Answer_DENSO 2026_FINAL.pdf
Denso International America Inc Petitioner Vs. City Of Southfield Respondent · 26-000133-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Denso International America, Inc. Petitioner, v City of Southfield, Respondent. MTT Docket No. 26-000133 Parcel No. 76-24-20-326-228 _____________________________________________________________________________/ JACKIE J. COOK (P68781) HONIGMAN LLP Attorney for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226 (313) 465-7270 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ ANSWER TO PETITION AND AFFIRMATIVE DEFENSES ANSWER Respondent, City of Southfield, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent lacks the information and knowledge necessary to respond to the truth of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 2. Respondent admits that the listed parcel corresponds to the stated address. 3. Respondent lacks the information and knowledge necessary to respond to the truth of the allegations set forth in Paragraph 3 and, therefore, leaves Petitioner to its proofs.
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2 4. Respondent can neither admit nor deny the allegations set forth in Paragraph 4 as standing is a legal matter that can only be resolved by the Tribunal. 5. Respondent objects as the paragraph is vague as to the date to which it corresponds. Subject to and without waiving the objection, Respondent admits that for the 2026 tax year the identified parcel is classified as commercial improved per Respondent’s assessment records. 6. Respondent lacks the information and knowledge necessary to respond to the truth of the allegations set forth in Paragraph 6 as said allegation is vague as “commercial uses” has not been defined and could be read in multiple ways. 7. Respondent restates its response to Paragraph 6 herein. 8. Respondent objects as the paragraph is vague as to the date to which it corresponds. Subject to and without waiving the objection, Respondent admits that for the 2026 assessment the property is within the Southfield Public School District. 9. Respondent objects as the paragraph is vague as to the date to which it corresponds. Subject to and without waiving the objection, Respondent admits the allegations as to the 2026 tax year. 10. Respondent objects as the paragraph is vague as to the date and tax year to which it corresponds. Subject to and without waiving said objection, Respondent acknowledges the matter identified to be at issue by Petitioner but denies Petitioner’s allegations have merit. 11. Respondent objects as the paragraph is vague as to the date and tax year to which it corresponds. Subject to and without waiving said objections, Respondent neither admits nor denies the allegations set forth in Paragraph 11 and leaves Petitioner to its proofs.
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3 12. Respondent objects as the paragraph is vague as to the date and tax year to which it corresponds. Subject to and without waiving said objections, Respondent neither admits nor denies the allegations set forth in Paragraph 12 and leaves Petitioner to its proofs. 13. Respondent objects as the paragraph is vague as to the date and tax year to which it corresponds. Subject to and without waiving said objections, Respondent neither admits nor denies the allegations set forth in Paragraph 13 and leaves Petitioner to its proofs. 14. Respondent objects as the paragraph is vague as to the date and tax year to which it corresponds. Subject to and without waiving said objections, Respondent denies the allegations in Paragraph 14 as untrue based on the determination rendered in STC Matter No. 154-2022- 0633. 15. Respondent objects as the paragraph is vague as to the date and tax year to which it corresponds. Subject to and without waiving said objections, Respondent neither admits nor denies the allegations set forth in Paragraph 15 and leaves Petitioner to its proofs. 16. Respondent acknowledges Petitioner’s attachment of certain tax bills to its Petition as well as Petitioner’s belief of “mistakes” contained with said bill. Upon information and belief, Respondent denies any mistake with said bills. Moreover, Respondent denies any implication that it is the entity responsible for said contested bills. Said bills clearly indicate they were issued by Oakland County. 17. Respondent neither admits nor denies the allegations in Paragraph 17 as the contested tax bills and Petitioner’s Petition speak for themselves.
