M.R. Non Profit Housing Corporations MTT# 26-000948 answer & affirmative defenses.pdf
M.R. Non-Profit Housing Corporation Petitioner Vs. City Of Detroit Respondent · 26-000948-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL M.R. NON-PROFIT HOUSING CORPORATION, Petitioner, v. Docket No. 26-000948 CITY OF DETROIT, Respondent. ________________________________/ ANSWER NOW COMES RESPONDENT, CITY OF DETROIT, by and through its undersigned counsel, and in Answer to the Petition filed in this matter states as follows: 1. Respondent denies as untrue. The parcel number is 03003239 and not 0300-3239. The placement of a hyphen in the middle of the parcel number designates a parcel which does not exist. 2. Respondent admits. 3. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 4. Respondent admits. 5. No response necessary. 6. Respondent admits. 7. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 8. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation.
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2 9. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 10. Respondent admits. 11. Respondent admits. 12. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 13. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues involving the subject property’s exemption from ad valorem taxation; however, Respondent denies that any such allegations have merit. 14. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 15. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 16. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 17. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 18. . Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation. 19. Request for relief no response necessary. 20. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation.
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3 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. 4. This Tribunal lacks subject matter jurisdiction. 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, /s/ Kevin C. Richard Kevin C. Richard (P43417) Mary Beth Cobbs (P40080) City of Detroit Law Department Coleman A. Young Municipal Center 2 Woodward Avenue, Suite 500 Detroit, Michigan 48226 (313) 237-3061 Dated: October 12, 2026
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4 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL M.R. NON-PROFIT HOUSING CORPORATION, Petitioner, v. Docket No. 26-000948 CITY OF DETROIT, Respondent. ________________________________/ PROOF OF SERVICE On October 12, 2026, I sent by Email a copy of Respondent’s Answer w/Affirmative Defenses in the instant matter to: Darwyn P. Fair dpfair@dpfairlaw.com 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) Senior Assistant Corporation Counsel City of Detroit Law Department Coleman A. Young Municipal Center 2 Woodward Avenue, Suite 500 Dated: October 12, 2026 Detroit, Michigan 48226