Respondent's Answer to Petition and Affirmative Defenses with PoS - 8-18-26.pdf
Sresl LLC Petitioner Vs. Township Of Allendale Respondent · 26-002635-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL SRESL LLC, MTT Docket No. 26-002635 Petitioner, Parcel No. 70-09-26-227-037 vs. TOWNSHIP OF ALLENDALE, Respondent. Jon Aylsworth Bradley J. Fisher, Esq. (P64608) PROPERTY TAX CONSULTANTS SCHOLTEN FANT Representative for Petitioner Attorneys for Respondent 861 Pinecrest Ave. SE 100 North Third Street, P. O. Box 454 East Grand Rapids, MI 49506 Grand Haven, MI 49417-0454 269-366-0300 (616) 842-3030 jack@skylinepropertytax.com bfisher@scholtenfant.com RESPONDENT’S ANSWER TO PETITIONER’S PROPERTY TAX PETITION NOW COMES the Respondent, ALLENDALE CHARTER TOWNSHIP, by and through its attorneys, SCHOLTEN FANT, and for its Answer to Petitioner’s Property Tax Petition states as follows: 1. Admitted upon information and belief. 2. Admitted upon information and belief. 3. Admitted upon information and belief. 4. Admitted upon information and belief. 5. Neither admitted nor denied for lack of sufficient knowledge or information as to form a belief and, therefore, leaves Petitioner to its proofs. 6. Admitted upon information and belief. 7. Admitted upon information and belief. 8. Denied as untrue. 9. Neither admitted nor denied for lack of sufficient knowledge or information as to form a belief and, therefore, leaves Petitioner to its proofs. 1
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10. Respondent respectfully requests that the Tribunal deny Petitioner’s requested relief, affirm the assessments made by Respondent’s Assessor, award Respondent its costs and attorney’s fees in responding to this action. WHEREFORE, Respondent respectfully requests that the Tribunal deny Petitioner’s requested relief, affirm the assessments made by Respondent’s Assessor, award Respondent its costs and attorney’s fees in responding to this action and award such further relief that it deems appropriate under the circumstances. Dated: August 18, 2026 Grand Haven, MI 49417-0454 (616) 842-3030 AFFIRMATIVE DEFENSES TO PETITIONER’S PETITION NOW COMES the Respondent, TOWNSHIP OF ALLENDALE, by and through its attorneys, SCHOLTEN FANT, and states that it may rely on one or all of the following affirmative defenses: 1. The appropriate methods of assessing the Subject Property were used and those methods conform to the methods used to assess similarly situated property in the State. 2 Petitioner has failed to state a claim upon which relief can be granted. 3. Petitioner may not be a proper party-in-interest. 4. Petitioner may not have standing to appeal. 5. The Tribunal may lack subject matter jurisdiction over this appeal. 6. Petitioner may have failed to comply with state property tax law by, inter alia, failing to report or failing to report completely its assessable property such that its property taxes No
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were delinquent or underpaid, such that Petitioner is precluded from appealing its property values, and, such that Respondent should be awarded damages. va Respondent reserves the right to add additional affirmative defenses as they become known to it through discovery in this matter. WHEREFORE, Respondent requests that the Tribunal taxable values as determined by Respondent, to dismiss the 2023 assessed and e Petitign, and award Respondent costs, attorney fees and any other relief that the Tribdnal determines/is fair, just and equitable. Dated: August 18, 2026 Bradley J. Risher (P64608) SCHOLTEN FANT Attorneys for Respondent, Allendale Twp. 100 North Third Street, P. O. Box 454 Grand Haven, MI 49417-0454 (616) 842-3030
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL SRESL LLC, MTT Docket No. 26-002635 Petitioner, Parcel No. 70-09-26-227-037 Vs. TOWNSHIP OF ALLENDALE, Respondent. Jon Aylsworth Bradley J. Fisher, Esq. (P64608) PROPERTY TAX CONSULTANTS SCHOLTEN FANT Representative for Petitioner Attorneys for Respondent 861 Pinecrest Ave. SE 100 North Third Street, P. O. Box 454 East Grand Rapids, MI 49506 Grand Haven, MI 49417-0454 269-366-0300 (616) 842-3030 jack@skylinepropertytax.com bfisher@scholtenfant.com PROOF OF SERVICE The undersigned certifies that a copy of the Appearance and Respondent's Answer to Property Tax Petition and Affirmative Defenses to Petitioner's Property Tax Petition was e-filed with the Michigan Tax Tribunal and served upon all parties and/or attorneys of record to this action to their addresses as disclosed by the pleadings, on August 18, 2026, via email and U.S. Mail First Class, from Grand Haven, Michigan, with postage therepn fully prepaid. Dated: August 18, 2026 Legal Assistant to Bradley J. Fisher