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26-000783 ANSWER09922920260720091650.pdf

Tc Bay Resort LLC Petitioner Vs. Township Of East Bay Respondent · 26-000783-TT

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Page 1

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

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