Monroe Capital Holdings MTT# 24-004087 answer.pdf
Monroe Capital Holding LLC, Petitioner V City Of Detroit, Respondent · 24-004087-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MONROE CAPITAL HOLDINGS, LLC, Petitioner, v. MTT Docket No. 24-004087 CITY OF DETROIT, Respondent. / ANSWER RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter states as follows: 1. Respondent admits as to parcel identification. 2. Respondent admits. 3. Respondent admits. 4. No response required. 5. No response required. 6. Respondent admits the subject properties are classified as residential condominiums. 7. No response required. 8. Respondent denies as untrue. As the properties are classified as residential condominiums an appeal to the Board of Review is required. 9. The subject properties were sold by Petitioner in 2022 to “Top Notch A1 Investment Co.” whose address is 23125 Greater Mack, P.O. Box 80754, St. Clair Shores, MI. 48080. Petitioner is therefore not a party in interest.
Page 2
2 10. Respondent admits. 11. Respondent admits. 12. Respondent admits. 13. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues involving true cash and taxable values. Respondent denies that any such allegations have merit. 14. Respondent denies that any tax years are at issue as Petitioner does not have standing to bring this appeal and the appeal was not timely filed. 15. The subject properties were sold by Petitioner in 2022 to “Top Notch A1 Investment Co.” whose address is 23125 Greater Mack, P.O. Box 80754, St. Clair Shores, MI. 48080. Petitioner is therefore not a party in interest. 16. Respondent denies Petitioner’s contentions of value are correct or accurate. 17. Respondent denies Petitioner’s contentions of value are correct or accurate. 18. Respondent denies Petitioner’s contentions of value are correct or accurate. 19. Request for relief, no response required. 20. The subject properties were sold by Petitioner in 2022 to “Top Notch A1 Investment Co.” whose address is 23125 Greater Mack, P.O. Box 80754, St. Clair Shores, MI. 48080. Petitioner is therefore not a party in interest. AFFIRMATIVE DEFENSES Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 1. Petitioner’s claims are barred by the applicable statute of limitations. 2. Petitioner has failed to state a claim for which relief may be granted. 3. Petitioner lacks standing.
Page 3
3 WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable Tribunal dismiss the petition in this matter and award costs and attorney fees. Respectfully Submitted, Dated: February 12, 2025 /s/ Kevin C. Richard Kevin C. Richard (P43417) Perry L. Yun (P39446) City of Detroit Law Department Coleman A. Young Municipal Center 2 Woodward Avenue, Suite 500 Detroit, Michigan 48226 (313) 237-3061
Page 4
4 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MONROE CAPITAL HOLDINGS, LLC, Petitioner, v. MTT Docket No. 24-004087 CITY OF DETROIT, Respondent. / PROOF OF SERVICE On February 12, 2025, I mailed by first class mail a copy of Respondent’s answer w/affirmative defenses in the instant matter to: Attn: Jerome Morgan Monroe Capital Holdings LLC 15450 Dale Street Detroit, Michigan 48223 I declare that the statement above is true to the best of my information, knowledge and belief. /s/ Kevin C. Richard Kevin C. Richard (P43417) Assistant Corporation Counsel City of Detroit Law Department Coleman A. Young Municipal Center 2 Woodward Avenue, Suite 500 Dated: February 12, 2025 Detroit, Michigan 48226