Answer to Petition (940 ROCHESTER LLC) (09.24.2026).pdf
940 Rochester LLC Petitioner Vs. City Of Rochester Hills Respondent · 26-001473-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS SYSTEM AND RULES MICHIGAN TAX TRIBUNAL 940 ROCHESTER LLC, Petitioner, v CITY OF ROCHESTER HILLS, Respondent. MTT Docket No. 26-001473 Parcel No. 70-15-15-476-011 _____________________________________________________________________________/ Colliers International Joshua T. Shillar (P72674) Representative for Petitioner 400 W. 4th Street, Suite 350 Royal Oak, MI 48067 (248) 226-1632 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com P. DANIEL CHRIST (P45080) HAFELI STARAN & CHRIST, P.C. Attorney for Respondent 2055 Orchard Lake Road Sylvan Lake, MI 48320-1746 (248) 731-3085 (248) 227-5421 (cell) dchrist@hsc-law.com _____________________________________________________________________________/ ANSWER TO PETITION Respondent City of Rochester Hills, through its City Attorney, P. Daniel Christ, responds to the allegations made in the Petition, as follows: 1. Respondent lacks knowledge or information sufficient to form a belief as to the truth of the allegation. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted.
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2 7. No response is required because no allegations are set forth. 8. Admitted. 9. Admitted, except as to the Assessed Value which was $278,230.00 for tax year 2026. 10. Respondent denies the allegations contained in Paragraph 11, as Respondent’s assessed, state equalized and taxable values and the corresponding taxes are valid. (a) Respondent denies the allegations contained in subparagraph (a), as Respondent submits the assessed, state equalized and taxable values do not exceed permitted amounts. (b) Respondent denies the allegations contained in subparagraph (b), as Respondent’s assessed, state equalized and taxable values do not exceed the percentage of true cash value permitted by law. (c) Respondent denies the allegations contained in subparagraph (c), as Respondent’s assessed, state equalized and taxable values were correctly determined and are based upon proper application of proper principles. (d) Respondent denies the allegations contained in subparagraph (d), as Respondent’s assessed, taxable and state equalized values are non-discriminatory and conform to uniformity, equal protection and due process requirements. 11. Respondent acknowledges Petitioner’s contentions of values, but denies that Petitioner’s contentions of values is correct. 12. Respondent acknowledges the values in dispute, but Respondent denies that Petitioner’s contentions of values is correct. 13. Respondent denies the allegations contained in Paragraph 13, as Respondent’s assessed and taxable values and the corresponding taxes are valid.
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3 WHEREFORE, Respondent City of Rochester Hills requests the Tribunal to dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. /s/P. Daniel Christ P. DANIEL CHRIST (P45080) HAFELI STARAN & CHRIST, P.C. Attorneys for Respondent 2055 Orchard Lake Road Sylvan Lake, MI 48320 (248) 731-3085 Dated: September 24, 2026 PROOF OF SERVICE On the date below, I sent by first class mail and email a copy of the foregoing Answer to Petition to: Joshua T. Shillar (P72674) Representative for Petitioner 400 W. 4th Street, Suite 350 Royal Oak, MI 48067 Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com I declare that the statement above is true to the best of my information, knowledge, and belief. /s/P. Daniel Christ P. Daniel Christ Dated: September 24, 2026