KENDALL V KZOO ANS 26-001161-TT10002720260730092742.pdf
Kendall Off Main LLC Petitioner Vs. Township Of Kalamazoo Respondent · 26-001161-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL KENDALL OFF MAIN LLC, Petitioner, MTT Docket No. 26-001161-TT \% TOWNSHIP OF KALAMAZOO. Respondent. Sarah Belloli Robert E. Thall (P46421) Ryan Bauckham, Thall, Seeber, Kaufman Representative for Petitioner & Koches, P.C. 101 West Big Beaver, Ste. 945 Attorney for Respondent Troy, MI 48084 470 W. Centre Ave., Ste. A 313-230-0104 Portage, MI 49024 sarah.belloli@ryan.com 269-382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, Township of Kalamazoo, states the following in response to the respective paragraphs of the Petition filed in this matter: 1. In answer to paragraph 1 of the Petition, Respondent admits the allegation therein. 2. In answer to paragraph 2 of the Petition, Respondent admits the allegation therein. 3. In answer to paragraph 3 of the Petition, no response is required as this is inapplicable.
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5. inapplicable. 8. inapplicable. 9. inapplicable. 10. therein. 11. therein. 12. therein. 13. In answer to paragraph 5 of the Petition, no response is required as this is In answer to paragraph 6 of the Petition, Respondent admits the allegation therein In answer to paragraph 7 of the Petition, Respondent admits the allegation therein. In In In In In answer to paragraph 8 of the Petition, no response is required as this is answer to paragraph 9 of the Petition, no response is required as this is answer to paragraph 10 of the Petition, Respondent admits the allegation answer to paragraph 11 of the Petition, Respondent admits the allegation answer to paragraph 12 of the Petition, Respondent admits the allegation In answer to paragraph 13 of the Petition, Respondent admits that the appeal involves the issues stated therein.
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15. In answer to paragraph 15 of the Petition, no response is required as this is inapplicable. 16. In answer to paragraph 16 of the Petition, Respondent admits the allegations therein. 17. In answer to paragraph 17 of the Petition, Respondent denies the contended values as untrue. 18. In answer to paragraph 18 of the Petition, Respondent admits the allegations therein. 19. Paragraph 19 of the Petition does not require an answer as it is the Petitioner’s prayer for relief. 20. In answer to paragraph 20 of the Petition, Respondent denies the allegations therein as untrue. WHEREFORE, Respondent respectfully requests that the Tribunal enter an Order denying the relief requested by Petitioner and uphold and affirm the valuations as established by the Respondent, and require Petitioner to pay Respondent’s costs and attorney fees. AFFIRMATIVE DEFENSES Please take notice that Respondent may rely on one or more of the following affirmative
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4. The subject property is under assessed and/or the taxable value and/or state equalized value of the subject property is too low, and should therefore be appropriately increased to comply with the mandate of the applicable provisions of law. 5. Respondent reserves the right to file such additional affirmative defenses as may become apparent pursuant to discovery procedures during the pendency of this matter. WHEREFORE Respondent requests that the Tribunal enter a determination of no cause in its favor, and such other and further relief as is appropriate including costs and attorney fees. Dated: July 30, 2026 Respectfully submitted, BAUCKHAM,THALL, KAUFMA By: Kobert E. Thall (P46421) Attorney for Respondent