Full record / Kurt Ivory and Kate Ivory 26-000631 Answer to Petition 6-11-26.pdf

Kurt Ivory and Kate Ivory 26-000631 Answer to Petition 6-11-26.pdf

Kurt Ivory, Katy Ivory Petitioners Vs. City Of Bloomfield Hills Respondent · 26-000631-TT

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S E C R E S T W A R D L E 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

KURT IVORY AND KATE IVORY, 

 

 

Petitioner, 

MTT Docket No. 26-000631 

 

-vs- 

 

 

 

 

 

 

 

CITY OF BLOOMFIELD HILLS, 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Richard E. Rassel (P57540) 

Attorney for Petitioner 

380 N. Old Woodward, Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

rer@wwrplaw.com 

SECREST WARDLE 

Alana E. Knox (P85859) 

Attorney for Respondent 

2600 Troy Center Drive 

P.O. Box 5025 

Troy, MI 48007-5025 

(248) 851-9500 

aknox@secrestwardle.com 

_________________________________________________________________________________/ 

 

RESPONDENT’S ANSWER TO PETITIONER’S 

PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) 

 

 

NOW COMES Respondent, CITY OF BLOOMFIELD HILLS, by and through its attorneys, 

SECREST WARDLE, and for its Answer to Petitioner’s Property Tax Petition (Entire Tribunal, 2026 

Tax Year), states as follows: 

 

1. 

Answering paragraph 1, Respondent admits that Kurt and Kate Ivory are parties in 

interest with respect to the property taxes on the parcel of property having tax identification number 

12-19-15-126-005, also identified as 1895 Rathmor, Bloomfield Hills, Michigan 48304. Respondent 

neither admits nor denies the remainder of the allegations contained in paragraph 1 for lack of 

sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs.

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S E C R E S T W A R D L E 

2. 

Answering paragraph 2, Respondent admits that the City of Bloomfield Hills assesses 

and collects taxes on the subject property. Respondent neither admits nor denies the remainder of the 

allegations contained in paragraph 2 for lack of sufficient knowledge or information upon which to 

form a belief and leaves Petitioners to their proofs. 

3. 

Answering paragraph 3, Respondent admits that the subject property having tax 

identification number 12-19-15-126-005 is classified as 401 Residential Improved and is vacant. 

Respondent neither admits nor denies the remainder of the allegations contained in paragraph 3 for 

lack of sufficient knowledge or information upon which to form a belief and leaves Petitioners to their 

proofs. 

4. 

Answering paragraph 4, Respondent admits that the subject property having tax 

identification number 12-19-15-126-005 is located in Oakland County and the City of Bloomfield 

Hills School District. Respondent neither admits nor denies the remainder of the allegations contained 

in paragraph 4 for lack of sufficient knowledge or information upon which to form a belief and leaves 

Petitioner to their proofs. 

5. 

Answering paragraph 5, Respondent admits the same. 

6. 

Answering paragraph 6, Respondent admits that the subject property’s 2026 true cash, 

assessed value and taxable value on the Respondent’s assessment roll are as follows: 

 

which assessed value will result in a state equalized value in the same amount based upon the tentative 

equalization factor. Respondent neither admits nor denies the remainder of the allegations contained 

in paragraph 6 for lack of sufficient knowledge or information upon which to form a belief and leaves 

Petitioner to its proofs. 

PARCEL NUMBER 

TRUE CASH 

VALUE 

ASSESSED 

VALUE 

TAXABLE 

 VALUE 

12-19-15-126-005

$ 1,837,960

$ 918,980

$ 918,980

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S E C R E S T W A R D L E 

. 

7. 

Answering paragraph 7, Respondent denies that the subject property’s 2026 true cash, 

state equalized and taxable values were no higher than: 

PARCEL NUMBER

TRUE CASH VALUE 

STATE EQUALIZED 

VALUE 

TAXABLE 

VALUE 

12-19-15-126-005 

$ 1,000,000 

$ 500,000 

$ 500,000 

 

Respondent neither admits nor denies the remainder of the allegations contained in paragraph 7 for 

lack of sufficient knowledge or information upon which to form a belief and leaves Petitioners to its 

proofs. 

8. 

Answering paragraph 8, Respondent neither admits nor denies the allegations 

contained in paragraph 8 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioners to its proofs. 

9. 

Answering paragraph 9, Respondent admits that Petitioners protested the 2026 values 

at the Bloomfield Hills Board of Review and that the Board of Review affirmed the assessed and 

taxable values. Respondent neither admits nor denies the remainder of the allegations contained in 

paragraph 9 for lack of sufficient knowledge or information upon which to form a belief and leaves 

Petitioners to its proofs. 

10. 

Answering paragraph 10, Respondent neither admits nor denies the allegations 

contained in paragraph 10 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioners to its proofs. 

