Answer Plymouth572026.pdf
Plymouth United Church Of Christ, Petitioner Vs. City Of Detroit, Respondent · 26-000048-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL PLYMOUTH UNITED CHURCH OF CHRIST , Petitioner, v CITY OF DETROIT, Docket No. 26-00048 -TT Respondent Parcel No. 03001350 03001349 ____________________________________________________________________________/ ANSWER TO AMENDED PETITION and AFFIRMATIVE DEFENSES Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer to the Petition filed in this matter states the following: 1. JURISDICTIONAL BASIS 1. Respondent, City of Detroit, admits as true. 2. Respondent admits as true. 3. Respondent neither admits nor denies and leaves Petitioner to its proofs. 4. Respondent admits as true. 2. Nature of Appeal ( LIMITED) Respondent neither admits nor denies and leaves Petitioner to its proofs. 3. Subject Property Information .
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2 Respondent admits that the subject property information is listed, but neither admits nor denies that the properties are contiguous and leaves Petitioner to its proofs. Respondent admits that the Property parcels are listed correctly. Respondent admits that the values listed by Respondent’s Board of Review are accurate Respondent denies as untrue Petitioner’s contention for the 2025 property values. Respondent leaves Petitioner to its proofs as to the relief requested. 4. Issues Presented COUNT I- Improper Denial of Non-Profit Exemption 1. Respondent, City of Detroit, admits the allegations in the corresponding paragraph as true. 2. Respondent denies as untrue. 3. Respondent neither admits nor denies and leaves Petitioner to its proofs. Respondent objects to Petitioner’s request for reinstatement of exempt status for tax year 2025. COUNT II- Improper Use of “Clerical Error /Mutual Mistake “Authority 1. Respondent denies as untrue. 2. Respondent denies as untrue. 3. Respondent denies as untrue. 4. Respondent denies as untrue. Respondent requests denial of Petitioner’s reversal of the BOR “correction.” COUNT III - Lack of Statutory Qualified Error
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3 1. Respondent admits that this is a statutory requirement but denies that the BOR acted in violation of the statute. 2. Respondent neither admits nor denies and leaves Petitioner to its proofs. 3. Respondent neither admits nor denies and leaves Petitioner to its proofs. 5. Relief Requested Respondent requests that the Tribunal dismiss this Appeals and award fees and cost 6. Related Circuit Court Case 1. Respondent admits that the Wayne County Circuit Court Case No. 25-015101-CB is pending, but the Court has scheduled the Defendant, City of Detroit Motion for Summary Disposition for April 15,2026. 2. Respondent admits as true. 3. Respondent admits as true and further avers that exclusive jurisdiction is before the Tribunal. 4. Respondent admits as true. CONCLUSION and REQUEST FOR RELIEF Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: May 7, 2026 /s/Mary Beth Cobbs By: Mary Beth Cobbs ( P40080) Kevin C. Richard ( P 43417) Attorneys for Respondent City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226
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4 AFFIRMATIVE DEFENSES NOW COMES Respondent, City of Detroit, and asserts the following Affirmative Defenses to the Petitioner’s claims: 1. Petitioner’s lacks standing and/or capacity to bring forth this Petition. 2. Petitioner’s claims may be barred by the applicable statute of limitations. 3. This Tribunal lacks subject matter jurisdiction. 4. Petitioner has failed to state a claim upon which relief can be granted. Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: May 7, 2026 /s/Mary Beth Cobbs By: Mary Beth Cobbs ( P40080) Kevin C. Richard ( P 43417) Attorneys for Respondent City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226 313.237.3075 cobbm@detroitmi.gov
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5 PROOF OF SERVICE On May 7, 2026, I mailed by first class mail a copy of Respondent’s Answer to: Darwyn P. Fair Law, PLLC Darwyn P. Fair 535 Griswold, Suite 111-554 Detroit, MI 48226 I declare that the above statement is true to the best of my information, knowledge, and belief. Dated: May 7, 2026 /s/Mary Beth Cobbs Mary Beth Cobbs ( P40080) City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226