Trilogy Real Estate Kent, LLC, Petitioner Vs. Township Of Byron, Respondent

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

TRILOGY REAL ESTATE KENT LLC, 

 

 

 

Petitioner, 

 

v 

 

BYRON TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-001767 

Parcel No. 41-21-03-302-007 

 

 

_____________________________________________________________________________/ 

 

PAUL M. JONES, JR. (P82235) 

JONES PYATT LAW, LLC 

Attorney for Petitioner 

435 E. Main Street, Suite 200 

Greenwood, IN 46143 

(317) 991-1865 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-002090 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of Parcel No. 41-21-03-

302-007 - located in Kent County. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-002090 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

Page 2

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-002090) has not yet been resolved. A Prehearing Conference is scheduled for 

February 17-27, 2026, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

002090 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

002090 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

002090. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-002090.

Page 3

3

Respectfully submitted, 

JONES PYATT LAW, LLC 

 

/s/ Paul M. Jones, Jr.________________ 

PAUL M. JONES, JR. (P82235) 

Attorney for Petitioner 

435 E. Main Street, Suite 200 

Greenwood, IN 46143 

(317) 991-1865 

 

 

 

Dated: October 8, 2025 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

Dated: October 8, 2025

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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 

Trilogy Real Estate Kent LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001767 

 

Byron Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

On October 8, 2025, the parties filed a joint motion requesting that the Tribunal hold this 

case in abeyance pending resolution of Docket No. 24-002090, which is currently 

pending before the Tribunal. In the motion, the parties state that, “[w]ith the exception 

of the tax year at issue, the parties, property, and issues raised in the above captioned 

appeal are, based on the pleadings, in essence identical to those at issue in MTT 

Docket No. 24-002090 . . . .” 

 

The Tribunal has considered the motion and the case file and finds that placing this 

case in abeyance pending resolution of Docket No. 24-002090 will facilitate the efficient 

administration of justice, as that resolution may have a direct bearing on the outcome of 

the instant appeal. Therefore, 

 

IT IS ORDERED that the Joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of resolution of Docket No. 24-002090 as to the need for further proceedings in 

this matter. 

 

 

 

Entered: October 20, 2025 

 

 

By _____________________________ 

kac/jcr 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

TRILOGY REAL ESTATE KENT LLC, 

 

 

 

Petitioner, 

 

v 

 

BYRON TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-001767 

Parcel No. 41-21-03-302-007 

 

 

_____________________________________________________________________________/ 

 

PAUL M. JONES, JR. (P82235) 

JONES PYATT LAW, LLC 

Attorney for Petitioner 

435 E. Main Street, Suite 200 

Greenwood, IN 46143 

(317) 991-1865 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-002090 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of Parcel No. 41-21-03-

302-007 - located in Kent County. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-002090 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure.

Page 2

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-002090) has not yet been resolved. A Prehearing Conference is scheduled for 

February 17-27, 2026, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

002090 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

002090 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

002090. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-002090.

Page 3

3

Respectfully submitted, 

JONES PYATT LAW, LLC 

 

/s/ Paul M. Jones, Jr.________________ 

PAUL M. JONES, JR. (P82235) 

Attorney for Petitioner 

435 E. Main Street, Suite 200 

Greenwood, IN 46143 

(317) 991-1865 

 

 

 

Dated: October 8, 2025 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

 

Dated: October 8, 2025

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

TRILOGY REAL ESTATE KENT LLC, 

 

 

 

Petitioner, 

 

v 

 

BYRON TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-001767 

Parcel No. 41-21-03-302-007 

 

 

_____________________________________________________________________________/ 

 

PAUL M. JONES, JR. (P82235) 

JONES PYATT LAW, LLC 

Attorney for Petitioner 

435 E. Main Street, Suite 200 

Greenwood, IN 46143 

(317) 991-1865 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, Byron Township, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

Respondent neither admits nor denies the allegations in Paragraph 3 for the reason 

that no statement is made and, thus, no responsive pleading is required. 

 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 for the reason 

that no statement is made and, thus, no responsive pleading is required.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 6 

 

5. 

Respondent neither admits nor denies the allegations in Paragraph 5 for the reason 

that no statement is made and, thus, no responsive pleading is required. 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent neither admits nor denies the allegations in Paragraph 7 for the reason 

that no statement is made and, thus, no responsive pleading is required. 

 

8. 

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

that no statement is made and, thus, no responsive pleading is required. 

 

9. 

