | 11/18/2025 | Not recorded | Download |
| 8 | A Stipulation has been received. | PET | Not recorded | 11/18/2025 | $50.00 | Download |
| 7 | Answer was received | RESP | Not recorded | 09/04/2025 | Not recorded | Download |
| 6 | Appearance | PET | Not recorded | 09/17/2025 | Not recorded | Download |
| 5 | Proof of service of petition was received. | PET | Not recorded | 08/01/2025 | Not recorded | Download |
| 4 | Petition has been verified | PET | 2 | 07/23/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 07/23/2025 | Not recorded | Download |
| 2 | A petition was received. | PET | Not recorded | 05/29/2025 | Not recorded | Download |
| 1 | ET Case Info Sheet | Not recorded | Not recorded | 05/29/2025 | $425.00 | Download |
Documents
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Page 1
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 TMT Lansing LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001768 City of Lansing, Presiding Judge Respondent. Jason C. Grinnell ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT The Tribunal has reviewed the Stipulation and finds that it comports with the mandates of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise indicated. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax years at issue shall correct or cause the assessment rolls to be corrected to reflect the property’s true cash and taxable values as provided in this Consent Judgment within 20 days of the entry of the Consent Judgment.2 IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund as required by the Consent Judgment within 28 days of the entry of the Consent Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a proportionate share of any property tax administration fees paid and of penalty and interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless otherwise indicated, bear interest from the date of payment to the date of judgment and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 1 See MCL 211.27a. 2 See MCL 205.755.
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MTT Docket No. 25-001768 Page 2 of 2 (ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 9.47%, and (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%. This Consent Judgment resolves all pending claims in this matter and closes this case. See docket look up for a copy of stipulation and for any possible refund paragraph. By _______________________________ Entered: November 18, 2025 gc 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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62819850.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TMT Lansing, LLC, Petitioner, v MTT Docket No. 25-001768 City of Lansing, Respondent. _____________________________/ Stipulation for Entry of Consent Judgment 1. The parcel is located in Ingham County. 2. The case is pending in the X Entire Tribunal OR __ Small Claims Division. 3. Property Parcel No: See Attachment A for multiple parcel numbers. 4. The values for the property identified above as established by Respondent’s Board of Review are: See Attachment A. 5. The values for the property were increased by the assessor after Respondent’s Board of Review as explained in the letter dated October 14, 2025, attached as Attachment B. 6. The values for the property identified above as stipulated by the parties for settlement purposes are: See Attachment A. 7. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years: Not applicable. 8. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc.: IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable to TMT Lansing, LLC and mailed to 3400 Belle Chase Way, Lansing, MI 48911-4251.
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MTT Docket No. 25-001768 Stipulation for Entry of Consent Judgment 2 62819850.1 Honigman LLP City of Lansing Attorneys for Petitioner Representatives for Respondent By: /s/ Jackie J. Cook____________ By: /s/ Jennifer Czeiszperger Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com Jennifer Czeiszperger, MMAO City Assessor 124 W. Michigan Ave., 3rd Floor Lansing, MI 48933 (517) 483-7624 jennifer.czeiszperger@lansingmi.gov Dated: November 18, 2025 Dated: November 18, 2025
