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Answer to Severed Petition (Candace Properties).pdf

Candace Properties LLC, Petitioner Vs. Township Of West Bloomfield, Respondent · 25-002402-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

CANDACE PROPERTIES LLC, 

 

 

 

Petitioner, 

 

v 

 

CHARTER TOWNSHIP OF WEST 

BLOOMFIELD, 

 

 

 

Respondent. 

 

 

 

 

Docket No. 25-002402 

 

Parcel No. X-18-19-101-019 

 

____________________________________________________________________________/ 

 

JOSHUA T. SHILLAIR (P72674) 

COLLIERS INTERNATIONAL 

Attorney for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO SEVERED PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, Charter Township of West Bloomfield, by and through its attorneys, Hallahan 

& Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits that Petitioner is a party in interest with respect to parcel number 

X-18-19-101-019. As to the remaining allegations, Respondent lacks the information and 

knowledge necessary to respond to the truth of the allegations set forth in Paragraph 1 and therefore 

leaves Petitioner to its proofs.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent admits the allegations in Paragraph 3. 

4. 

Respondent lacks the information and knowledge necessary to respond to the 

allegations set forth in Paragraph 4 and therefore leaves Petitioner to its proofs. 

5. 

Respondent admits the allegations in Paragraph 5. 

6. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but 

denies that those issues have merit and further denies that Petitioner is entitled to any relief. 

7. 

Respondent admits the allegations in Paragraph 7. 

8. 

Respondent admits the allegations in Paragraph 8. 

9. 

Respondent admits the allegations in Paragraph 9. 

10. 

The values for the property identified above as established by Respondent’s Board 

of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$621,780 

$310,890 

$310,890 

 

11. 

Respondent contends that the values for the property identified above are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$621,780 

$310,890 

$310,890 

 

12. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$0 

$0 

$0 

 

13. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to such relief for the reasons stated above.

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Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

WHEREFORE, Respondent, Charter Township of West Bloomfield, requests the Tribunal 

dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state 

equalization, and award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Laura M. Hallahan__________________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: July -8, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Charter Township of West Bloomfield, asserts the following affirmative 

defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents.

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Entire Tribunal Property Tax Answer 

Page 4 of 5 

 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in accordance with statutory and constitutional requirements. 

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

13. 

Respondent reserves the right to raise additional affirmative defenses as the same 

may become known to it during the course of these proceedings.

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Entire Tribunal Property Tax Answer 

Page 5 of 5 

 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Date: July 8, 2025 

(248) 731-3089 

 

 

 

 

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to Petition 

and Affirmative Defenses to: 

 

Joshua T. Shillair, Esq. 

Collier’s International 

joshua.shillair@colliers.com 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

/s/Laura M. Hallahan______________ 

Dated: July 8, 2025 

Laura M. Hallahan

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