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26-000449.pdf

Conrad Group LLC Petitioner Vs. City Of Farmington Hills Respondent · 26-000449-TT

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Page 1

on 

RECEIVED 

1153.9 2076 

STATE OF MICHIGAN 

SUCHET ATTRIB 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

CONRAD GROUP LLC 

Petitioner 

v 

MOAHR Docket 26-000449 

Parcel No. 22-23-26-101-019 

CITY OF FARMINGTON HILLS, 

Respondent 

Jennifer Hendrix, MMAQO 

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 to 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

Page 2

MTT Docket # 26-000449 

7. 

Respondent admits the allegations in Paragraph 7. 

8. 

The 2026 values for the property identified above as established by Respondent’s Board 

10. 

11. 

of Review are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

22-23-26-101-019 

$1,040,240 

$520,120 

$520,120 

Respondent contends that the 2026 values for the property identified above are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

22-23-26-101-019 

$1,040,240 

$520,120 

$520,120 

The 2026 values in dispute for the property identified above are: 

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

22-23-26-101-019 

$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. 

Dated: 

Ni 177 [26 

OFFICE OF THE CITY ASSESSOR

Page 3

MTT Docket # 26-000449 

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 

Respondent's 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

Page 4

MTT Docket # 26-000449 

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 Respondents 

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. 

I: 

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 value 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 

to 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 

CITY OF FARMINGTON HILLS 

Dated: T2728 

By: 

Ads oudie vy 

Jenhifer Hendtix, MMAO 

City Assessor, Farmington Hills 

31555 West Eleven Mile Rd 

Farmington Hills, MI 48336

Page 5

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

CONRAD GROUP LLC 

Petitioner(s) 

) 

MICHIGAN TAX TRIBUNAL 

Y 

MTT Docket No. 26-000449 

CITY OF FARMINGTON HILLS 

Respondent(s) 

PROOF OF SERVICE 

JENNIFER HENDRIX 

states that on al) 2ly 

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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