Respondent's Answer to Petition and Aff Defenses signed 26-0012662.pdf
The Flag Living - Jonna, LLC; Rac Ryan, LLC; Rac Greenfield 10, LLC, Et Al Petitioner Vs. City Of Troy Respondent · 26-001262-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL The Flag Living- Jonna, LLC; RAC Ryan, LLC: RAC Greenfield 10, LLC The Flag Living- Stare, LLC, Petitioner, City of Troy, Respondent. MTT Docket: 26-001262 Parcel ID 88-20-08-451-013 LAURA M. HALLAHAN (P42101) HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner 1750 S. Telegraph Road Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 LHallahan@Hallahanlaw.com LORI GRIGG BLUHM (P46908) TROY CITY ATTORNEY'S OFFICE Attorney for Respondent 500 W. Big Beaver Road Troy, Ml 48084 (248) 524-3320 BluhmLG@TroyMI.gov RESPONDENT’S ANSWER TO PETITION NOW COMES, Respondent, CITY OF TROY, by and through its attorney, Lori Grigg Bluhm, and for its Answer to Petitioner's Petition, states as follows: 1. As to Paragraph 1, Respondent admits. 2. As to Paragraph 2, Respondent admits that Petitioner did not file with the City of Troy Board of Review.
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5. As to Paragraph 5, Respondent neither admits nor denies, and leaves Petitioner to its proofs. 6. As to Paragraph 6, Respondent admits that Petitioner is challenging the subject property's true cash and taxable values, but denies that there is support for the challenge. 7. As to paragraph 7, Respondent admits. 8. As to Paragraph 8, Respondent admits that Petitioner has accurately set forth Respondent's true cash value and state equalized value, but denies that Petitioner has accurately set forth the taxable value of the subject property, which is $7,368,720. 9. As to Paragraph 9, Respondent denies that the Petitioner's alleged values for the subject property are accurate and/or have any support for its contention. 10. As to Paragraph 10, Respondent does not contest Petitioner's calculations as to the true cash value differences and state equalized value differences, but denies that Petitioner's alleged values for the subject property are accurate and/or have any support for its contention. Respondent also avers that the difference between the taxable value figures is $693,720. 11. As to Paragraph 11, Respondent denies that the taxes imposed are invalid or unlawful, and denies that any reduction to the assessment for the Subject Property is appropriate, since the allegations are untrue. WHEREFORE, Respondent, CITY OF TROY, requests the Tribunal dismiss the Petition, affirm or increase Respondent's assessed and taxable values, subject to county and
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AFFIRMATIVE DEFENSES For its further Answer to Petitioner's Petition, Respondent relies on the following Affirmative Defenses: 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 or its agents. 3. Petitioner fails to allege specific and sufficient facts to establish the true cash value, assessed value, and taxable value of its property. 4. Petitioner fails to allege specific and sufficient facts to support its allegations that the property's taxable value is improper, or failed to conform with the mode and method applied in the case of all properties in the City of Troy for 2026. 5. 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. 6. Respondent has properly and lawfully assessed Petitioner's property and established its taxable value in accordance with statutory and constitutional requirements. 7. Respondent reserves the right to argue additional Affirmative Defenses during the pendency of this action.
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Dated: October 6, 2026 CITY OF TROY Hg LORI GRIGG BLUHM (P46908) Attorney for Respondent 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 bluhmlg@troymi.gov Certificate of Service | hereby certify that on October 6, 2026, | filed this Answer and Affirmative Defenses with the Michigan Tax Tribunal and sent a copy to Petitioner's Attorney Laura Hallahan via email at: LHallahan@HallahanLaw.com; and also sent the documents via first class mail to the Michigan Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 49822; Secretary of School Board, Troy Public Schools, 4400 Livernois Road, Troy, MI 48098; Director of Equalization; Oakland Pointe Office Building, 250 Elizabeth Lake Road Suite 1000, Pontiac, MI 48341; and Clerk, Oakland County, 1200 N. Telegraph, Building 12 East, Pontiac, MI 48341. Dated: October 6, 2026 CITY OF TROY Clara Reid Legal Administrative Coordinator 500 W. Big Beaver Road Troy, MI 48084