Answer Undercar Products v Wyoming -- 25-002118.pdf
Undercar Products Group Inc., Petitioner Vs. City Of Wyoming, Respondent · 25-002118-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Undercar Products Group Inc., Petitioner, v. City of Wyoming, Respondent _____________________________________/ MTT Docket No. 25-002118-TT Michelle (Mikki) M. Silvey (P69494) Alex Morse DuCharme, McMillen & Associates Representatives for Petitioner 9229 Delegates Row, Suite 735 Indianapolis, IN 46240 (317) 689-6467 msilvey@dmainc.com amorse@dmainc.com ____________________________________/ Ryan M. Shannon (P74535) Dickinson Wright PLLC Counsel for Respondent 123 W. Allegan St., Suite 900 Lansing, MI 48933 (517) 410-5443 rshannon@dickinson-wright.com ANSWER AND AFFIRMATIVE DEFENSES Respondent, City of Wyoming, by and through its counsel, Dickinson Wright PLLC, files its Answer to the Petition filed in the above-captioned matter by like- numbered paragraphs, and states separately thereafter its Affirmative Defenses: 1. No allegation of fact or law has been made to which a response is required. Respondent shall refer to Parcel No. 41-18-19-426-007, 41-18-19-600-001, and 41-55-93-213-119 as the “Subject Property.” 2. Admitted. 3. Admitted. 4. Respondent neither admits nor denies as it is without sufficient information to form a belief, and leaves Petitioner to its proofs.
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MTT Docket No. 25-002118-TT Page 2 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Respondent neither admits nor denies as it is without sufficient information and leaves Petitioner to its proofs. 11. Respondent neither admits nor denies as it is without sufficient information and leaves Petitioner to its proofs. 12. Admitted. 13. Admitted. 14. Denied as untrue that the values for the Subject Property are or should be as set forth in this paragraph, or in the multiple parcel form attached to the Petition. 15. Admitted, based on Petitioner’s contentions of value. 16. Denied as untrue, including as to each subpart. AFFIRMATIVE DEFENSES 1. Petitioner has failed to plead in conformity with the Tax Tribunal Rules. 2. Petitioner has failed to state a claim upon which relief can be granted. 3. Any reduction in the value of Petitioner’s property is the result of Petitioner’s own action or inaction and cannot form the basis for a reduction in value.
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MTT Docket No. 25-002118-TT Page 3 4. Respondent reserves the right to identify additional affirmative defenses as they become known through litigation in this matter or otherwise. WHEREFORE, Respondent respectfully requests that the Tribunal deny and dismiss the Petition, affirm the tax rolls at their current value, and grant to Respondent such other and further relief as the Tribunal deems to be within its powers to give. Submitted Respectfully DICKINSON WRIGHT PLLC /s/ Ryan M. Shannon Ryan M. Shannon Counsel for Respondent Dated: October 13, 2025
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MTT Docket No. 25-002118-TT Page 4 CERTIFICATE OF SERVICE The undersigned hereby certifies that on October 13, 2025, he caused a copy of the foregoing Answer and Affirmative Defenses to be served on counsel for Petitioner at the following address by first class mail, postage prepaid: Mikki M. Silvey DuCharme, McMillen & Associates, Inc. 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 So certified: /s/ Ryan M. Shannon Ryan M. Shannon Dated: October 13, 2025