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25-002363.pdf

Zenith Inc, Petitioner Vs. Township Of Flint, Respondent · 25-002363-TT

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Page 1

RECEIVED 

JUL 29 2025 

MICHIGAN TAX TRIBUNAL 

RAM 

CHARTER TOWNSHIP OF FLINT 

ves 

BARB VERT 

CLERK. 

1490 8. Dye Road 

CAROL PFAFF-DAHL 

MANYA TRIPLETT 

Flint, Michigan 48532 

h 

TREASURER 

TOM KLEE 

LISA R. ANDERSON 

DEBBE CAMPBELL 

July 23, 2025 

Office of the Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

MTT Docket No.: 25-002363 

Zenith Inc v Township of Flint 

Parcels: 07-15-504-006 

Dear Honorable Michigan Tax Tribunal: 

Enclosed for filing, please find Respondent’s Reply to Petitioner’s Petition (in the Entire 

Tribunal) and Respondent’s Proof of Service. 

Respectfully submitted, 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Zenith Inc. 

MTT Docket No.: 25-002363 

Petitioner 

Parcel 

07-15-504-006 

Vv 

Flint Township, Genesee County 

Respondent 

Ward D. Tubbs 

Paula Dotson 

Jim Tubbs Tax Consultants LLC 

Deputy Assessor, Charter Township of Flint 

G-8469 S. Saginaw 

1490 S. Dye Road 

Grand Blanc, MI 48439 

Flint, MI 48532 

810.444.1779 

810.600.3227 

RESPONDENT'S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2025 

ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) 

Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy 

Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 

1. 

Respondent acknowledges 

that parcels 07-15-504-006 

identified 

in paragraph 

1 

of 

Petitioner’s Petition will be the subject of Petitioner’s appeal. 

2. 

Respondent admits the statements set forth in paragraph 2 of Petitioner’s Petition. 

3. 

N/A 

4. 

N/A 

5. 

N/A 

6. 

Respondent admits the statements set forth in paragraph 6 of Petitioner’s Petition.

Page 3

13. 

14. 

15. 

16. 

17. 

18. 

19: 

20. 

MTT Docket 25-002363 

N/A 

Respondent admits the statements set forth in paragraph 10 of Petitioner’s Petition. 

Respondent admits the statements set forth in paragraph 11 of Petitioner’s Petition. 

Respondent neither admits 

nor denies 

the statements 

set 

forth 

in paragraph 

12 

of 

Petitioner’s Petition. 

Respondent acknowledges the intent of Petitioner’s Petition as set forth in paragraph 13 of 

Petitioner’s Petition and leaves Petitioner to meeting its required burden of proof. 

Respondent acknowledges the intent of Petitioner to invoke the honorable Tribunal’s 

jurisdiction for tax year 2025 as set forth in paragraph 14 of Petitioners Petition. 

N/A 

Respondent admits 

the 

statements 

and/or allegations 

set 

forth 

in paragraph 

16 

of 

Petitioner’s Petition. 

Respondent neither admits nor denies 

the statements and/or allegations 

set forth 

in 

paragraph 

17 of Petitioner’s Petition as said paragraph 

is merely the opportunity for 

Petitioner to set forth its contention of value. 

Respondent neither admits nor denies 

the statements and/or allegations 

set forth 

in 

paragraph 

18 

of Petitioner’s 

Petition 

as 

said paragraph 

is merely 

the mathematical 

calculation of the difference between Respondent’s valuations and Petitioner’s contention 

of value. 

The relief and actions requested by Petitioner in paragraph 19 of Petitioner’s Petition 

should be denied. 

Respondent denies 

the 

statements 

and 

or allegations 

set forth 

in paragraph 20 

of 

Petitioner’s Petition as they are untrue. 

Respondent leaves Petitioner to meeting 

its 

required burden of proof. 

Respondent’s Response submitted on this date, 

July 23, 2025, by:

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Zenith Inc. 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

MTT DOCKET NO.: 25-002363 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

GENESEE COUNTY) 

THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on 

July 23, 2025, she caused to be served upon: 

Ward D. Tubbs 

Michigan Tax Tribunal 

Jim Tubbs Tax Consultants LLC 

PO Box 30232 

G-8469 S. Saginaw 

Lansing, Michigan 48909 

Grand Blanc, MI 48439 

by enclosing the same in an envelope, plainly addressed to said party at the above address, with 

lawful United States first class postage affixed thereon and by placing same in the United States 

mail. 

July 23, 2025 

p 

Ap At 

Date 

"Paula Dotson 

Deputy Assessor

Page 5

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