07162026_ANSWER.pdf

Appleton Of Monroe Group, LLC Petitioner Vs. City Of Monroe Respondent · 26-000559-TT

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STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

APPLETON OF MONROE GROUP, LLC 

Petitioner, 

v 

City of Monroe, 

Respondent. 

MOAHR Docket No. 26-000559 

Laura M. Hallahan (P42101) 

Hallahan & Associates, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 7331-3089 

Matthew D. Budds (P71938) 

Mohr Budds Law, PLLC 

8 West First Street 

P.O. Box 904 

Monroe, MI 48161 

734-735-4084 

Attorneys for Respondent 

ANSWER AND AFFIRMATIVE DEFENSES 

ANSWER 

NOW COMES Respondent, the City of Monroe, by and through its attorney, Matthew D. 

Budds, of Mohr Budds Law, PLLC, and hereby answers the Petition in this cause as follows: 

1. 

Respondent admits Allegation No. 1. 

2. 

Respondent neither admits nor denies Allegation No. 2 because it is not 

applicable. 

3. 

Respondent admits Allegation No. 3. 

4. 

Respondent neither admits nor denies Allegation No. 4 for lack of 

knowledge or information sufficient to form a belief. 

5. 

Respondent neither admits nor denies Allegation No. 5 for lack of 

knowledge or information sufficient to form a belief.

10. 

11. 

Respondent admits that the appeal appears to involve issues relating to 

true cash and taxable values; however, Respondent denies Petitioner is 

entitled to the relief sought in the Petition. 

Respondent admits that the appeal appears to involve the 2026 tax year as 

stated in Allegation 7, however, Respondent denies Petitioner is entitled to 

the relief sought in the Petition. 

Respondent admits Allegation No. 8. 

Respondent denies Petitioner’s contentions of value in Allegation No. 9 as 

untrue. 

Respondent admits that based on Petitioner’s untrue contentions, the value 

in dispute is accurately stated in Allegation 10 but further denies that 

Petitioner is entitled to the relief sought in the Petition. 

Respondent requests that the Tribunal deny the relief sought. 

WHEREFORE, Respondent prays that the Michigan Tax Tribunal: 

1. 

Pw 

Dismiss the Petition 

Affirm the Respondent’s determination of the true cash and assessed, state 

equalized, and taxable values 

Award the Respondent costs and attorney fees as appropriate; and 

Make and award such further relief as the Tribunal determines appropriate. 

Respectfully submitted, 

= 

Matthew D. Budds 

Mohr Budds Law, PLLC 

8 West First Street 

P.O. Box 904 

Monroe, MI 48161 

734-735-4084 

Attorneys for Respondent City of Monroe

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, the City of Monroe, by and through its attorney, Matthew D. Budds 

of Mohr Budds Law, PLLC, and for its Affirmative Defenses States as follows: 

1. 

2. 

The Tribunal lacks jurisdiction to hear the appeal; 

The appropriate methods of assessing the subject property were used and those 

methods conform to the methods used to assess similarly situated property in the 

State of Michigan; 

The Petitioner fails to state a claim upon which relief can be granted; 

The Petitioner fails to provide a factual basis to determine that the assessment of 

Respondent was incorrect or invalid. 

The Petitioner fails to provide a factual and/or legal basis for its constitutional 

and/or statutory allegations. 

Respectfully submitted, 

Matthew D. Budds 

Mohr Budds Law, PLLC 

8 West First Street 

P.O. Box 904 

Monroe, MI 48161 

734-735-4084 

Attorneys for Respondent City of Monroe

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

APPLETON OF MONROE GROUP, LLC 

Petitioner, 

v 

MOAHR Docket No. 26-000559 

City of Monroe, 

Respondent. 

Laura M. Hallahan (P42101) 

Matthew D. Budds (P71938) 

Hallahan & Associates, P.C. 

Mohr Budds Law, PLLC 

Attorney for Petitioner 

8 West First Street 

1750 S. Telegraph Road, Suite 202 

P.O. Box 904 

Bloomfield Hills, MI 48302-0179 

Monroe, MI 48161 

(248) 7331-3089 

734-735-4084 

Attorneys for Respondent 

PROOF OF SERVICE 

On July 16, 2026, I served a copy of Respondent City of Monroe’s Answer and Affirmative 

Defenses in the above-referenced matter upon the following by sending a copy of said documents 

to the individual named below at her respective address by first-class United States mail with 

postage prepaid. 

Laura M. Hallahan (P42101) 

Hallahan & Associates, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 7331-3089 

a> 

a — 

Matthew D. Budds

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