Respondent Answer_26-001080.pdf
Rda Holdings, LLC Petitioner Vs. City Of Dearborn Respondent · 26-001080-TT
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR RDA Holdings, LLC MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 26-001080 City of Dearborn , Respondent. ENTIRE TRIBUNAL PROPERTY TAX ANSWER 1. X__Admit ___ Deny. If 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 Petition is ___ real ___ personal. 3. ___Admit ___ Deny. If denied, identify the contiguous and non-contiguous parcels by parcel number (attach additional page if necessary): ya 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): ja 5. __ Admit_ Deny. n/a a. If denied, state when the personal property statements were filed, if at all: 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: 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. 26-001080 Page 2 of 4 7. 10. 11. 12. 13. ___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: X__Admit___ Deny. If denied, what is the applicable local governmental unit: 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): According to the City of Dearborn Assessing Department's records, the owner of record is RCA Holdings LLC, with a mailing address of 5501 North Nob Hill Road, Fort Lauderdale, FL 33351. If the property's taxable value is at issue, was there an addition or loss for purposes of establishing the property's taxable value for the tax year or years at issue? ___Yes _X No.
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MTT Docket No. 26-001080 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 page 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 page 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 2026 $5,018,400 $2,509,200 $2,371,753 17. Respondent contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 $5,018,400 $2,509,200 $2,371,753 18. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2026 0 0 0
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MTT Docket No. 26-001080 Page 4 of 4 19. 20. 21. 22. 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 maintains that the established assessed and taxable values are accurate and supported by the assessment records. 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 maintains that the subject property is properly assessed in accordance with Michigan law and that the established assessed and taxable values are accurate and supported by the City of Dearborn’s assessment records. 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): Respondent maintains that the 2026 assessed value of $2,509,200 represents 50% of the established true cash value of $5,018,400. Respondent relies upon the property record card, assessment records, and valuation methodology supporting the 2026 assessment. List affirmative defenses and the separate and specific facts upon which Respondent relies in support of those affirmative defenses (attach additional page if necessary): WHEREFORE, Respondent, City of Dearborn, asserts that the requested reduction is not supported and requests that the Tribunal deny the requested relief, affirm Respondent's 2026 assessed and taxable values, subject to county and state equalization, and grant any other appropriate relief. Signature of Respondent's Authorized Representative or, if none, Respondent: /s/ Aaron P. Powers Printed Name of Respondent's Authorized Representative or, if none, Respondent: Aaron P. Powers Email Address: MTTappeals@wcaassessing.com Mailing Address: 38110 Executive Dr. STE 200 Westland, Mi 48185 Telephone Number: (734) 331-3980 Date: October 22, 2026
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PROOF OF SERVICE The undersigned, being first duly sworn, deposes and says that she, Haley B. Johnson, placed in the United States Mail, postage prepaid, a copy of the following, properly addressed: DATE: October 22, 2026 DOCUMENT: Respondent’s Answer to Petition MTT Docket No. 26-001080 ADDRESSEE(S): Russell R. Raftary 834 Abbey Ln Milford, M1 48381 Agusta — Haley B. Tomson October 22, 2026