NCO Parking, LCC MTT# 25-002805 answer.pdf

Nco Parking LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002805-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

NCO PARKING, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 25-002805 

 

CITY OF DETROIT, 

 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

2. Respondent admits. 

3. Respondent admits. 

4. Respondent admits. 

5. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

involving valuation, assessment, and uniformity, however, Respondent denies that any 

such allegations have merit. 

6. Respondent admits. 

7. Respondent denies as untrue. 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

1. Petitioner’s claims are barred by the applicable statute of limitations.

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2. Petitioner has failed to state a claim for which relief may be granted. 

3. Petitioner lacks standing. 

4. This Tribunal lacks subject matter jurisdiction. 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

(313) 237-3061 

Dated: July 23, 2025

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