Answer to Petition.pdf
Statewide Meskill LLC Petitioner Vs. Township Of Columbus Respondent · 26-001113-TT
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STATE OF MICHIGAN MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM MICHIGAN TAX TRIBUNAL STATEWIDE MESKILL LLC, Petitioner, v. MTT Docket No: 26-001113 TOWNSHIP OF COLUMBUS, Respondent. ________________________________________________________________________ RESPONDENT TOWNSHIP OF COLUMBUS’ ENTIRE TRIBUNAL ANSWER TO PETITION Respondent, Township of Columbus (“Respondent” or “Township”), by and through its undersigned counsel, answers Petitioner Statewide Meskill LLC’s Petition as follows: 1. In answer to paragraph 1, Respondent neither admits nor denies the allegations concerning Petitioner’s principal-office address and party-in-interest status because Respondent lacks knowledge or information sufficient to form a belief as to their truth and therefore leaves Petitioner to its proofs. Respondent admits that the Petition identifies parcel numbers 74-16-009-3001-002 and 74-16-009-2003-000 as the parcels at issue. Respondent denies all remaining allegations not expressly admitted. 2. In answer to paragraph 2, Respondent admits that it is the local assessing and tax- collecting unit for real property located within its jurisdiction, including the parcels at
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issue, subject to applicable law. Respondent denies all remaining allegations not expressly admitted. 3. In answer to paragraph 3, Respondent admits that the 2026 Board of Review records reflect taxable values and assessed values of $145,000 for parcel 74-16-009- 3001-002 and $235,000 for parcel 74-16-009-2003-000. Respondent denies all remaining allegations, including any characterization of the assessment process, state equalization, and legal effect of the asserted values that is inconsistent with applicable law and the complete assessment record. 4. In answer to paragraph 4, Respondent admits that its 2026 assessment records classify parcel 74-16-009-3001-002 as agricultural-vacant and parcel 74-16-009-2003- 000 as agricultural-improved. Respondent denies that the parcels are commercial property to the extent Petitioner alleges a classification different from the Township’s 2026 records. Respondent neither admits nor denies Petitioner’s alleged belief concerning the design or intended use of the parcels because Respondent lacks knowledge or information sufficient to form a belief as to its truth and therefore leaves Petitioner to its proofs. 5. In answer to paragraph 5, Respondent admits only that Petitioner purports to raise issues relating to valuation, assessment, taxable value, and uniformity. Respondent denies that Petitioner is entitled to relief on any asserted issue and denies all remaining allegations not expressly admitted. 6. In answer to paragraph 6, Respondent denies the allegations contained therein. Answering further, Respondent states that Petitioner has not identified the alleged loss,
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the factual basis for the claimed loss, the calculation at issue, or a statutory basis for relief. 7. In answer to paragraph 7 and its subparagraphs, Respondent denies the allegations contained therein and further states that the allegations call for legal conclusions. Answering further, Respondent denies that the 2026 assessment, assessed value, state equalized value, taxable value, or taxes levied on the parcels are invalid, unlawful, discriminatory, nonuniform, unconstitutional, fraudulent, based on an erroneous determination of true cash value, or based on wrong principles. A. In answer to Petitioner’s request to reduce the 2026 taxable value, assessed value, and state equalized value of parcel 74-16-009-3001-002, Respondent denies that Petitioner is entitled to the requested relief. B. In answer to Petitioner’s request to reduce the 2026 taxable value, assessed value, and state equalized value of parcel 74-16-009-2003-000, Respondent denies that Petitioner is entitled to the requested relief. C. In answer to Petitioner’s request for refunds, interest, costs, and other relief, Respondent denies that Petitioner is entitled to the requested relief. Affirmative Defenses 1. Failure to Establish Entitlement to Relief. Petitioner has not alleged or established a factual or legal basis for the requested reductions, refund, interest, costs, or other relief. 2. True Cash Value, Assessed Value, and Taxable Value. Respondent denies that Petitioner is entitled to a reduction in true cash value, assessed value, state equalized
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value, or taxable value. Respondent’s 2026 determinations were made under applicable law and assessment principles. 3. Taxable-Value Claim. Petitioner has not identified a statutory or factual basis for a taxable-value adjustment based on an alleged “loss” or otherwise. 4. Uniformity and Constitutional Claims. Petitioner has not alleged or established facts demonstrating unequal treatment, discriminatory assessment practices, a denial of due process, or a violation of constitutional uniformity or equal-protection requirements. 5. Jurisdiction and Statutory Prerequisites. Respondent preserves all jurisdictional objections and defenses arising from Petitioner’s compliance, or lack of compliance, with statutory and Tribunal-rule prerequisites, including filing, service, party-in-interest status, property classification, and Board of Review requirements. 6. Additional Defenses. Respondent reserves the right to amend this Answer and assert additional defenses as permitted by the Tribunal’s rules and orders and as the assessment record and discovery develop. WHEREFORE, Respondent Township of Columbus respectfully requests that the Michigan Tax Tribunal: A. Deny the relief requested in the Petition; B. Affirm the Township’s 2026 assessment, state equalized value, and taxable value determinations for parcels 74-16-009-3001-002 and 74-16-009-2003-000; C. Deny Petitioner’s request for refunds, interest, costs, and other relief; and
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D. Grant Respondent such other relief as the Tribunal considers just and proper. Respectfully submitted, ADDIS LAW FIRM, PLLC Paul B. Addis Paul Addis (P61691) Attorney for Respondent Township of Columbus Dated: September 9, 2026 Proof of Service I certify that on September 9, 2026, I served this Respondent Township of Columbus’ Entire Tribunal Answer to Petition upon Aaron M. Fales, Esq., Law Office of Aaron M. Fales, P.C., 330 Hamilton Row, Suite 350, Birmingham, Michigan 48009, attorney for Petitioner Statewide Meskill LLC, by first class mail and afaleslaw@gmail.com Paul B. Addis Paul B Addis (P61691)