26-000746 ANSWER09927220260720130716.pdf

Tsfr Apple Venture, LLC Petitioner Vs. City Of Sturgis Respondent · 26-000746-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TSFR APPLE VENTURE, LLC, 

Petitioner, 

MOAHR Docket No. 26-000746-TT 

\% 

CITY OF STURGIS, 

Respondent. 

Jerome P. Pesick (P29039) 

Robert E. Thall (P46421) 

Jason C. Long (P59244) 

Bauckham, Thall, Seeber, 

Williams, Williams, Rattner 

Kaufman & Koches, P.C. 

& Plunkett, PC 

Attorney for Respondent 

Attorneys for Petitioner 

470 W. Centre Ave., Suite A 

380 N. Old Woodward Ave., Ste. 300 

Portage, MI 49024-5362 

Birmingham, MI 48009 

269-382-4500 

(248) 642-0333 

thall@michigantownshiplaw.com 

ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES 

Respondent, City of Sturgis, states the following in response to the respective paragraphs 

of the Petition filed in this matter: 

1. 

In answer 

to paragraph 

1 

of the Petition, Respondent admits the allegations 

therein. 

2. 

In answer to paragraph 

2 

of the Petition, Respondent admits the allegations 

therein.

4. 

In answer to paragraph 

4 

of the Petition, Respondent admits the allegations 

therein. 

S. 

In answer 

to paragraph 

5 

of the Petition, Respondent admits the allegations 

therein. 

6. 

In answer 

to paragraph 

6 

of the Petition, Respondent admits the allegations 

therein. 

7. 

In answer to paragraph 

7 of the Petition, Respondent admits the allegations 

therein. 

8. 

In answer 

to paragraph 

8 

of the Petition, Respondent denies the Petitioner’s 

values for the property as untrue. 

9. 

In answer to paragraph 9 of the Petition, Respondent admits the allegation therein. 

10. 

In answer to paragraph 

10 of the Petition, Respondent admits the allegations 

therein. 

11. 

In answer 

to paragraph 

11 

of the Petition, Respondent denies the allegation 

therein as untrue. 

12. 

In answer to paragraph 

12 

of the Petition, Respondent denies the allegation 

therein regarding overestimating the values as untrue. 

WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying 

the relief requested by Petitioner and uphold and affirm the valuations as established by the

1. 

Petitioner has failed to state a claim upon which relief may be granted. 

2. 

The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 

3. 

The service of process was insufficient. 

4. 

The subject property 

is under assessed and/or the taxable value and/or state 

equalized value of the subject property 

is too low, and should therefore be appropriately 

increased to comply with the mandate of the applicable provisions of law. 

S. 

Respondent reserves the right to file such additional affirmative defenses as may 

become apparent pursuant to discovery procedures during the pendency of this matter. 

WHEREFORE Respondent requests that the Tribunal enter a determination of no cause 

in its favor, and such other and further relief as is appropriate including costs and attorney fees. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMAN & K 

ES, P. 

J 

Date: July 20, 2026 

A 

By: 

ps 

Rébert E. Thall, Attorney for Respondent

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