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MTT Docket No. 25-001768 Stipulation for Entry of Consent Judgment 3 62819850.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TMT Lansing, LLC, Petitioner, v MTT Docket No. 25-001768 City of Lansing, Respondent. _____________________________/ Attachment A to Stipulation for Entry of Consent Judgment: Multiple Parcels 1. Tax Year 2025 values adopted by the March Board of Review: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-05-03-377-002 $1,260,800 $630,400 $411,443 2025 33-01-05-03-377-013 $586,600 $293,300 $205,521 $1,847,400 $923,700 $616,964 2. Tax Year 2025 values increased per letters from the City Assessor’s office dated October 14, 2025 (Attachment B): Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-05-03-377-002 $1,260,800 $630,400 $538,444 2025 33-01-05-03-377-013 $586,600 $293,300 $220,743 $1,847,400 $923,700 $759,187 3. Tax Year 2025 values stipulated to by the parties: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-05-03-377-002 $871,200 $435,600 $435,600 2025 33-01-05-03-377-013 $586,600 $293,300 $220,743 $1,457,800 $728,900 $656,343
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MTT Docket No. 25-001768 Stipulation for Entry of Consent Judgment 4 62819850.1 Attachment B
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Jennifer Czeiszperger, Assessor 3rd Floor City Hall CITY ASSESSORS OFFICE 124 West Michigan Avenue Lansing, Michigan 48933 (517) 483-7624 mute Andy Schor, Mayor October 14, 2025 TMT - Lansing C/O PW Parent LLC 1 Glenlake Parkway NE Atlanta GA 30328 RE:33-01-05-03-377-013 1200 Keystone, Lansing, Ml Our records indicate that the above property was transferred during 2021. As provided by State Statute the Taxable Value (TV) of a property must be the same as its State Equalized Value (SEV) in the year following an ownership transfer (section 211.27a (3) of the Michigan Compiled Laws). This is referred to as "uncapping" Taxable Value. You are hereby notified that the Taxable Value (TV) of this property will be "uncapped" for 2022. This change will be reflected on the assessment and tax rolls as follows: Tax Year 2022 Taxable Value From: $180,810 To: $194,200 $1,072 Tax Year 2023 Taxable Value From: $189,850 0 $203,910 $1,126 Tax Year 2024 Taxable Value From: $199,342 To: $214,106 $1,182 Tax Year 2025 Taxable Value From: $205,521 To: $220,743 $1,231 This change in taxable value will increase your adjusted tax bill by approximately: $4,610 The Ingham Country Treasurer will be sending adjusted tax bills to cover any additional taxes owed for prior years. The current year taxes will be adjusted by the Lansing City Treasurer. If you wish to appeal this "uncapping" of the Taxable Value, you must file an appeal to the Michigan Tax Tribunal (MTT) within 35 days of this notice. If you elect to proceed with an appeal to the MTT, you must File a small Claims Petition Form, which is available at www.michigan.gov/taxtrib. The MTT will then send you a Notice of Docket Number. If you have any questions regarding these procedures or the uncapping of the property, feel free to contact Jennifer Czeiszperger 517-483-7624. Respectfully yours,
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62819850.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TMT Lansing, LLC, Petitioner, v MTT Docket No. 25-001768 City of Lansing, Respondent. _____________________________/ Stipulation for Entry of Consent Judgment 1. The parcel is located in Ingham County. 2. The case is pending in the X Entire Tribunal OR __ Small Claims Division. 3. Property Parcel No: See Attachment A for multiple parcel numbers. 4. The values for the property identified above as established by Respondent’s Board of Review are: See Attachment A. 5. The values for the property were increased by the assessor after Respondent’s Board of Review as explained in the letter dated October 14, 2025, attached as Attachment B. 6. The values for the property identified above as stipulated by the parties for settlement purposes are: See Attachment A. 7. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years: Not applicable. 8. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc.: IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be made payable to TMT Lansing, LLC and mailed to 3400 Belle Chase Way, Lansing, MI 48911-4251.
