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26-000571.pdf

Fh Hotels Inc Petitioner Vs. City Of Farmington Hills Respondent · 26-000571-TT

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Page 1

RECEIVED 

AUG 24 2026 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

IGAN TAX TRiguna, 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

FH HOTELS INC 

Petitioner 

: 

v 

: 

MOAHR Docket 26-000571-TT 

- 

Parcel No. 22-23-14-101-039 

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. 

Asto Paragraph 1, Respondent admits the allegations. 

2. 

As to Paragraph 2, Respondent admits the allegations. 

3. 

As to Paragraph 3, no response is required as no allegations have been made. 

4. 

As to Paragraph 4, no response is required as no allegations have been made. 

5. 

As to Paragraph 5, no response is required as no allegations have been made.

Page 2

MTT Docket # 26-000571 

8. 

9. 

10. 

il. 

12. 

13. 

14, 

15. 

16. 

17. 

18. 

As to Paragraph 8, no response is required as no allegations have been made. No March 

Board of Review was filed. 

As to Paragraph 9, no response is required as no allegations have been made. 

As to Paragraph 10, Respondent admits the allegations. 

As to Paragraph 11, Respondent admits the allegations. 

As to Paragraph 12, Respondent neither admits nor denies the allegations contained 

therein, lacking knowledge or information sufficient to form a belief as to the truth of the 

allegations and, therefore, leaves Petitioner to its proofs. The mailing address of record 

is 994 Saint James Park Ave, Monroe, MI 48161. 

As to Paragraph 13, Respondent neither admits nor denies the allegations. 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 leaves Petitioner to their 

strictest proofs. 

As to Paragraph 14, Respondent admits the allegations. 

As to Paragraph 15, no response is required as no allegations have been made. 

As to Paragraph 16, Respondent admits the allegations. 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 

$5,120,780 

$2,560,390 

$2,560,390 

As to paragraph 17, Respondent denies that Petitioner's values for the subject property 

are accurate or frue. 

As to Paragraph 18, Respondent neither admits nor denies the allegations contained

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MTT Docket # 26-000571 

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 leaves Petitioner to its proofs. 

WHEREFORE, Respondent CITY OF FARMINGTON HILLS 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 costs and attorney fees. 

OFFICE OF THE CITY ASSESSOR 

Dated: 

5 J 27 

TE OF 

Ns dos 

= pe MMAO 

City Assessor, Farmington Hills 

31555 West Eleven Mile Rd 

Farmington Hills, MI 48336 

(248) 871-2479 

jhendrix@fhgov.com

Page 4

MTT Docket # 26-000571 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent CITY OF FARMINGTON HILLS will 

rely on the following affirmative defenses: 

1. 

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, 

2. 

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). 

3. 

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). 

4. 

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. 

5. 

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’ taxing unit for the tax year in questions. 

6. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

7. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject propetty, 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 5

MTT Docket # 26-000571 

9. 

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. 

10. 

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. 

11. 

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. 

12. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

13. 

Respondent reserves the right to add affirmative defenses which may become 

known during the course of informal or formal discovery proceedings. 

14. 

Respondent objects to the extent Petitioner lacks standing to bring this Petition. 

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: 

Shjz¢ 

Lad Loli 

Jennifer Hendrix, MMAO 

City Assessor, Farmington Hills 

31555 West Eleven Mile Rd

Page 6

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LAINE 

DIRECTOR 

FH HOTELS INC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 26-000571 

CITY OF FARMINGTON HILLS 

, 

Respondent(s) 

PROOF OF SERVICE 

JENNIFER HENDRIX 

states that on AUGUST 11, 2026 

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 

PETER ELLENSON 

30500 NORTHWESTERN HWY, STE 500 

FARMINGTON HILLS, MI 48334 

Li will ny 

[Signature of person who is serving/mailing copy] 

JENNIFER HENDRIX, MMAO 

[Print/type name of person serving/mailing copy]

Page 7

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