Executed Answer and Affirmative Defenses.pdf
Troy Tech Sf Owner LLC Petitioner Vs. City Of Troy Respondent · 26-001663-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL TROY TECH SF OWNER, LLC, Petitioner, MTT Docket: 26-001663 Vv Parcel ID 88-20-35-226-087 CITY OF TROY, Respondent. / JOHN-PAUL WOLFE LORI GRIGG BLUHM (P46908) FRIEDMAN REAL ESTATE JULIE QUINLAN DUFRANE (P59000) Representative for Petitioner TROY CITY ATTORNEY'S OFFICE 34975 W. Twelve Mile Road Attorneys for Respondent Farmington Hills, MI 48331 500 W. Big Beaver Road (248) 848-4154 Troy, MI 48084 TaxAppeals@FREG.com (248) 524-3320 BLUHMLG@TROYMI.GOV i RESPONDENT'S EXECUTED ANSWER TO PETITION AND AFFIRMATIVE DEFENSES NOW COMES, Respondent, CITY OF TROY, by and through its attorney, Lori Grigg Bluhm, and for its Answer to Petitioner's Petition, states as follows: 1. As to Paragraph 1, Respondent admits the allegation 2. As to Paragraph 2, Respondent admits the allegation. 3. As to Paragraph 3, no answer is required. 4. As to Paragraph 4, no answer is required.
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8. As to Paragraph 8, no answer is required. 9. As to Paragraph 9, no answer is required. 10. As to Paragraph 10, Respondent admits the allegation. 11. As to Paragraph 11, Respondent admits the allegation. 12. As to Paragraph 12, Respondent neither admits nor denies the allegation, lacking knowledge or information sufficient to form a belief as to the truth of the allegations and therefore and leaves Petitioners to the proofs. 13. As to Paragraph 13, Respondent denies that there are any issues concerning the valuation, assessment, taxable value, due process, equal protection and/or uniformity. 14. As to Paragraph 14, Respondent admits. 15. As to Paragraph 15, no answer is required. 16. As to Paragraph 16, Respondent admits that the Respondent's true cash value, assessed value, and taxable values for the subject property are accurately reflected. 17. As to Paragraph 17, Respondent denies that Petitioner's allegations as to true cash value, state equalized value, and taxable value for the subject property are correct, or that there is any support for these values. 18. As to Paragraph 18, Respondent admits that Petitioner has properly calculated the difference between Petitioner's alleged and Respondent's true cash value, state equalized value, and taxable values for the subject property. Respondent denies that Petitioner's alleged values are correct and can be supported.
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20. As to Paragraph 20, Respondent neither admits nor denies the allegations, since it is without sufficient knowledge, and leaves Petitioner to its proofs. WHEREFORE, Respondent, CITY OF TROY, requests the Tribunal dismiss the Petition, affirm or increase the subject property's assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. Dated: August 27, 2026 CITY OF TROY HL LORI GRIGG BLUHM (P46908) Attorney for Respondent 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BLUHMLG@TROYMI.GOV
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AFFIRMATIVE DEFENSES For its further Answer to Petitioners’ Petition, Respondent relies on the following Affirmative Defenses: 1. Petitioners fail to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. Petitioners fail to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles or illegality on the part of the Respondent or its agents. Petitioners fail to allege specific and sufficient facts to establish the true cash value, assessed value, and taxable value of its property. Petitioners fail to allege specific and sufficient facts to support its allegations that the property's taxable value is improper, or failed to conform with the mode and method applied in the case of all properties in the City of Troy for 2026. 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. Respondent has properly and lawfully assessed Petitioner's property and established its assessed and taxable value in accordance with statutory and constitutional requirements.
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affirmed or increased, that Petitioners’ Petition be dismissed with prejudice, and that Respondent be granted costs and attorney fees so wrongfully sustained. Dated: August 27, 2026 ITY OF TROY WHE LORT GRIGG BLUHM (P46908) Attorney for Respondent 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BLUHMLG@TROYMI.GOV Certificate of Service | hereby certify that on August 27, 2026, | served a copy of this Executed Answer and Affirmative Defenses via email to Petitioner's representative John- Paul Wolfe at TaxAppeals@FREG.com and to the following via first class mail: Michigan Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 49822; Secretary of School Board, Warren Consolidated Public Schools, 31300 Anita Drive, Warren, MI 48093; Director of Equalization; Oakland Pointe Office Building, 250 Elizabeth Lake Road Suite 1000; Pontiac, MI 48341; and Clerk, Oakland County; 1200 N. Telegraph, Building 12 East, Pontiac, MI 48341. Dated: August 27, 2026 Legal Administrative Coordinator