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MTT Docket No. 25-001768 Stipulation for Entry of Consent Judgment 2 62819850.1 Honigman LLP City of Lansing Attorneys for Petitioner Representatives for Respondent By: /s/ Jackie J. Cook____________ By: /s/ Jennifer Czeiszperger Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com Jennifer Czeiszperger, MMAO City Assessor 124 W. Michigan Ave., 3rd Floor Lansing, MI 48933 (517) 483-7624 jennifer.czeiszperger@lansingmi.gov Dated: November 18, 2025 Dated: November 18, 2025
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MTT Docket No. 25-001768 Stipulation for Entry of Consent Judgment 3 62819850.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TMT Lansing, LLC, Petitioner, v MTT Docket No. 25-001768 City of Lansing, Respondent. _____________________________/ Attachment A to Stipulation for Entry of Consent Judgment: Multiple Parcels 1. Tax Year 2025 values adopted by the March Board of Review: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-05-03-377-002 $1,260,800 $630,400 $411,443 2025 33-01-05-03-377-013 $586,600 $293,300 $205,521 $1,847,400 $923,700 $616,964 2. Tax Year 2025 values increased per letters from the City Assessor’s office dated October 14, 2025 (Attachment B): Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-05-03-377-002 $1,260,800 $630,400 $538,444 2025 33-01-05-03-377-013 $586,600 $293,300 $220,743 $1,847,400 $923,700 $759,187 3. Tax Year 2025 values stipulated to by the parties: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2025 33-01-05-03-377-002 $871,200 $435,600 $435,600 2025 33-01-05-03-377-013 $586,600 $293,300 $220,743 $1,457,800 $728,900 $656,343
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MTT Docket No. 25-001768 Stipulation for Entry of Consent Judgment 4 62819850.1 Attachment B
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Jennifer Czeiszperger, Assessor 3rd Floor City Hall CITY ASSESSORS OFFICE 124 West Michigan Avenue Lansing, Michigan 48933 (517) 483-7624 mute Andy Schor, Mayor October 14, 2025 TMT - Lansing C/O PW Parent LLC 1 Glenlake Parkway NE Atlanta GA 30328 RE:33-01-05-03-377-013 1200 Keystone, Lansing, Ml Our records indicate that the above property was transferred during 2021. As provided by State Statute the Taxable Value (TV) of a property must be the same as its State Equalized Value (SEV) in the year following an ownership transfer (section 211.27a (3) of the Michigan Compiled Laws). This is referred to as "uncapping" Taxable Value. You are hereby notified that the Taxable Value (TV) of this property will be "uncapped" for 2022. This change will be reflected on the assessment and tax rolls as follows: Tax Year 2022 Taxable Value From: $180,810 To: $194,200 $1,072 Tax Year 2023 Taxable Value From: $189,850 0 $203,910 $1,126 Tax Year 2024 Taxable Value From: $199,342 To: $214,106 $1,182 Tax Year 2025 Taxable Value From: $205,521 To: $220,743 $1,231 This change in taxable value will increase your adjusted tax bill by approximately: $4,610 The Ingham Country Treasurer will be sending adjusted tax bills to cover any additional taxes owed for prior years. The current year taxes will be adjusted by the Lansing City Treasurer. If you wish to appeal this "uncapping" of the Taxable Value, you must file an appeal to the Michigan Tax Tribunal (MTT) within 35 days of this notice. If you elect to proceed with an appeal to the MTT, you must File a small Claims Petition Form, which is available at www.michigan.gov/taxtrib. The MTT will then send you a Notice of Docket Number. If you have any questions regarding these procedures or the uncapping of the property, feel free to contact Jennifer Czeiszperger 517-483-7624. Respectfully yours,
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AD RECEIVED SEP 0 4 2025 MICHIGAN TAX TRIBUNAL STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC , MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 25-001768 City of Lansing , Respondent. ENTIRE TRIBUNAL PROPERTY TAX ANSWER 1. X__Admit___Deny. Hf denied, state the parcel number for the property identified on the Entire Tribunal Property Tax Petition for the tax year or years at issue: (If more than one parcel is at issue, attach a completed Multiple Parcel Answer Form addressing all other parcels at issue.) 2. X__Admit Deny. If denied, the property identified on the Entire Tribunal Property Tax Petitionis ___real ___ personal. 3. X__Admit ___Deny. [f denied, identify the contiguous and non-contiguous parcels by parcel number (attach additional page if necessary): 4, ___Admit __ Deny. If denied, identify the parcel or parcels of personal property that are not located on a parcel of real property under appeal by parcel number (attach additional page if necessary): 5. NA Admit ____Deny. a. If denied, state when the personal property statements were filed, if at all: REAL PROPERTY APPEAL b. On what date did the March Board of Review commence: 6. X__Admit ___Deny. If denied, state the classification of the property identified on the Entire Tribunal Property Tax Petition for the tax year or years at issue:
