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25-002166.pdf

Tjs Flint, LLC, Petitioner Vs. Township Of Flint, Respondent · 25-002166-TT

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Page 1

RECEIVED 

, 

JUL 09 2025 

MIC 

SUPERVISOR 

Rost IGAN TAX TRIBUNAL 

KARYN MILLER 

BARB VERT 

CLERK 

1490 S. Dye Road 

) PEAR DALL. 

MANYA TRIPLETT 

Flint, Michigan 48532 

CAR 

- 

TREASURER 

TOM KLEE 

LISA R. ANDERSON 

DEBBE CAMPBELL 

July 2,2025 

Office of the Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

MTT Docket No.: 25-002166 

TIS Flint LLC v Township of Flint 

Parcels: 07-27-100-025 

Dear Honorable Michigan Tax Tribunal: 

Enclosed for filing, please find Respondent’s Reply to Petitioner’s Petition (in the Entire 

Tribunal) and Respondent’s Proof of Service. 

Re 

ctfully submitted, 

ada 

JOD red — 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint LLC 

MTT Docket No.: 25-002166 

Petitioner 

Parcel 

07-27-100-025 

AY 

Flint Township, Genesee County 

Respondent 

Honigman LLP 

Paula Dotson 

Stewart L. Mandell 

Deputy Assessor, Charter Township of Flint 

39400 Woodward Avenue, Suite 101 

1490 S. Dye Road 

Bloomfield Hills, MI 48304-5151 

Flint, MI 48532 

313.465.7420 

810.600.3227 

RESPONDENT’S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2025 

ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) 

Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy 

Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 

I. 

Respondent acknowledges 

that 

parcel 

07-27-100-025 

identified 

in paragraph 

1 

of 

Petitioner’s Petition will be the subject of Petitioner’s appeal 

as to the remainder of the 

statements, Respondent neither admits nor denies for the reason Respondent is without 

sufficient knowledge to form a belief as to the truth and leaves Petitioner to meeting its 

required burden of proof. 

2. 

Respondent admits the statements set forth in paragraph 2 of Petitioner’s Petition. 

3. 

Respondent admits the statements set forth in paragraph 3 of Petitioners Petition. 

4. 

Respondent admits the subject property is classified as commercial real; as to the remainder 

of the statements, Respondent neither admits nor denies for the reason Respondent 

is 

without sufficient knowledge to form a belief as to the truth and leaves Petitioner to

Page 3

MTT Docket 25-002166 

7 

Respondent admits the statements and or allegations set forth in paragraph 7 of Petitioner’s 

Petition. 

8. 

Respondent denies the statements and or allegations set forth in paragraph 8 of Petitioner’s 

Petition because they are untrue. 

Respondent leaves Petitioner to meeting its required 

burden of proof. 

WHEREFORE, Respondent, Charter Township of Flint, denies that Petitioner is entitled to the 

relief it seeks and respectfully requests that the Respondent’s assessed value and taxable value of 

the subject property be affirmed and that the Honorable Tribunal dismiss the Petition with 

prejudice. 

Respondent’s Response submitted on this date, 

July 2, 2025, by: 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TJS Flint LLC 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

MTT DOCKET NO.: 25-002166 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

GENESEE COUNTY) 

THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on 

July 2, 2025, she caused to be served upon: 

Honigman LLP 

Michigan Tax Tribunal 

Stewart L. Mandell 

PO Box 30232 

39400 Woodward Avenue, Suite 101 

Lansing, Michigan 48909 

Bloomfield Hills, MI 48304-5151 

by enclosing the same in an envelope, plainly addressed to said party at the above address, with 

lawful United States first class postage affixed thereon and by placing same in the United States 

mail. 

py 2 

’ 

: 

July 2, 2025 

Date 

Paula Dotson 

Deputy Assessor

Page 5

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