Full record / St. Joseph - Whirlpool Tax - Appearance and Answer (2025) (8.15.25) final.pdf

St. Joseph - Whirlpool Tax - Appearance and Answer (2025) (8.15.25) final.pdf

Whirlpool Corporation, Petitioner Vs. City Of St Joseph, Respondent · 25-001963-TT

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Page 1

STATE OF MICHIGAN 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

WHIRLPOOL CORPORATION, 

Petitioner, 

v 

CITY OF ST. JOSEPH, 

Respondent. 

 

 

MTT Docket No. 25-001963 

PPN: 76-0013-0034-16-9 

 

 

 

 

 

 

 

 

 

/ 

 

 

Michelle (Mikki) M. Silvey (P69494) 

Derik Edwards 

Aaron Stout 

DUCHARME, MCMILLEN & ASSOC, INC. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 596-3260, ext. 2404 

msilvey@dmainc.com 

dedwards@dmainc.com 

astout@dmainc.com 

 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9343 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

/ 

 

 

 

APPEARANCE 

NOW COMES attorney Toby Koenig, of the law firm of Bloom Sluggett, PC and hereby 

enters his appearance on behalf of Respondent in this matter. 

 

 

 

 

Dated: August 15, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340

Page 2

2 

 

4906-8098-2367, v. 1 

STATE OF MICHIGAN 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

WHIRLPOOL CORPORATION, 

Petitioner, 

v 

CITY OF ST. JOSEPH, 

Respondent. 

 

 

MTT Docket No. 25-001963 

PPN: 76-0013-0034-16-9 

 

 

 

 

 

 

 

 

 

/ 

 

 

Michelle (Mikki) M. Silvey (P69494) 

Derik Edwards 

Aaron Stout 

DUCHARME, MCMILLEN & ASSOC, INC. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

(317) 596-3260, ext. 2404 

msilvey@dmainc.com 

dedwards@dmainc.com 

astout@dmainc.com 

 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9343 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

/ 

 

 

 

RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

NOW COMES Respondent through its attorneys Bloom Sluggett, PC, and hereby submits 

its Answer to Petition and Affirmative Defenses as follows: 

1. Admitted. 

 

2. Admitted. 

 

3. Admitted. 

 

4. Admitted. 

 

5. Admitted. 

 

6. Admitted. 

 

7. Admitted.

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3 

 

4906-8098-2367, v. 1 

8. Admitted. 

 

9. Admitted. 

 

10. Respondent lacks sufficient knowledge or information to form a belief as to the 

truthfulness of the allegations in paragraph 10 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

11. This paragraph contains a restatement of Petitioner’s claim to which no response is 

required. To the extent a response is required, Respondent admits that Petitioner alleges 

issues relating to valuation, assessment, taxable value, and uniformity, but Respondent 

denies that the subject property is improperly assessed and denies that Petitioner is 

entitled to any relief. 

 

12. Admitted. 

 

13. Respondent denies the values alleged in Paragraph 13 of Petitioner’s Petition as the 

correct Roll Values are as follows: True Cash Value: $5,547,400; Assessed Value: 

$2,773,700; Taxable Value: $2,647,409. 

 

14. Denied as untrue. 

 

15. Denied as untrue as the values alleged are based on incorrect calculations involving the 

Roll Values for the subject property. 

 

16. Denied as untrue. 

 

AFFIRMATIVE DEFENSES 

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

2. Petitioner’s claims against Respondent are barred because the valuation methods used 

by Respondent comply with the Constitution, state law, and prevailing State Tax Commission 

procedures. 

 

3. Respondent’s assessment reflects 50% of the subject property’s true cash value, and 

the values on the roll, including the taxable value, comply with the General Property Tax Act. 

 

4. Petitioner has failed to allege facts to support standing to bring this appeal or that it is 

a proper party-in-interest. 

 

5. Petitioner has failed to allege facts to support its allegation that the taxable value of the 

subject property is improper. 

 

6. Respondent reserves the right to identify further affirmative defenses as may become 

known through discovery.

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4 

 

4906-8098-2367, v. 1 

WHEREFORE, Respondent requests that the Tribunal dismiss Petitioner’s petition with 

prejudice and award Respondent its costs, attorney fees, and all such further and additional relief 

as this Tribunal may deem appropriate. 

 

 

 

 

 

 

 

Dated: August 15, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent 

 

 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom 

Sluggett, PC, and that on August 15, 2025, she served a copy of Respondent’s Appearance and 

Respondent’s Answer to Petition with Affirmative Defenses by First Class and electronic mail 

upon: 

 

Michelle (Mikki) M. Silvey 

Derik Edwards 

Aaron Stout 

DUCHARME, MCMILLEN & ASSOC, INC. 

9229 Delegates Row, Suite 375 

Indianapolis, IN 46240 

msilvey@dmainc.com 

dedwards@dmainc.com 

astout@dmainc.com 

 

 

 

 

 

 

 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 Tonya Voakes

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