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MTT Docket No. 25-001768 Page 2 of 4 7. 10. 11. 12. NA Admit ___Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional page if necessary): N/A Admit Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): N/A Admit Deny Neither Admit Nor Deny. If denied, state the facts upon which Respondent relies in support of the denial (attach additional page if necessary): N/A X __Admit___ Deny. If denied, in what County are the property or properties located in and what is the address of the property or properties: 1200 KEYSTONE AVE, LANSING MI 48911 X__Admit ___ Deny. If denied, what is the applicable local governmental unit: Admit Deny X__ Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional page if necessary): MAILING ADDRESS ON RECORD: 3400 BELLE CHASE WAY, LANSING MI 48911-4251
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MTT Docket No. 26-001768 Page 3 of 4 14. X Admit Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): 15. Admit Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): N/A 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 2025 (377-013) 586,600 293,300 203,300 2025 (377-002) 1,260,800 630,400 630,400 17. Respondent contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 (377-013) |586,600 293,300 293,300 2025 (377-002) |1,260,800 630,400 630,400 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 (377-013) [0 0 0 2025 (377-002) [0 0 0
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MTT Docket No. 25-001768 Page 4 of 4 19. Admit X Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional page if necessary): 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 2025 tax year. 20. Admit X Deny Neither Admit Nor Deny. If denied, list the separate facts upon which Respondent relies in support of the denial (attach additional age if necessary): Respondent denies the allegations 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. 21. List any separate and specific facts upon which Respondent relies to support every ground on which Respondent relies and also has the burden of proof (attach additional page if necessary): SEE ATTACHED AFFIRMATIVE DEFENSE 22. List affirmative defenses and the separate and specific facts upon which Respondent relies in support of those affirmative defenses (attach additional age if necessary): SEE ATTACHED AFFIRMATIVE DEFENSE SE Respohdent’s Authorized Representative or, if none, Respondent: [\N CA MOA 1A Q0 AL 2 hl h\) \ J Printed Name of Respondent's Authorized Representative or, if none, Respondent: Jennifer Czeiszperger, MMAO Email Address: jennifer.czeiszperger@lansingmi.gov Mailing Address:
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL TMT LANSING LLC Petitioner v MOAHR Docket 25-001768 Parcel No. 33-01-05-03-377-002 & 33-01-05-03-377-013 CITY OF LANSING, Respondent Jennifer Czeiszperger, MMAO City Assessor 124 W. Michigan Avenue 3rd Floor, City Hall Lansing, MI 48933 (517) 483-4136 Jennifer.czeiszperger@lansingmi.gov RESPONDENT’S AFFIRMATIVE DEFENSES AFFIRMATIVE DEFENSES PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the following affirmative defenses:
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FRE! AJ RECEIVED 60. SEP 17 2075 STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TMT Lansing LLC, Petitioner, v MTT Docket No. 25-001768 City of Lansing, Respondent. Jackie J. Cook (P68781) Jennifer Czeiszperger, MMAO Honigman LLP City of Lansing Attorneys for Petitioner Representative for Respondent 39400 Woodward Avenue, Suite 101 14 W Michigan Ave, 3" Floor Bloomfield Hills, MI 48304 Lansing, M1 48933 (248) 566-8474 (517) 483-4136 jcook@honigman.com jennifer.czeiszperger(@lansingmi.gov Ted Kuch Kroll, LLC Former Representative for Petitioner 285 Fulton Street, 31% Floor New York, NY 10007 (212) 833-3211 ted. kuch@kroll.com Stipulated Substitution of Petitioner’s Representative Petitioner hereby gives notice that Jackie J. Cook of the law firm Honigman LLP, will be representing Petitioner going forward. Kroll, LLC (“Kroll”) hereby withdraws as Petitioner’s representative in this matter. Please serve all pleadings, orders, notices, and other documents upon Jackie J. Cook at the
