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Answer.pdf

Pnc Bank, National Association Petitioner Vs. Township Of Texas Respondent · 26-000728-TT

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Page 1

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

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