Respondent neither admits nor denies the allegations in Paragraph 9 for the reason 

that no statement is made and, thus, no responsive pleading is required. 

 

10. 

Respondent admits the allegations in Paragraph 10. 

 

11. 

Respondent admits the allegations in Paragraph 11. 

 

12. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 12 and, therefore, leaves Petitioner to its proofs. 

 

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. 

 

14. 

Respondent acknowledges Petitioner’s identification of the 2025 tax year as being 

at issue but denies an issue with the identified tax year. 

 

15. 

Respondent neither admits nor denies the allegations in Paragraph 15 for the 

reason that no statement is made and, thus, no responsive pleading is required. 

 

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 

$25,259,000 

$12,629,500 

$10,458,798 

 

17. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$25,259,000 

$12,629,500 

$10,458,798

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 6 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$0 

$0 

$0 

 

19. 

Respondent denies that Petitioner is entitled to the relief requested as Petitioner’s 

amounts do not reflect accurate valuations for the subject property. In further answer, the 

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

the percentage for true cash value permitted by law, were correctly determined and are based 

upon correct application of proper principles, and the values and Respondent’s mode of 

assessment are nondiscriminatory and constitutional. 

 

20. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 20 and, therefore, leaves Petitioner to its proofs. 

 

WHEREFORE, Respondent, Byron Township, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 19, 2025 

(248) 731-3089

Page 4

Entire Tribunal Property Tax Answer 

Page 4 of 6 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Byron Township, asserts the following affirmative defenses: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 

(1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

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

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

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

applied to the true cash value of Petitioner’s property, as well

Page 5

En

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001767

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Byron (KENT)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

TRILOGY REAL ESTATE KENT LLC, 

) MOAHR Docket No.: 25-001767 

) 

Petitioner, 

) Parcel No.: 41-21-03-302-007 

) 

Vv. 

) 

) 

TOWNSHIP OF BYRON, 

) 

) 

Respondent. 

) 

Paul M. Jones, Jr. 

Jones Pyatt Law, LLC 

435 East Main Street, Suite 220 

Greenwood, IN 46143 

TEL: (317) 991-1864 

E-mail: paul@jonespyattlaw.com 

Attorney No.: P82235 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

Mandy Jonte states that on August 10, 2025 she served by U.S. certified mail, return receipt 

requested, a copy of the foregoing documents relative to the above-captioned matter: Case 

Information Sheet, Entire Tribunal Property Tax Petition, Notice of Docket Number and Proof of 

Service to: 

Township of Byron 

Township of Byron 

Attn: Township Assessor 

Attn: Township Clerk 

8085 Byron Center Avenue SW 

8085 Byron Center Avenue SW 

Byron Center, MI 49315 

Byron Center, MI 49315

Page 2

Mandy Jonte states that on August 2", 2025 she served by U.S. first-class mail, a copy of the 

Petition relative to the above-captioned matter: Case Information Sheet, Entire Tribunal 

Property Tax Petition, Notice of Docket Number and Proof of Service to: 

Kent County 

Kent County 

Bureau of Equalization 

Attn: County Clerk 

Attn: Equalization Director 

300 Monroe Avenue NW 

300 Monroe Avenue NW 

Grand Rapids, MI 49503-2288 

Grand Rapids, MI 49503-2288 

Byron Center Public Schools 

Michigan Department of Treasury 

Attn: BOE Secretary 

State Treasurer 

8542 Byron Center Ave SW 

430 W Allegan St 

Byron Center, MI 49315 

Lansing, MI 48933-1592 

Dated: August) 

2025 

/s/Mandy Jonte 

Mandy Jonte 

Paralegal 

Jones Pyatt Law, LLC 

435 E Main St, Suite 220 

Greenwood, IN 46143 

mandy@jonespyattlaw.com

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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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

(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 ___real ___personal. 

 

3. 

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

contiguous? ___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? ___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 _________________________ 

 

7. 

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

to Respondent’s ___ March ___ July ___December Board of Review. 

 

 

 

 

TRILOGY REAL ESTATE KENT, LLC

BYRON TOWNSHIP

41-21-03-302-007

x

201 Commercial-Improved

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

 

8. 

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): 

 

 

 

 

 

9. 

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): 

 

 

 

 

 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

 

 

 

 

 

11. 

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

local governmental unit): ________________________________________ 

 

12. 

Petitioner’s legal residence or principal office address is: 

 

 

 

 

 

13. 

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

________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 ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

 under MCL ______ 

 

14. 

