25-002492.pdf
Ssp Associates Inc, Petitioner Vs. Township Of Saginaw, Respondent · 25-002492-TT
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RECEIVED JUL 29 2025 MICHIGAN TAX TRIBUNAL FRANCIS J. KEATING Attorney TEL: 989.631.1027 FAX: 989.631.9880 EMAIL: frakea@braunkendrick.com July 25, 2025 Ms. Samantha M. Welton Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 Re: SSP Associates Inc v Township of Saginaw MTT Docket No.: 25-002492 Dear Ms. Welton: Enclosed please find the following for the above-referenced matter: 1. Respondent’s Answer to Entire Tribunal Property Tax Petition; and 2. Proof of Service. Please file them in your usual manner. Thank you for your attention to this matter. If you have any questions regarding it, please contact me. CIS J. KEATING FJK/Is Enclosures
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com RESPONDENT’S ANSWER TO ENTIRE TRIBUNAL PROPERTY TAX PETITION NOW COMES Respondent, Township of Saginaw, by and through its attorneys, Braun Kendrick Finkbeiner P.L.C., and for its Answer to Petition, states as follows: 1. 2, Admitted. Admitted. N/A. No parcels of personal property are under appeal. N/A. Admitted.
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10. Admitted. 11. Admitted. 12. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 12. 13. Respondent admits that Petitioner’s Petition states that this appeal involves issues relating to the property’s true cash value and taxable value. 14. Admitted. 15. N/A. 16. Admitted. 17. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 17. 18. Respondent admits that Petitioner has correctly computed the values in dispute by subtracting its erroneous value claims from the values correctly determined by Respondent. 19. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 19 regarding what Petitioner requests. Respondent denies as untrue that Petitioner is entitled to the relief it is requesting. 20. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 20 regarding what Petitioner requests. Respondent denies as untrue that Petitioner is entitled to the relief it is requesting. NEW MATTERS AND AFFIRMATIVE DEFENSES 1. Petitioner has failed to allege specific and sufficient facts to set forth a cause of
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3. Petitioner may not be the real party in interest to bring this tax appeal. 4. Petitioner may not have standing to bring this tax appeal. S. Petitioner has 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 fails to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper. 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 assert additional affirmative defenses during the pendency of this action. WHEREFORE, Respondent, Township of Saginaw, respectfully requests that this Honorable Tribunal provide it with the following relief: A. Dismiss Petitioner’s Entire Tribunal Property Tax Petition and award Respondent its attorney fees and costs; and B. Provide Respondent with such other relief as the Tribunal deems appropriate. BRAUN KENDRICK FI INER P.L.C. — Dated: July 5 2025 Fem EATING (P39223) Aiomgy bor r Respondent
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SSP ASSOCIATES INC, Petitioner, MTT Docket No.: 25-002492 v TOWNSHIP OF SAGINAW, Respondent. MICHIGAN TAX APPEAL SERVICES BRAUN KENDRICK FINKBEINER P.L.C. By: Steve Johnson By: Francis J. Keating (P39223) Representative for Petitioner Attorneys for Respondent 436 N. Center St. 4301 Fashion Square Blvd. Northville, MI 48167 Saginaw, MI 48603 (248) 392-4342 (989) 498-2100 sjohnson@mitaxappeal.com frakea@braunkendrick.com PROOF OF SERVICE STATE OF MICHIGAN ) )ss COUNTY OF MIDLAND) FRANCIS J. KEATING, duly sworn, deposes and says that he is an attorney with BRAUN KENDRICK FINKBEINER P.L.C., attorneys for the Respondent, Township of Saginaw, and states that on the 25th day of July 2025, he served a copy of Respondent’s Answer to Entire Tribunal Property Tax Petition by first class mail, by placing same in nvelope with sufficient postage attached and plainly addressed to: “Steve Jes i Services, 436 N. Center St., Northville, MI 48167. 2 8 FRANGEIRY TG
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BX BRAUN KENDRICK ATTORNEYS AT LAW | 240 W. Main St. Suite 1200 Midland, MI 48640 METROPLEX Mg 4 26 JUL 2025. Pr A FIRST- : oe Zp 42640 $ 0006197887 [Ns FamanTha We [+on) Chief “Cleri< Michigan TAX Tribunal