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4 18. Respondent admits valuation has not been identified at issue. Respondent neither admits nor denies the remainder of the allegations set forth in Paragraph 18 as Petitioner’s Petition speak for itself. 19. Respondent neither admits nor denies the allegations in Paragraph 19 as MCL 205.735a(6) speaks for itself and jurisdiction is a legal matter for the Tribunal to determine. However, based on proceeding allegations, Petitioner’s Petition appears to be a protest of taxable value rather than of “arithmetic errors or mistakes.” To the extent Petitioner implies the Tribunal has jurisdiction over the subject property’s 2024 and 2025 taxable values, Respondent denies such allegations as untrue. 20. Respondent objects as the paragraph is vague as to what the phrase “original taxable values” refers. Subject to and without waiving said objection, Respondent denies the values set forth by Petitioner in Paragraph 20 constitute the correct taxable values for the subject property for the 2024 and 2025 tax years. 21. Based on Respondent’s assessment records, Respondent admits that the subject property’s 2024 taxable value is $14,442,223. Based on Respondent’s assessment records, Respondent admits that the subject property’s 2025 taxable value is $14,886,932. Respondent denies that it was a mistake to base the subject property’s tax bills on the aforementioned taxable values. 22. Respondent denies any implication that it is the entity responsible for the contested tax bills. Upon information and belief, Respondent denies any mistake with the contested tax bills. Respondent confirms that the subject property’s 2024 tax bill should be premised on a taxable value of $14,442,223 and that the subject property’s 2025 tax bill should be premised on a taxable value of $14,889,932.
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5 23. Respondent denies the allegations in Paragraph 23 as untrue for Petitioner has failed to identify any mistake in the contested tax bills. 24. Respondent denies any implication that the Tribunal has jurisdiction over the subject property’s 2024 and 2025 taxable values under MCL 205.735a(6). Accordingly, Respondent denies any taxable value as being in contention. 25. Respondent neither admits nor denies the allegations in Paragraph 25 as MCL 205.731(a) speaks for itself. Respondent denies the Tribunal has jurisdiction over the subject property’s 2024 and 2025 taxable values for the reasons set forth in MCL 205.735a(6). 26. Respondent denies the allegations in Paragraph 26 as untrue. Under MCL 205.735a(6), the Tribunal’s jurisdiction “is limited solely to correcting arithmetic errors or mistakes” in the contested tax bills—not resolving disputes regarding the subject property’s taxable value. 27. Respondent denies the Tribunal has jurisdiction to revise the subject property’s 2024 and 2025 taxable values. Respondent further denies the presence of a mistake in the contested tax bills. 28. Respondent denies it has unlawfully collected property taxes from Petitioner. Respondent further denies that the Tribunal has jurisdiction to grant Petitioner the relief it seeks. 29. Respondent denies the allegations in Paragraph 29, including subsections (a)-(d), for the reason that the same are 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, the values and Respondent’s mode of assessment are non-discriminatory and
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6 constitutional, and Petitioner has failed to identify any mistake in the tax bills identified to be at issue. 30. Respondent acknowledges the relief requested by Petitioner in the final paragraph of its Petition but denies that Petitioner is entitled to said relief for the reasons set forth above. WHEREFORE, Respondent, City of Southfield, requests the Tribunal dismiss the Petition, affirm the subject property’s 2024 and 2025 tax bills, and award Respondent its costs and attorney fees. HALLAHAN & ASSOCIATES, P.C. /s/Kelsea M. Melcher_____________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 Dated: May 7, 2026 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent, City of Southfield, asserts the following affirmative defenses: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. 2. Petitioner asks the Tribunal to grant it preference by application of a self-chosen method of assessment contrary to the intent, purpose and law of this State. 3. Petitioner, in essence, asks the Tribunal to grant it an illegal preference by application of laws different from that employed in the assessment of other properties in Respondent’s taxing unit.
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7 4. Petitioner has failed to pursue its appeal in a timely fashion. 5. Respondent reserves the right to raise additional affirmative defenses as the same may become known to it during the course of these proceedings. HALLAHAN & ASSOCIATES, P.C. /s/Kelsea M. Melcher_____________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 Dated: May 7, 2026 (248) 731-3089 PROOF OF MAILING On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to Petition and Affirmative Defenses to: Jackie J. Cook Honigman LLP jcook@honigman.com I declare that the statement above is true to the best of my information, knowledge and belief. /s/ Kelsea M. Melcher_______________ Dated: May 7, 2026 Kelsea M. Melcher