NEPTUNE V ALAMO ANS 26-001135-TT10003220260730100819.pdf
Neptune Kalamazoo LLC Petitioner Vs. Township Of Alamo Respondent · 26-001135-TT
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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