Answer to Complaint Bay City Realty - 2026 Appeal(35049614.pdf
Bay City Realty LLC Petitioner Vs. City Of Bay City Respondent · 26-001188-TT
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STATE OF MICHIGAN
DEPARTMENT OF LICENSING & REGULATORY AFFAIRS
MICHIGAN TAX TRIBUNAL
____________________
Bay City Realty LLC,
Petitioner,
v
City of Bay City,
Respondent.
_____________________________________/
MTT Docket No. 26-001188
Sarah R. Belloli
101 West Big Beaver, Suite 945
Troy, Michigan 48084
Sarah.Belloli@Ryan.com
313.230.0104
Attorneys for Petitioner
Thomas M. Amon (P72351)
WARNER NORCROSS + JUDD LLP
150 Ottawa Avenue NW, Suite 1500
Grand Rapids, MI 49503
616.752.2000
Attorneys for Respondent
RESPONDENT’S ANSWER TO
PROPERTY TAX PETITION AND AFFIRMATIVE DEFENSES
City of Bay City ("Respondent"), through its attorneys, Warner Norcross + Judd LLP,
states for its Answer as follows:
1.
Admitted.
2.
Admitted.
3.
Admitted.
4.
n/a
5.
n/a
6.
Admitted.Page 2
2 7. Admitted that no protest was made to the Board of Review, and that these properties are commercial properties. 8. n/a 9. n/a 10. Admitted. 11. Admitted. 12. Admitted, upon information and belief. 13. Admitted. 14. Admitted. 15. n/a 16. Admitted. 17. All of Petitioner’s contentions are denied as untrue. 18. Admitted that this paragraph purports to show the values in dispute. 19. Admitted that Petitioner seeks the relief stated, denied as untrue that Petitioner is entitled to any such relief. 20. Denied as untrue. AFFIRMATIVE DEFENSES Respondent asserts the following Affirmative Defenses: 1. Petitioner fails to allege specific and sufficient facts to establish true cash value, assessed value and taxable value of its property. 2. Petitioner has failed to state a claim upon which relief may be granted. 3. Respondent has properly and lawfully assessed Petitioner’s property in accordance with statutory and constitutional requirements.
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3 4. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, and application of wrong principles or illegality on part of the Respondent. 5. Respondent reserves the right to add, modify, or amend these Affirmative Defenses as discovery reveals. WHEREFORE, Respondent, City of Bay City, denies that Petitioner is entitled to the relief it seeks and respectfully requests that the Petition be dismissed with prejudice, and/or that Respondent’s assessment and taxable value of the subject property be affirmed or increased, and that Respondent be granted costs and attorney fees so wrongfully sustained. WARNER NORCROSS + JUDD LLP Dated: October 21, 2026 By Thomas M. Amon (P72351) 150 Ottawa Avenue NW Grand Rapids, MI 49503 616.752.2000 Attorneys for Respondent
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4 PROOF OF SERVICE Hallie Padron states that she is an employee of Warner Norcross + Judd LLP and that on the 21st day of October, 2026, she served the Respondent’s Answer to Petition and Affirmative Defenses, Respondent’s Motion to Set Aside Default, and this Proof of Service upon Petitioner by First-Class Mail with proper postage affixed as follows: Sarah R. Belloli 101 West Big Beaver, Suite 945 Troy, Michigan 48084 /s/ Hallie Padron Hallie Padron