 WHEREFORE, Respondent, CITY OF BLOOMFIELD HILLS, denies that Petitioner is 

entitled to the relief it seeks and respectfully requests that the Respondent’s assessed and taxable 

values of the subject property be affirmed or increased, that Petitioner’s Property Tax Petition (Entire

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S E C R E S T W A R D L E 

Tribunal, 2026 Tax Year) be dismissed with prejudice and that Respondent be granted costs and 

attorney fees so wrongfully incurred. 

 

 

 

 

 

 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

BY: 

 /s/ Alana E. Knox 

 

 

 

 ALANA E. KNOX (P85859) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

2600 Troy Center Drive, P.O. Box 5025 

 

 

 

 

 

 

Troy, Michigan 48007-5025 

Dated: June 11, 2026 

 

 

(248) 851-9500 

 

 

AFFIRMATIVE DEFENSES 

 

 

For its further Answer to Petitioner’s Property Tax Petition (Entire Tribunal, 2026 Tax Year) 

and by way of its Affirmative Defenses, Respondent respectfully requests unto this Honorable 

Tribunal as follows: 

 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

 

2. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, application of wrong principles or illegality on the part of the Respondent. 

 

3. 

Petitioner fails to allege that the mode and method of appraising its property failed to 

conform with the mode and method applied in the case of all of the properties in the Respondent’s 

taxing unit for the year in question. 

 

4. 

Petitioner fails to allege specific and sufficient facts to establish the true cash value, 

assessed value and taxable value of its property.

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S E C R E S T W A R D L E 

 

5. 

Petitioner fails to allege specific and sufficient facts to support its allegation that the 

assessed value of its property, as equalized, is at a factor other than 50% and also fails to allege 

specific and sufficient facts to support its allegations that the property’s taxable value is improper. 

 

6. 

Petitioner fails to show that any rate other than 50% after equalization was applied to 

the true cash value of its property, as well as to the properties of all others to arrive at the respective 

equalized assessments. 

 

7. 

Petitioner, in essence, asks that this Honorable Tribunal grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in the Respondent’s taxing unit. 

 

8. 

Petitioner, in essence, seeks by Petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

 

9. 

Petitioner failed to allege to the Board of Review that: 

A. 

The equalized assessment of the property is more than 50% of its 

true cash value and that the taxable value is in violation of 

applicable statutory and constitutional limitations. 

 

B. 

The property is assessed in a discriminatory manner and that the 

assessment is a higher level of true cash value than the average 

level of assessment of all other property within the City, 

excepting this property and the assessment on other property 

which is also under appeal. 

 

C. 

The assessment and taxable value are unlawful and based upon 

the application of wrong principles and thereby operate as a 

constructive fraud upon the taxpayer. 

 

The failure to raise such objections to the Respondent’s Board of Review constitutes a failure to 

exhaust the administrative remedies provided for by the General Property Tax Act, constitutes a 

waiver of any such allegations contained in the Petition, and further amounts to a failure by the 

Petitioner to appear in protest to Respondent’s Board of review as required by the Tax Tribunal Act.

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S E C R E S T W A R D L E 

 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and established its 

taxable value in accordance with statutory and constitutional requirements. 

 

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

 

13. 

Respondent reserves the right to add to these Affirmative Defenses any new 

Affirmative Defenses that discovery reveals. 

 

WHEREFORE, Respondent, CITY OF BLOOMFIELD HILLS, denies that Petitioner is 

entitled to the relief it seeks and respectfully requests that the Respondent’s assessment and taxable 

value of the subject property be affirmed or increased and that Petitioner’s Property Tax Petition 

(Entire Tribunal, 2026 Tax Year) be dismissed with prejudice and that Respondent be granted costs 

and attorney fees so wrongfully incurred. 

 

 

 

 

 

 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

BY: 

 /s/ Alana E. Knox 

 

 

 

 ALANA E. KNOX (P85859) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

2600 Troy Center Drive, P.O. Box 5025 

 

 

 

 

 

 

Troy, Michigan 48007-5025 

Dated: June 11, 2026 

 

 

(248) 851-9500

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S E C R E S T W A R D L E 

PROOF OF SERVICE 

 

I hereby certify that on June 11, 2026, a copy of the foregoing document, Respondent’s 

Answer to Petitioner’s Property Tax Petition, was filed electronically with the Michigan Tax Tribunal, 

and was served upon: 

 

Williams, Williams, Rattner & Plunkett, P.C. 

Richard E. Rassel, Esq. 

380 N. Old Woodward, Suite 300 

Birmingham, MI 48009 

by depositing same in the United States mail with postage fully prepaid thereon. 

/s/ Tamera Briggs 

 

Tamera Briggs 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(10784261.1)

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