Answer to Petition (Ferndale Avenue Shoppes) (10.06.2026).pdf
Ferndale Avenue Shoppes Petitioner Vs. City Of Ferndale Respondent · 26-001387-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS SYSTEM AND RULES MICHIGAN TAX TRIBUNAL Ferndale Avenue Shoppes, Petitioner, v CITY OF FERNDALE, Respondent. MTT Docket No. 26-001387 Parcel No. 24-25-27-352-027 _____________________________________________________________________________/ Laura M. Hallahan (P42101) Representative for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com P. DANIEL CHRIST (P45080) HAFELI STARAN & CHRIST, P.C. Attorney for Respondent 2055 Orchard Lake Road Sylvan Lake, MI 48320-1746 (248) 731-3085 (248) 227-5421 (cell) dchrist@hsc-law.com _____________________________________________________________________________/ ANSWER TO PETITION Respondent City of Ferndale, through its City Attorney, P. Daniel Christ, responds to the allegations made in the Petition, as follows: 1. Admitted. 2. No response required because no allegations are set forth. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted.
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2 7. Respondent acknowledges Petitioner contends this appeal involves issues related to the subject property’s true cash and taxable values but Respondents true case and taxable values for the subject property are valid. 8. Admitted. 9. Respondent acknowledges Respondent’s Board of Review established values and Petitioner’s value contentions and the values in dispute set forth in Petitioner’s attachment. 10. Respondent denies the allegations contained in Paragraph 10, as Respondent’s assessed, state equalized and taxable values and the corresponding taxes are valid. (a) Respondent denies the allegations contained in subparagraph (a), as Respondent submits the assessed, state equalized and taxable values do not exceed permitted amounts. (b) Respondent denies the allegations contained in subparagraph (b), as Respondent’s assessed, state equalized and taxable values do not exceed the percentage of true cash value permitted by law. (c) Respondent denies the allegations contained in subparagraph (c), as Respondent’s assessed, state equalized and taxable values were correctly determined and are based upon proper application of proper principles. (d) Respondent denies the allegations contained in subparagraph (d), as Respondent’s assessed, taxable and state equalized values are non-discriminatory and conform to uniformity, equal protection and due process requirements. (e) Taxable values of parcels 24-25-27-352-025 and 24-25-27-352-007 were not unlawfully uncapped.
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3 WHEREFORE, Respondent City of Ferndale requests the Tribunal to dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. /s/P. Daniel Christ P. DANIEL CHRIST (P45080) HAFELI STARAN & CHRIST, P.C. Attorneys for Respondent 2055 Orchard Lake Road Sylvan Lake, MI 48320 (248) 731-3085 Dated: October 6, 2026 PROOF OF SERVICE On the date below, I sent by email a copy of the foregoing Answer to Petition to: Laura M. Hallahan (P42101) Representative for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 lhallahan@hallahanlaw.com I declare that the statement above is true to the best of my information, knowledge, and belief. /s/P. Daniel Christ P. Daniel Christ Dated: October 6, 2026