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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 

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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 

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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

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