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Kroll, LLC, Former Representative for Petitioner By/s/ Ted Kuch Ted Kuch 285 Fulton Street, 31% Floor New York, NY 10007 (212) 833-3211 ted kuch@kroll.com Dated: September 17, 2025 Honigman LLP, Attorneys for Petitioner By./s/ Jackie J. Cook Jackie J. Cook (P68781) 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8474 jcook@honigman.com Dated: September 17, 2025
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RECEIVED SEP 17 2025 MICHIGAN TAX TRIBUNAL STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TMT Lansing LLC, Petitioner, v MTT Docket No. 25-001768 City of Lansing, Respondent. Jackie J. Cook (P68781) Jennifer Czeiszperger, MMAO Honigman LLP City of Lansing Attorneys for Petitioner Representative for Respondent 39400 Woodward Avenue, Suite 101 14 W Michigan Ave, 3" Floor Bloomfield Hills, M1 48304 Lansing, MI 48933 (248) 566-8474 (517) 483-4136 jcook@honigman.com jennifer.czeiszperger@lansingmi.gov Ted Kuch Kroll, LLC Former Representative for Petitioner 285 Fulton Street, 31% Floor New York, NY 10007 (212) 833-3211 ted.kuch@kroll.com Proof of Service Lisa Joseph hereby affirms that on September 17, 2025, via electronic mail, she served a copy of the Stipulated Substitution of Petitioner’s Representative upon: Ted Kuch Jennifer Czeiszperger, MMAO Kroll, LLC City of Lansing Former Representative for Petitioner Representative for Respondent ted.kuch@kroll.com jennifer.czeiszperger@lansingmi.gov
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RECEIVED AUG 01 2025 PMICHIGAN TAX TRIBUNAL STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No.25-001768 City of Lansing i 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 June 6, 2025 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): City Assessor, Jennifer Czeiszperger, 124 W Michigan Ave., 3rd Floor, Lansing, Mi 48933 2. City Clerk or Township Supervisor/Clerk (via certified mail): City Clerk, Chris Swope, 124 W Michigan Ave., 9th Floor, Lansing, MI 48933 3. County Equalization Director (via first class mail or personal service): Equalization Director, Rosemary Anger, Ingham County Department of Equalization & Tax Mapping, P.O. Box 319, Courthouse, Mason, Ml 48854 4. County Clerk (via first class mail or personal service): Ingham County Clerk, Barb Byrum, P.O. Box 179, Mason, MI 48854 5. Secretary of the local school board (via first class mail or personal service): Schoolboard Secretary, Dr. Deyanira Nevarez Martinez, Board of Education, 519 West Kalamazoo St., Lansing, MI 48933 6. State Treasurer (via first class mail): Michigan Department of Treasury, State Treasurer 430 W. Allegan
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Kroll LLC Ted Kuch One World Trade Center 285 Fulton Street, 31% Floor New York, NY, 10007 I 9589 0710 5270 1717 3947 yg Michigan Tax Tribunal 611 W. Ottawa St. Lansing, MI, 48933 B= [42] FIRST-CLASS $00
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) \' MTT Docket No. City of Lansing , Respondent(s) ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 33-01-05-03-377-013; 33-01-05-03-377-002 (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 201Commercial-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
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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 Ingham County. The property or properties’ address is: 1200 Keystone Ave, Lansing, MI 48911 The assessment or assessments at issue were established by the (applicable local governmental unit): 33 City of Lansing - Ingham Petitioner’s legal residence or principal office address is: ServiceMaster Brands, 1 Glenlake Parkway NE, Suite 1400, Atlanta, GA 30328 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 or loss? ___ Yes X 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: 2025
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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 2025 175,980 87,990 61,656 2025 378,240 189,120 123,432 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 586,600 293,300 205,521 2025 1,260,800 630,400 411,443 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner requests reductions in the properties’ 2025 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 2025 true cash and taxable values signficantly exceed market value.
