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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)

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