Response-x holdings.pdf
X Holdings LLC, Petitioner Vs. City Of Warren, Respondent · 25-002512-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL X HOLDINGS LLC MOAHR Docket #. 25-002512 Petitioner, Parcel ID No. 12-13-34-101-028 V. CITY OF WARREN, Respondent. STEPHEN POLTER (P72591) Attorney for Petitioner 2600 W. Big Beaver, Suite L100 Troy, Michigan 48084 (248) 213-6800 spolter@polterlaw.com MARY MICHAELS (P44601) JENNIFER PIERCE (P57078) CITY OF WARREN Attorneys for Respondent One City Square, Suite 400 Warren, MI 48093 (586) 574-4671 ipierce@cityofwarren.org / RESPONSE TO PETITION Respondent, City of Warren, by its attorney, MARY MICHAELS, City Attorney and JENNIFER PIERCE, Assistant City Attorney, in response to the Petition states as follows: 1. Respondent admits the allegations contained in paragraph 1.
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6. Respondent admits the allegations contained in paragraph 6 for assessing purposes. 7. No allegations are set forth in paragraph 7 and therefore no response is necessary. 8. No allegations are set forth in paragraph 8 and therefore no response is necessary. 9. No allegations are set forth in paragraph 9 and therefore no response is necessary.. 10. Respondent admits the allegations in paragraph 10. 11. Respondent admits the allegations contained in paragraph 11. 12. In response to Paragraph 12, Respondent is without knowledge or information sufficient to form a belief as to the truth of the allegations, and therefore leaves Petitioner to its proofs. 13. In response to Paragraph 13, Respondent is without knowledge or information sufficient to form a belief as to the truth of the allegation and therefore leaves Petitioner to its proofs. 14. Respondent admits the allegations contained in paragraph 14. 15. No allegations are set forth in paragraph 15 and therefore no response is necessary. 186. Respondent admits the amounts set forth for the assessed and taxable values. Respondent further states that the true cash value is $2,112,686.00. 17. In response to Paragraph 17, Respondent is without knowledge or information sufficient to form a belief as to the truth of the allegation and therefore leaves Petitioner to its proofs.
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20. No allegations are set forth in paragraph 20 and therefore no response is necessary. THEREFORE, Respondent City of Warren requests this Tribunal deny the requested relief, dismiss the Petition with prejudice, and award Respondent costs it incurred in the defense of this appeal. Respectfully submitted, By: [slJennifer Pierce JENNIFER PIERCE (P57078) Assistant City Attorney Attorneys for Respondent Dated: July 10, 2025 JP/s Response to Petition, Affirmative Defenses and POS — X Holdings LLC — ID 113560
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL X HOLDINGS LLC Petitioner, Vv. CITY OF WARREN, Respondent. STEPHEN POLTER (P72591) Attorney for Petitioner 2600 W. Big Beaver, Suite L100 Troy, Michigan 48084 (248) 213-6800 spolter@polterlaw.com MARY MICHAELS (P44601) JENNIFER PIERCE (P57078) CITY OF WARREN Attorneys for Respondent One City Square, Suite 400 Warren, Ml 48093 (586) 574-4671 ipierce@cityofwarren.org MOAHR Docket #. 25-002512 Parcel ID No. 12-13-34-101-028 AFFIRMATIVE DEFENSES Respondent, City of Warren, by its attorney, MARY MICHAELS, City Attorney and JENNIFER PIERCE, Assistant City Attorney, in response to the Petition, submit the following Affirmative Defenses:
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Tribunal. 4, Petitioner failed to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles, or illegality on the part of Respondent or its agents. 5. Petitioner failed to allege that the mode and method of assessing the subject property fails to conform to the mode and method applied in the case of all other properties in Respondent's taxing unit for the year in question. 6. Petitioner failed to show that any factor other than fifty percent (50%) was applied to the true cash value of Petitioner's property, as well as all others, to arrive at the respective assessments appearing on the roll, and also failed to allege specific and sufficient facts to support its allegations that the property's taxable value is improper. 7. Petitioner failed to submit any evidence warranting relief from the assessments to the Board of Review. 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. Respondent reserves the right to raise additional defenses as may become known to it during the course of these proceedings. Respectfully submitted, By: [slJennifer Pierce JENNIFER PIERCE (P57078) Assistant City Attorney Attorneys for Respondent Dated: July 10, 2025