Full record / NEPTUNE V ALAMO ANS 26-001135-TT10003220260730100819.pdf

NEPTUNE V ALAMO ANS 26-001135-TT10003220260730100819.pdf

Neptune Kalamazoo LLC Petitioner Vs. Township Of Alamo Respondent · 26-001135-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

NEPTUNE KALAMAZOO, LLC, 

Petitioner, 

MTT Docket No. 26-001135-TT 

v 

TOWNSHIP OF ALAMO, 

Respondent. 

Brian E. Etzel (P54905) 

Robert E. Thall (P46421) 

Williams, Williams, Rattner 

Bauckham, Thall, Seeber, 

& Plunkett, PC 

Kaufman & Koches, P.C. 

Attorney for Petitioner 

Attorney for Respondent 

380 N. Old Woodward Ave., Ste. 300 

470 W. Centre Ave., Suite A 

Birmingham, MI 48009 

Portage, MI 49024-5362 

(248) 642-0333 

269-382-4500 

bee@wwrplaw.com 

thall@michigantownshiplaw.com 

ANSWER TO PROPERTY TAX PETITION AND MULTIPLE PARCEL 

FORM 

WITH AFFIRMATIVE DEFENSES 

Respondent, Township of Alamo, 

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 allegations 

therein. 

2. 

In answer to paragraph 

2 

of the Petition, Respondent admits the allegations 

therein, except that the Township is a general law township and not a charter township.

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4. 

In answer to paragraph 

4 of the Petition, Respondent admits the allegations 

therein. 

5. 

In answer to paragraph 

5 

of the Petition, Respondent admits the allegations 

therein. 

6. 

In answer to paragraph 

6 

of the Petition, Respondent admits the allegations 

therein. 

7. 

In answer to paragraph 7 of the Petition and paragraph 

1 of the Multiple Parcel 

Form, Respondent admits the allegations therein. 

8. 

In answer to paragraph 8 of the Petition and paragraph 2 of the Multiple Parcel 

Form, Respondent denies the contended valuations therein as untrue. 

9. 

In answer to paragraph 9 of the Petition and paragraph 3 of the Multiple Parcel 

Form, Respondent admits the allegations therein. 

10. 

In answer to paragraph 

10 of the Petition, Respondent admits the allegations 

therein. 

11. 

In answer to paragraph 11 of the Petition, Respondent denies the allegations as 

untrue. 

12. 

In answer to paragraph 12 of the Petition, Respondent denies that the Respondent 

overestimated the subject properties values as untrue. 

WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying 

the relief requested by Petitioner and uphold and affirm the valuations as established by the

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AFFIRMATIVE DEFENSES 

Please take notice that Respondent may rely on one or more of the following affirmative 

defenses: 

1. 

2. 

3. 

4. 

Petitioner has failed to state a claim upon which relief may be granted. 

The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 

The service of process was insufficient. 

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. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMANy& 

KOCHES P.C. 

Date: July 30, 2026 

lf 

By: 

5 

/ Robert E. Thall 

Attorney for Respondent

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