26-000783 ANSWER09922920260720091650.pdf
Tc Bay Resort LLC Petitioner Vs. Township Of East Bay Respondent · 26-000783-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TC BAY RESORT LLC, Petitioner, Vv EAST BAY CHARTER TOWNSHIP, Respondent. MTT Docket No. 26-000783 Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Rd., Ste. 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 Robert E. Thall (P46421) Bauckham, Thall, Seeber, Kaufman & Koches, P.C. Attorney for Respondent 470 W. Centre Ave., Ste. A lhallahan@hallahanlaw.com Portage, MI 49024 (269) 382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, East Bay Charter Township, 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 contained therein. 2. In answer to paragraph 2 of the Petition, no answer is required. 3. In answer to paragraph 3 of the Petition, Respondent admits the allegations therein. 4. In answer to paragraph 4 of the Petition, Respondent neither admits nor denies and
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6. In answer to paragraph 6 of the Petition, Respondent admits the allegations therein. 7. In answer to paragraph 7 of the Petition, Respondent admits the allegation therein. 8. In answer to paragraph 8 of the Petition, Respondent admits the allegations therein. 9. In answer to paragraph 9 of the Petition, Respondent denies the allegations therein as untrue. 10. In answer to paragraph 10 of the Petition, Respondent admits the values in dispute. 11. In answer to paragraph 11, including (a) through (d), 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. 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.
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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. Date: July 20, 2026 Respectfully submitted, BAUCKHAM, SPARKS, THALL, SEEBER, & KAUFMAN, P.C. ~ - ZM/ By: | /Robert E. THall Attorney for Respondent