The tax year(s) at issue are: _______________________________________ 

 

 

 

 

 

 

Kent

2280 Byron View Dr SW 

Byron Center, MI 49315

Byron Township

303 N Hurstbourne Pkwy, Ste 200 

Louisville, KY 40222

x

2025

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 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

19. 

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

 

 

 

 

 

 

20. 

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

relief requested (attach additional page if necessary): 

 

 

 

 

 

 

 

2025

25,259,000

12,629,500

10,458,798

2025

9,250,000

4,625,000

4,625,000

2025

16,009,000

8,004,500

5,833,798

Reduction of TCV, SEV and AV as indicated in paragraph 17.

Comparable sales and/or income capitalization analysis. Petitioner may obtain an 

appraisal for the purpose of this appeal. Valuation evidence will be provided in 

accordance with the Tribunal's disclosure schedule.

Page 4

MTT Docket No. _________________ 

Page 4 of 4 

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

______________________________________________________________________ 

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

______________________________________________________________________ 

Email Address: _________________________________________________________ 

Mailing Address: 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________ 

Telephone Number: _____________________________________________________ 

Date: _________________________________________________________________ 

Paul M. Jones, Jr. (Attorney #P82235)

paul@jonespyattlaw.com

Jones Pyatt Law, LLC

435 E Main St, Ste 200

Greenwood, IN 46143

317.991.1865

5/28/2025

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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

Trilogy Real Estate Kent, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001767

Township Of Byron, 

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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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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

(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 ___real ___personal. 

 

3. 

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

contiguous? ___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? ___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 _________________________ 

 

7. 

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

to Respondent’s ___ March ___ July ___December Board of Review. 

 

 

 

 

TRILOGY REAL ESTATE KENT, LLC

BYRON TOWNSHIP

41-21-03-302-007

x

201 Commercial-Improved

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

 

8. 

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): 

 

 

 

 

 

9. 

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): 

 

 

 

 

 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

 

 

 

 

 

11. 

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

local governmental unit): ________________________________________ 

 

12. 

Petitioner’s legal residence or principal office address is: 

 

 

 

 

 

13. 

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

________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 ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

 under MCL ______ 

 

14. 

The tax year(s) at issue are: _______________________________________ 

 

 

 

 

 

 

Kent

2280 Byron View Dr SW 

Byron Center, MI 49315

Byron Township

303 N Hurstbourne Pkwy, Ste 200 

Louisville, KY 40222

x

2025

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 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

19. 

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

 

 

 

 

 

 

20. 

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

relief requested (attach additional page if necessary): 

 

 

 

 

 

 

 

2025

25,259,000

12,629,500

10,458,798

2025

9,250,000

4,625,000

4,625,000

2025

16,009,000

8,004,500

5,833,798

Reduction of TCV, SEV and AV as indicated in paragraph 17.

Comparable sales and/or income capitalization analysis. Petitioner may obtain an 

appraisal for the purpose of this appeal. Valuation evidence will be provided in 

accordance with the Tribunal's disclosure schedule.

Page 4

MTT Docket No. _________________ 

Page 4 of 4 

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

______________________________________________________________________ 

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

______________________________________________________________________ 

Email Address: _________________________________________________________ 

Mailing Address: 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________ 

Telephone Number: _____________________________________________________ 

Date: _________________________________________________________________ 

Paul M. Jones, Jr. (Attorney #P82235)

paul@jonespyattlaw.com

Jones Pyatt Law, LLC

435 E Main St, Ste 200

Greenwood, IN 46143

317.991.1865

5/28/2025

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

Trilogy Real Estate Kent, LLC

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

303 N Hurstbourne Parkway

Ste 200

City or Town

Louisville

State

Kentucky

ZIP Code

40222

Telephone Number

317.991.1865

Fax Number

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

paul@jonespyattlaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Paul

M.I.

M

Last Name

Jones

Firm Name (if any)

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

435 East Main St.

Suite 220

City or Town

Greenwood

State

Indiana

ZIP Code

46143

Telephone Number

317-223-5441

Fax Number

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

paul@jonespyattlaw.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]

2280 Byron View Dr SW

Byron Center

Michigan

49315

Taxing Authority (City or Township)

Township Of Byron (KENT)

County

Kent

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:

41-21-03-302-007

Classification of Property: Real 

Commercial

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

12629500

Current Taxable Value as established by the Board of Review:

10458798

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

9250000

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

4625000

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/ Paul M Jones, Jr

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