Respondent_Answer_Cole_Frageman_v_Delhi_26-000575 (1).pdf
Cole Eric Frageman Petitioner V Township Of Delhi Charter Respondent · 26-000575-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL – SMALL CLAIMS COLE ERIC FRAGEMAN, MOAHR Docket No.: 26-000575 Petitioner, v Tax Parcel No.: 33-25-05-15-479-009 CHARTER TOWNSHIP OF DELHI, Respondent. COLE ERIC FRAGEMAN DAVID M. REVORE (P68929) Petitioner MCGINTY, HITCH, PERSON, 9014 Island View Drive ANDERSON & REVORE, P.C. Laingsburg, MI 48848 Attorney for Respondent (219) 861-8087 3410 Bell Chase Way, Suite 600 c.frageman@gmail.com Lansing, MI 48911 (517) 351-0280 davidrevore@mcgintylaw.com PETITIONER’S ANSWER TO RESPONDENT’S AFFIRMATIVE DEFENSES NOW COMES Petitioner, Cole Frageman, an answer to the Affirmative Defenses provided by Respondent. 1. On April 20th, 2026 Petitioner provided a Restricted Real Estate Appraisal Report completed by Vantage Appraisal Services LLC and approved by Credit Union One bank to Docket No. 26-000575.On July 24th, 2026 Respondent claims in their Affirmative Defenses #1, #2, #3, and #4 that Petitioner provided no evidence or factual basis for relief, assessment, property value, or to claim different taxable value on the property in question. 2. The Exhibit A Property Record Card and Valuation Report for Parcel ID No. 33-25-05-15-479-009 provided by the Respondent does not have accurate property information on the valuation. The income and expense estimates used by the Respondent in Valuation Report are not correctly represented. The Appraisal Report provided by the Petitioner has the accurate information on the property. 3. Based on the capitalization rate used by the Respondent in their analysis and combined with the actual numbers provided by Petitioner the income capitalization value of the property would be $622,328. 4. Petitioner has more data on income and expenses to back up the Appraisal Report. 5. Petitioner requests for pretrial hearing under Michigan Court Rule (MCR) 2.401(A). WHEREFORE, Petitioner respectfully requests that the Tribunal approve all relief requested by Petitioner and affirm the 2026 assessed and taxable values as determined by Petitioner. Thank you for your time on this. Dated: August 8th 2026 Respectfully submitted, by: _______________________________ Cole Frageman Petitioner