Respondent's Answer to Petition and Affirmative Defenses with PoS - 8-18-26 (2).pdf
Spc Of West Michigan LLC Petitioner Vs. Township Of Allendale Respondent · 26-001345-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS SPC OF WEST MICHIGAN LLC, Petitioner, Docket No. 26-001345 Parcel No. 70-09-24-465-002 Vv. TOWNSHIP OF ALLENDALE, Respondent. Steve Johnson Representative for Petitioner Bradley J. Fisher (P64608) 436 N. Center Street SCHOLTEN FANT Northville, Michigan 48167 Attorneys for Respondent Phone: (248) 392-4342 100 N. Third St. PO BOX 454 info@mitaxappeal.com Grand Haven, MI 49417 Phone: (616) 842-3030 bfisher@scholtenfant.com RESPONDENT’S ANSWER TO PETITIONER’S ENTIRE TRIBUNAL PROPERTY TAX PETITION NOW COMES the Respondent, ALLENDALE CHARTER TOWNSHIP, by and through its attorneys, SCHOLTEN FANT, and for its Answer to Petitioner’s Entire Tribunal Property Tax Petition states as follows: Admitted upon information and belief. Admitted. N/A. N/A. N/A. Admitted. Admitted. N/A. N/A. oP ND YM FP YN OP
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10. Lt. 12, 13. 14. 15. 16. 17. 18. LS. 20. Admitted upon information and belief. Admitted. Neither admitted nor denied for lack of sufficient knowledge or information as to form a belief, and therefore leaves the Petitioner to its proofs. Admitted upon information and belief. Admitted upon information and belief N/A. Admitted upon information and belief. Neither admitted nor denied for lack of sufficient knowledge or information as to form a belief, and therefore leaves the Petitioner to its proofs. Neither admitted nor denied for lack of sufficient knowledge or information as to form a belief, and therefore leaves the Petitioner to its proofs. 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. Neither admitted nor denied for lack of sufficient knowledge or information as to form a belief, and therefore leaves the Petitioner to its proofs. 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 y submitted, FANT Bradley J. Risher (P64608) Attorneys for Respondent, Allendale Twp.
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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: Li 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 were delinquent or underpaid, such that Petitioner is precluded from appealing its property values, and, such that Respondent should be awarded damages. 7 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 affirm the 2025 assessed and taxable values as determined by Respondent, to dismiss the Petition, and award Respondent costs, attorney fees and any other relief that the Tribunal determines is fair, just and equitable. Respe¢tfully submitted, SCHOLTEN FANT Dated: August 18, 2026 By: Bradley J. Fishet¥P64608) Attorneys for Respondent, Allendale Twp.
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS SPC OF WEST MICHIGAN LLC, Petitioner, Docket No. 26-001345 Parcel No. 70-09-24-465-002 V. TOWNSHIP OF ALLENDALE, Respondent. Steve Johnson Representative for Petitioner Bradley J. Fisher (P64608) 436 N. Center Street SCHOLTEN FANT Northville, Michigan 48167 Attorneys for Respondent Phone: (248) 392-4342 100 N. Third St. PO BOX 454 info@mitaxappeal.com Grand Haven, MI 49417 Phone: (616) 842-3030 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 thereon fully prepaid. Dated: August 18, 2026 nerly Tapp Legal Assistant to Bradley J. Fisher