2025.01.17 Answer to Petition.pdf
800 E. Court Street Village Limited Dividend Housing Association Limited PA, Petitioner Vs. Michigan Department Of Treasury, Respondent · 24-004101-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 800 E. COURT STREET VILLAGE LIMITED MTT Docket No. 24-004101-TT DIVIDEND HOUSING ASSOCIATION LIMITED PARTNERSHIP, Petitioner, v. CITY OF FLINT and MICHIGAN DEPARTMENT OF TREASURY, Respondents. _____________________________________________________________________/ HONIGMAN LLP Stewart L. Mandell (P-33781) Daniel L. Stanley (P-57052) Attorneys for Petitioner 39400 Woodward Ave, Ste 101 Bloomfield Hills, MI 48304 (313) 465-7420 (517) 377-0714 slmandell@hongiman.com dstanley@honigman.com JOSEPH N. KUPTZ (P-68623) Chief Deputy City Attorney Attorney for Respondent City of Flint, only City of Flint Law Department 1101 S. Saginaw St., 3rd Floor Flint, MI 48502 (810) 237-2085 jkuptz@cityofflint.com _____________________________________________________________________/ ENTIRE TRIBUNAL PROPERTY TAX ANSWER Respondent, City of Flint, answers Petitioner’s Entire Tribunal Property Tax Petition as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted.
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5. Respondent admits that Petitioner has raised issues regarding the taxation of the property and an October 16, 2024 decision by the other Respondent in this matter, the Michigan Department of Treasury. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations. 11. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegations. 12. Admitted. 13. Admitted. 14. Admitted. 15. Admitted. 16. This allegation is directed to the Respondent Michigan Department of Treasury. In further response, Respondent City of Flint lacks knowledge or information sufficient to form a belief as to the truth of the allegations. AFFIRMATIVE DEFENSES 1. Respondent, City of Flint, approved Petitioner’s request for exemption on July 3, 2024.
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2. Respondent reserves the right to amend or supplement its affirmative defenses in this matter. Respectfully submitted, Dated: January 17, 2025 /s/ Joseph N. Kuptz_________ Joseph N. Kuptz (P-68623) Chief Deputy City Attorney Attorney for Respondent 1101 S. Saginaw Street, 3rd Fl. Flint, MI 48502 (810) 237-2085