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25-002276.pdf

Target Corporation, Petitioner Vs. Township Of Clinton, Respondent · 25-002276-TT

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Page 1

RECEIVED 

AUG 1 8 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

TARGET CORPORATION, 

Petitioner, 

Docket No. 25-002276 

v 

Parcel No. 16-11-34-328-004 

CLINTON TOWNSHIP, 

Respondent. 

/ 

MICHAEL B. SHAPIRO (P20282) 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA A. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, M1 48302 

(248) 731-3089 

ANSWER TO PETITION 

AFFIRMATIVE DEFENSES 

ANSWER 

Respondent, Clinton Township, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent neither admits nor denies the allegations set forth in Paragraph 

1 as 

Petitioner’s Petition and the Tribunal’s Order speak for themselves. 

2. 

Respondent lacks the information and knowledge necessary to respond to the truth 

of the allegations set forth in Paragraph 2 and, therefore, leaves Petitioner to its proofs.

Page 2

4. 

Respondent admits the allegations in Paragraph 4 to the extent it is the entity that 

assesses and collects property taxes with relation to the parcel identified in the Petition. 

S. 

Respondent admits the allegations in Paragraph 5 as to the stated values. 

6. 

Respondent admits the allegations in Paragraph 6 as to the stated classification. 

7. 

Upon information and belief, Respondent admits the allegations in Paragraph 7. 

8. 

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

truth of the allegations contained in Paragraph 8 and, therefore, leaves Petitioner to its proofs. 

9. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 9 but denies 

Petitioner’s claims have merit and further denies Petitioner is entitled to any relief. 

10. 

Respondent acknowledges Petitioner’s belief of a dispute relative to the value of a 

loss but denies that such a loss has occurred. 

11. 

Respondent neither admits nor denies the allegations in Paragraph 11 as the General 

Property Tax Act speaks for itself. 

12. 

Respondent denies the allegations in Paragraph 12, including subparagraphs (a)- 

(d), for the reason that the same are untrue. 

In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional. 

13. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in

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WHEREFORE, Respondent, Clinton Township, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

_/s/Laura M, Hallahan 

LAURA M. HALLAHAN (P42101) 

SETH A. O'LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 11, 2025 

(248) 731-3089 

AFFIRMATIVE DEFENSES 

Respondent, Clinton Township, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alki Development Cov Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. 

See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents.

Page 4

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as 

all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, 

in essence, 

asks 

the Tribunal 

to grant 

it 

an 

illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

13. 

Respondent reserves the right to raise additional affirmative defenses as the same 

may become known to it during the course of these proceedings.

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HALLAHAN & ASSOCIATES, P.C. 

/s/ Laura M. Hallahan 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Date: August 11,2025 

(248) 731-3089 

PROOF OF MAILING 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to Petition 

and Affirmative Defenses to: 

Michael B. Shapiro 

Honigman LLP 

mshapiro@honigman.com 

Jackie J. Cook 

Honigman LLP 

jeook@honigman.com 

I declare that the statement above is true to the best of my information, knowledge and belief. 

/s/Kelsea M. Melcher 

Dated: August 11,2025 

Kelsea M. Melcher

Page 6

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HALLAHAN & ASSOCIATES, P.C. 

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1750 S. Telegraph Road, Suite 202 

METROPLEX MI 480 

US 

Bloomfield Hills, Michigan 48302 

Fe ho EI uh 

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B02810.02 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909

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