Answer.pdf
Pnc Bank, National Association Petitioner Vs. Township Of Texas Respondent · 26-000728-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL PNC BANK, NATIONAL ASSOCIATION Petitioner, MTT Docket No. 26-000728-TT v TEXAS CHARTER TOWNSHIP, Respondent. Scott Aston Ad Valorem Partners LLC Representative for Petitioner 21446 Columbine Ct. Gross Ile, MI 48138 (734) 731-0558 aston@advalpartners.com Robert E. Thall (P46421) Bauckham, Thall, Seeber, Kaufman & Koches, P.C. Attorney for Respondent 470 W. Centre Ave., Ste. A Portage, MI 49024 (269) 382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, Texas Charter Township, states the following in response to the respective paragraphs of the Petition filed in this matter: 1. In answer to paragraph 1 of the Petition, Respondent admits the allegations therein. 2. In answer to paragraph 2 of the Petition, Respondent admits the allegations therein. 3. In answer to paragraph 3 of the Petition, Respondent admits the allegations therein. 4. In answer to paragraph 4 of the Petition, Respondent admits the allegations therein. 5. In answer to paragraph 5 of the Petition, Respondent admits that Petitioner has raised such issues. 6. In answer to paragraph 6 of the Petition, Respondent admits the allegation therein.
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7. In answer to paragraph 7 of the Petition and its subparts, Respondent denies the allegations therein as untrue. WHEREFORE, Respondent respectfully requests that the Tribunal enter an Order denying the relief requested by Petitioner and uphold and affirm the valuations as established by the Respondent and require Petitioner to pay Respondent’s costs and attorney fees. AFFIRMATIVE DEFENSES Please take notice that Respondent may rely on one or more of the following affirmative defenses: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 3. The service of process was insufficient. 4. The subject property is under assessed and/or the taxable value and/or state equalized value of the subject property is too low, and should therefore be appropriately increased to comply with the mandate of the applicable provisions of law. 5. Respondent reserves the right to file such additional affirmative defenses as may become apparent pursuant to discovery procedures during the pendency of this matter. WHEREFORE Respondent requests that the Tribunal enter a determination of no cause in its favor, and such other and further relief as is appropriate including costs and attorney fees. Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN & KOCHES, P.C. Date: September 24, 2026 By: /s/ Robert E. Thall Robert E. Thall Attorney for Respondent