26-000450.pdf
Conrad Group LLC Petitioner Vs. City Of Farmington Hills Respondent · 26-000450-TT
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RECEIVED JUL 2 92025 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIR$ICHIGAN TAX TRIBUNAL MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES MICHIGAN TAX TRIBUNAL CONRAD GROUP LIL.C Petitioner v MOAHR Docket 26-000450 Parcel No. 22-23-15-201-270 CITY OF FARMINGTON HILLS, Respondent Jennifer Hendrix, MMAO City Assessor 31555 West Eleven Mile Rd Farmington Hills, MI 48336 (248) 871-2479 jhendrix@fhgov.com RESPONDENT’S ANSWER TO PETITIONER’S PETITION AND AFFIRMATIVE DEFENSES RESPONDENT, the City of Farmington Hills, through its Assessor, Jennifer Hendrix, hereby responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent admits the allegations in Paragraph 1. 2. Petitioner has not set forth any allegations fo warrant a response. No March Board of Review was filed. 3. Respondent admits the allegations in Paragraph 3. 4. Respondent lacks the information and knowledge necessary to respond to the allegations in Paragraph 4. The owner of record is 31525 Building LLC, which was transferred from
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MTT Docket # 26-000450 6. Respondent neither admits nor denies the allegations in Paragraph 6 for reason that they do not have sufficient knowledge to for a belief as to the truth of the allegations and leaving Petitioner to their strictest proofs. 10. 11. Respondent admits the allegations in Paragraph 7. . The 2026 values for the property identified above as established by Respondent’s Board of Review are: Parcel Number True Cash Value | Assessed Value Taxable Value 22-23-15-201-270 $6,572,200 $3,286,100 $3,286,100 Respondent contends that the 2026 values for the property identified above are: Parcel Number True Cash Value Assessed Value Taxable Value 22-23-15-201-270 $6,572,200 $3,286,100 $3,286,100 The 2026 values in dispute for the property identified above are: Parcel Number True Cash Value | Assessed Value | Taxable Value 22-23-15-201-270 $0 $0 $0 Respondent denies the allegations in Paragraph 11 for the reason that it is 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 constitutional. Further, the subject property did not have any “additions” or “losses” for the 2026 tax year and leaving Petitioner to their strictest proofs. WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal dismiss the Petition; affirm Respondent’s assessed and taxable values, subject to county and state equalization., and award Respondent its cost and attorney fees.
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MTT Docket # 26-000450 Dated: / / bd 7 zl OFFICE et THE CITY ASSESSOR Re) OF F INGTON HILLS N onde ft: rrr “MMAO City Assessor, Farmington Hills 31555 West Eleven Mile Rd Farmington Hills, MI 48336 (248) 871-2479 jhendrix@fhgov.com
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MTT Docket # 26-000450 AFFIRMATIVE DEFENSES PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the following affirmative defenses: A. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against the Respondent and to support Petitioner’s claim for relief. B. The Tribunal is charged with finding a property’s true cash value to determine the property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). C. 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). B. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, and application of wrong principles or illegality on the part of the Respondent or its agents. C. Petitioner fails to allege the mode and method of assessing the subject property failed to conform to the mode and method applied in the case of all properties within the Respondents taxing unit for the tax year in questions. D. Petitioner fails to allege specific and sufficient facts needed to establish the true cash value, assessed and taxable value for the subject property. E. Petitioner fails to allege specific and sufficient facts to support its allegations that the assessed value of the subject property, as equalized, is at a level other than 50% and it also fails to allege specific and sufficient facts to support its allegations that the subject property’s
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MTT Docket # 26-000450 G. Petitioner asks this Tribunal to grant it illegal preference by application of a method of assessment different from that utilized in the assessment of other properties in the Respondent’s taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. H. 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. IL 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. J. Respondent has properly and lawfully assessed Petitioner’s property and established its taxable alia in accordance with statutory and constitutional requirements. K. Respondent reserves the right to add affirmative defenses which may become known during the course of informal or formal discovery proceedings. WHEREFORE, Respondent denies that the Petitioner is entitled 0 any relief and respectfully requests that the Respondent’s assessed and taxable values for the year under appeal be affirmed and the Petitioner’s Petition be dismissed with prejudice and that the Respondent be granted all attorney fees and cost wrongfully sustained. OFFICE OF THE CITY ASSESSOR ILLS Z Zz CITY OF FARMINGTON H Dated: a4 27) . Londo budinsy Jennifer Hendrix, MMAO City Assessor, Farmington Hills 31555 West Eleven Mile Rd Farmington Hills, MI 48336 (248) 871-2479
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STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR CONRAD GROUP LLC ; MICHIGAN TAX TRIBUNAL Petitioner(s) v MTT Docket No. 26-000450 CITY OF FARMINGTON HILLS , Respondent(s) PROOF OF SERVICE JENNIFER HENDRIX states that on 7)7[ 2 he/she [Name of person serving/mailing petition] [date of service] served a copy of the ANSWER relative to the above-captioned matter upon: [Provide name and address of the party/people being served] MTT P.O. BOX 30232, LANSING MI 48909 AND LAURA M HALLAHAN 1750 S TELEGRAPH RD, STE 202 BLOOMFIELD HILLS, MI 48302-0179 [Signature of petson who is serving/mailing copy] JENNIFER HENDRIX, MMAO [Print/type name of person serving/mailing copy]
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FARMINGTON A City of Farmington Hills Finance Department Assessing Division 31555 West Eleven Mile Road Farmington Hills, MI 48336 METROPI EX MTT P.O. BOX 30232 LANSING, M1 48909 Ag —— | 2p 42038 $001.07" i 0008042865 JUL 27 2026