Answer.pdf
2980 Interstate Parkway LLC Petitioner Vs. Township Of Comstock Respondent · 26-001357-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 2980 INTERSTATE PARKWAY LLC, Petitioner, MTT Docket No. 26-001357-TT V TOWNSHIP OF COMSTOCK, Respondent. Steve Johnson Representative for Petitioner 436 N. Center St. Northville, MI 48167 (248) 392-4342 info@mitaxappeal.com Robert E. Thall (P46421) Bauckham, Thall, Seeber, Kaufman & Koches, P.C. Attorney for Respondent 470 W. Centre Ave., Suite A Portage, MI 49024-5362 269-382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, Township of Comstock 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 answer is required. 4. In answer to paragraph 4 of the Petition, the parcel under appeal is real. 5. In answer to paragraph 5 of the Petition, no response is required. 6. In answer to paragraph 6 of the Petition, Respondent admits the allegation therein. 7. In answer to paragraph 7 of the Petition, no response is required. 8. In answer to paragraph 8 of the Petition, no response is required.
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9. In answer to paragraph 9 of the Petition, no response is required. 10. In answer to paragraph 10 of the Petition, Respondent admits the allegations therein. 11. In answer to paragraph 11 of the Petition, Respondent admits the allegation therein. 12. In answer to paragraph 12 of the Petition, Respondent admits the allegation therein. 13. In answer to paragraph 13 of the Petition, Respondent admits the allegations therein. 14. In answer to paragraph 14 of the Petition, Respondent admits the allegation therein. 15. In answer to paragraph 15 of the Petition, no response is required. 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 Petitioner’s values for the property as untrue. 18. In answer to paragraph 18 of the Petition, Respondent admits the values in dispute. 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 request that the Tribunal enter an Order denying the relief requested by Petitioner and uphold and affirm the valuation as established by the Respondent and require Petitioner to pay Respondent’s costs and attorney fees.
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AFFIRMATIVE DEFENSES Please take notice that Respondent may rely on one or more of the following affirmative defenses: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 3. The service of process was insufficient. 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. Respectfully submitted, BAUCKHAM, SPARKS, THALL, SEEBER, & KAUFMAN, P.C. Date: October 7, 2026 By: /s/ Robert E. Thall Robert E. Thall, Attorney for Respondent