City's Response to Petition - WF 301 LLC - 26-001064.pdf
Wf 301 LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001064-TT
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STATE OF MCHIGAN MICHIGAN TAX TRIBUNAL WF 301 LLC, Petitioner, V City of Ann Arbor, Respondent. MTT Docket No. 26-001064 Joshua T. Shillair (P72674) COLLIERS INTERNATIONAL Attorney for Petitioner 400 W. 4th Street, Suite 350 Royal Oak, Michigan 48067 (248) 226-1632 joshua.shillair@colliers.com John W. Reiser (P45050) OFFICE OF THE CITY ATTORNEY Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org RESPONDENT CITY OF ANN ARBOR’S RESPONSE TO PETITION Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City Attorney’s Office, responds in opposition to the Petition of WF 301 LLC (“Petitioner”) as follows: 1. Respondent leaves Petitioner to its proofs. 2. Admit. 3. Admit. 4. Respondent leaves Petitioner to its proofs. 5. Respondent leaves Petitioner to its proofs. 6. Admit. 7. Respondent leaves Petitioner to its proofs as to (a) through (d).
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2 8. Admit. 9. Respondent denies Petitioner’s stated True Cash Value and Assessed Value as untrue. The correct values as established by the Board of Review are as follows: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 09-09-29-211-001 $3,692,600 $3,751,600 $1,846,300 $1,875,800 $1,331,608 Respondent admits the remainder of this allegation. 10. Respondent leaves Petitioner to its proofs and further denies the allegations in sub-paragraphs a. through d. as untrue. 11. Respondent leaves Petitioner to its proofs. 12. Respondent leaves Petitioner to its proofs. 13. Respondent leaves Petitioner to its proofs. For the reasons stated above, Respondent requests that the Tribunal deny Petitioner’s request and affirm its 2026 assessed and taxable values. Dated: August 24, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org
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3 AFFIRMATIVE DEFENSES Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City Attorney’s Office, and for its Affirmative Defenses to the Petition of WF 301 LLC (“Petitioner”), states the following: 1. Respondent reserves the right to raise affirmative defenses as the same become apparent in the court of this litigation. Dated: August 24, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org PROOF OF SERVICE I hereby certify that on August 24, 2026, I emailed a true and correct copy of the foregoing Response to Petition and Affirmative Defenses to the above-named attorney for petitioner at the address listed above. /s/ Dawn M. Bagozzi Legal Assistant