Answer to Petition - Dicastal v Greenville (2026) - 9.25.26.pdf
Dicastal North America, Inc. Petitioner Vs. City Of Greenville Respondent, Michigan Department Of Treasury Intervening Respondent · 26-000570-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL DICASTAL NORTH AMERICA, INC., Petitioner, v MTT Docket No. 26-000570-TT CITY OF GREENVILLE, Respondent, and THE MICHIGAN DEPARTMENT OF TREASURY, Intervenor-Respondent. _____________________________________________________________________________/ Christian E. Meyer (P56037) Warner Norcross & Judd Attorney for Petitioner 150 Ottawa NW, Suite 1500 Grand Rapids, MI 49503 (616)752-2423 cmeyer@wnj.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 B. Thomas Golden (P70822) Adam M. Roose (P68893) Jessica L. Rundle (P83788) Assistant Attorneys General Revenue and Tax Division Attorneys for Intervenor-Respondent P.O. Box 30754 Lansing, MI 48909 (517) 335-7584 goldent2@michigan.gov roosea2@michigan.gov rundlej1@michigan.gov _____________________________________________________________________________/ INTERVENOR-RESPONDENT MICHIGAN DEPARTMENT OF TREASURY’S ANSWER TO PETITION
Page 2
2 The Michigan Department of Treasury (Treasury), through its counsel, Assistant Attorneys General B. Thomas Golden, Adam M. Roose, and Jessica L. Rundle, states for its Response to the Petition as follows: 1. Treasury admits the allegations in paragraph 1. 2. Treasury admits the allegations in paragraph 2. 3. Treasury admits the allegations in paragraph 3. 4. No answer is required as no claims are made. 5. No answer is required as no claims are made. 6. Treasury admits that Petitioner has identified the classification of the subject parcels in paragraph 6, as identified on Multiple Parcel Petition paragraph 1. 7. No answer is required as no claims are made. 8. Treasury neither admits nor denies the allegations of paragraph 8 because the statute cited by Petitioner speaks for itself. 9. No answer is required as no claims are made. 10. Treasury admits the allegations in paragraph 10. 11. Treasury admits the allegations in paragraph 11. 12. Treasury neither admits nor denies the allegations of paragraph 12 because Treasury lacks knowledge or information sufficient to form a belief as to the truth of the matter asserted and leaves Petitioner to its proofs. 13. Treasury admits the allegations in paragraph 13.
Page 3
3 14. Treasury admits the allegations in paragraph 14. 15. No answer is required as no claims are made. 16. Treasury admits the allegations of paragraph 16, as identified on Multiple Parcel Petition Form paragraph 2. 17. Treasury admits that Petitioner has identified its value contentions in paragraph 17, as identified on Multiple Parcel Petition Form paragraph 3, but denies that its value contentions are supported by fact or law. 18. Treasury admits that Petitioner has identified the values in dispute in paragraph 18, as identified on Multiple Parcel Petition Form paragraph 4. 19. Treasury neither admits nor denies the allegations of paragraph 19, as no response is required. 20. Treasury neither admits nor denies the allegations of paragraph 20 because Treasury lacks knowledge or information sufficient to form a belief as to the truth of the matter asserted and leaves Petitioner to its proofs. 21. Treasury denies the allegations in paragraph 21 as untrue. 22. Treasury denies the allegations in paragraph 22 as untrue. 23. Treasury neither admits nor denies the allegations of paragraph 19, as no response is required.
Page 4
4 In response to the Multiple Parcel Petition Form, Treasury: 1. Treasury admits the allegations in paragraph 1. 2. Treasury admits the allegations in paragraph 2. 3. Treasury admits that Petitioner has stated its value contentions in paragraph 3 but denies that its value contentions are supported by fact or law. 4. Treasury admits that the difference in values listed in paragraph 4 accurately reflect the difference between the values listed in paragraphs 2 and 3. WHEREFORE, proposed Intervenor-Respondent Michigan Department of Treasury asks that this Tribunal deny Petitioner’s requested relief, affirm the assessments as lawfully determined by the City of Greenville and its assessor, and grant Respondents such other relief as this Tribunal deems appropriate. AFFIRMATIVE DEFENSES Intervenor-Respondent, Michigan Department of Treasury, asserts the following affirmative defenses: 1. Petitioner has failed to show that any factor other than fifty percent (50%) was applied to the true cash value of Petitioner’s property, or any other relevant property or properties in the class and fails to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper, discriminatory, or lacks uniformity, or that there was any “loss” for the tax year at issue.
Page 5
5 2. Treasury incorporates by reference Respondent City of Greenville’s affirmative defenses as set forth in its answer to the petition. 3. Respondent City of Greenville has properly and lawfully assessed Petitioner’s property and established its taxable value in accordance with statutory and constitutional requirements. 4. Petitioner has failed to meet its burden of proof establishing the true cash value of the properties at issue in this matter. 5. Treasury reserves the right to raise additional affirmative defenses as the same may become known during the course of these proceedings. Respectfully Submitted, /s/ B. Thomas Golden B. Thomas Golden (P70822) Adam M. Roose (P68893) Jessica L. Rundle (P83788) Assistant Attorneys General Revenue and Tax Division Attorneys for Intervenor-Respondent P.O. Box 30754 Lansing, MI 48909 (517) 335-7584 goldent2@michigan.gov roosea2@michigan.gov rundlej1@michigan.gov Dated: September 25, 2026