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26-000809.pdf

Luca Land Development, LLC Petitioner Vs. Township Of Grand Blanc Respondent · 26-000809-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LUCA LAND DEVELOPMENT, LLC, 

Docket No. 26-000809 

Petitioner, 

RECEIVED 

VS. 

AUG 14 2026 

GRAND BLANC TOWNSHIP,’ 

MICHIGAN TAX TRIBUNAL 

Respondent. 

WILLIAMS, WILLIAMS, RATTNER 

DELZER LEGAL 

& PLUNKETT, PC 

William E. Delzer (68488) 

Jerome P. Pesick (P29039) 

Attorney for Respondent 

Jason C. Long (P59244) 

8332 Office Park Dr., Ste B 

380 N. Old Woodward Ave., Ste 300 

Grand Blanc, MI 48439 

Birmingham, MI 48009 

(810) 603-1000 

(248) 642-0333 

wdelzer@delzerlegal.com 

ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

NOW COMES Respondent, Grand Blanc Township, by and through their attorney 

William E. Delzer, and in response to the Petition in this cause, sets forth to this 

Honorable Tribunal as follows: 

1. 

That as an answer to paragraph 1 of Petition, Respondent neither admits nor 

denies the allegations contained therein and leaves Petitioner to its proofs. 

2. 

That as an answer to paragraph 2 of Petition, Respondent admits the 

allegations contained therein. 

3. 

That as an answer to paragraph 3 of Petition, Respondent neither admits nor 

denies the allegations contained therein and leaves Petitioner to its proofs. 

4. 

That as an answer to paragraph 4 of Petition, Respondent neither admits nor 

denies the allegations contained therein and leaves Petitioner to its proofs.

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7. 

That as an answer to paragraph 7 of Petition, Respondent admits the 

allegations contained therein. 

8. 

That as an answer to paragraph 8 of Petition, Respondent denies the 

allegations contained therein. 

9. 

That as an answer to paragraph 9 of Petition, Respondent denies the 

allegations contained therein. 

10. That as an answer to paragraph 10 of Petition, Respondent neither admits nor 

denies the allegations contained therein and leaves Petitioner to its proofs. 

11. That as an answer 

to paragraph 

11 

of Petition, Respondent denies the 

allegations contained therein. 

12. That as an answer to paragraph 12 of Petition, Respondent neither admits nor 

denies the allegations contained therein and leaves Petitioner to its proofs. 

WHEREFORE, Respondent denies Petitioner's prayer for relief and prays that this 

Honorable Tribunal affirm the 2026 assessment and taxable value of the subject property 

and award Respondent costs, attorney fees and any other relief that this Honorable 

Tribunal may deem appropriate. 

Respectfully submitted, 

DELZER LEGAL

Page 3

AFFIRMATIVE DEFENSES 

Respondent, Grand Blanc Township asserts the following affirmation 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. 

The Tribunal 

is charged with finding 

a property's true cash value to 

determine the property’s lawful assessment. Alhi Dev Co v Orion Twp, 110 Mich App 764, 

767 (1981). 

3. 

Petitioner has the burden of establishing the property's true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has 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. 

5. 

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 others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient 

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

6. 

Petitioner asks the Tribunal to grant it preference by application of a self- 

chosen method of assessment contrary to the intent, purpose and law of this State. 

7. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

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

other properties in 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. 

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.

Page 4

11. 

Respondent reserves the right to raise additional affirmative defenses as the 

same may become known to it during the course of these proceedings. 

WHEREFORE, Respondent prays that this Honorable Tribunal affirm the 2026 

assessment and taxable value of the subject property and award Respondent costs, 

attorney fees and other relief that this Honorable Tribunal may deem appropriate. 

Respectfully submitted, 

DELZER LEGAL 

Dated: August 10, 2026 

William E. Delzer (68488) 

Attorney for Respondent

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LUCA LAND DEVELOPMENT, LLC, 

Docket No. 26-000809 

Petitioner, 

vs. 

GRAND BLANC TOWNSHIP, 

Respondent. 

WILLIAMS, WILLIAMS, RATTNER 

DELZER LEGAL 

& PLUNKETT, PC 

William E. Delzer (P68488) 

Jerome P. Pesick (29039) 

Attorney for Respondent 

Jason C. Long (P59244) 

8332 Office Park Dr., Ste B 

380 N. Old Woodward Ave., Ste 300 

Grand Blanc, MI 48439 

Birmingham, MI 48009 

(810) 603-1000 

(248) 642-0333 

wdelzer@delzerlegal.com 

PROOF OF SERVICE OF ANSWER AND AFFIRMATIVE DEFENSES TO ENTIRE 

TRIBUNAL TAX PETITION FOR 2026 

1, William E. Delzer, being duly sworn deposes and says that on August 10, 2026 

he served a copy of Respondent's Answer to and Affirmative Defenses to Entire Tribunal 

Tax Petition for 2026 and this proof of service by first class mail to: 

Jerome Pesick, Attorney for Petitioner, 380 N. Old Woodward Ave., Ste 300, 

Birmingham, MI 48009 

by placing in an envelope addressing, it to their address of record with proper postage 

attached and depositing in a US Postal receptacle.

Page 6

DELZER 

LEGAL 

August 10, 2026 

Department of Licensing and Regulatory Affairs 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

RE: 

Luca Land Development, LLC v Grand Blanc Township 

Docket No.: 

26- 000309 

Dear Clerk: 

Enclosed for filing please find Respondent's Answer to Petition and Affirmative Defenses along with 

a Proof of Service of Mailing of same with regard to the above-entitled matter. 

If you have any questions regarding this matter, please contact my office. 

Very truly yours, 

DELZER LEGAL

Page 7

DELZER n LEGAL 

8332 Office Park Drive, Suite B 

Grand Blanc, Michigan 48439 

Department of Licensing and Regulatory Affairs 

Received 

Michigan Tax Tribunal 

PO Box 30232 

AUR 14 

2026 

Lansing, MI 48909 

i 

LARA

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