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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 1007 Telephone Number: 212.833.3211 Date: 5/29/25
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a “a, Gad STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC MICHIGAN TAX TRIBUNAL Petitioner, \ MTT Docket No. City of Lansing , Respondent. MULTIPLE PARCEL PETITION FORM 1 OF 1 1. The classification of the property identified herein as established by Respondent's Board of Review is: Tax Year Parcel Number Real/Personal Classification 2. The values for the property identified herein as established by Respondent's Board of Review are: Tax Year | Parcel Number | True Cash Value | Assessed Value | Taxable Value 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
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MTT Docket No.
Page 2 of 2
3.
Petitioner contends that the values for the property identified herein are:
Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value
2025
33-01-05-03-377-013
{175,980
87,990
61,656
2025
33-01-05-03-377-002
(378,240
189,120
123,432
4.
The values in dispute for the property identified herein are:
Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value
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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 TMT Lansing LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 25-001768 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: July 23, 2025 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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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC , MICHIGAN TAX TRIBUNAL Petitioner(s) \' MTT Docket No. City of Lansing , Respondent(s) ENTIRE TRIBUNAL PROPERTY TAX PETITION 1. Property Parcel No: 33-01-05-03-377-013; 33-01-05-03-377-002 (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 201Commercial-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
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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 Ingham County. The property or properties’ address is: 1200 Keystone Ave, Lansing, MI 48911 The assessment or assessments at issue were established by the (applicable local governmental unit): 33 City of Lansing - Ingham Petitioner’s legal residence or principal office address is: ServiceMaster Brands, 1 Glenlake Parkway NE, Suite 1400, Atlanta, GA 30328 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 or loss? ___ Yes X 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: 2025
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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 2025 175,980 87,990 61,656 2025 378,240 189,120 123,432 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 586,600 293,300 205,521 2025 1,260,800 630,400 411,443 19. Petitioner requests the following relief (attach additional page if necessary): Petitioner requests reductions in the properties’ 2025 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 2025 true cash and taxable values signficantly exceed market value.
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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 1007 Telephone Number: 212.833.3211 Date: 5/29/25
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a “a, Gad STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR TMT-Lansing LLC MICHIGAN TAX TRIBUNAL Petitioner, \ MTT Docket No. City of Lansing , Respondent. MULTIPLE PARCEL PETITION FORM 1 OF 1 1. The classification of the property identified herein as established by Respondent's Board of Review is: Tax Year Parcel Number Real/Personal Classification 2. The values for the property identified herein as established by Respondent's Board of Review are: Tax Year | Parcel Number | True Cash Value | Assessed Value | Taxable Value 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
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MTT Docket No.
Page 2 of 2
3.
Petitioner contends that the values for the property identified herein are:
Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value
2025
33-01-05-03-377-013
{175,980
87,990
61,656
2025
33-01-05-03-377-002
(378,240
189,120
123,432
4.
The values in dispute for the property identified herein are:
Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value
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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 Ulm Home Address (No., Street, P.O. Box or Rural Route) 1 Glenlake Parkway NE Suite 1400 City or Town Atlanta State Georgia ZIP Code 30328 Telephone Number 404.882.4631 Fax Number E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) kevin.ulm@servicemaster.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?2 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 1200 Keystone Avenue Lansing Michigan 48911 Taxing Authority (City or Township) City Of Lansing (INGHAM) County Ingham If you are appealing more than one parcel, are they contiguous or adjoining? Yes (*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)
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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: 33-01-05-03-377-013 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 293300 Current Taxable Value as established by the Board of Review: 205521 What do you believe is the fair market value (also known as True Cash Value)? 175980 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 87990 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 61656 Parcel Number: 33-01-05-03-377-002 Classification of Property: Real Commercial Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 630400 Current Taxable Value as established by the Board of Review: 411443 What do you believe is the fair market value (also known as True Cash Value)? 378240 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 189120 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 123432 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:
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR 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? 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
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