Full record / Walker - Peng Chang 2 LLC 26-001350 Respondent's App and Answer w Affirm Defs and POS 10-22-26.pdf

Walker - Peng Chang 2 LLC 26-001350 Respondent's App and Answer w Affirm Defs and POS 10-22-26.pdf

Peng Chang 2 LLC Petitioner Vs. City Of Walker Respondent · 26-001350-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

PENG CHANG 2, LLC, 

 

 

Petitioner, 

 

v 

 

CITY OF WALKER, 

 

 

Respondent. 

 

MTT Docket No. 26-001350 

 

Parcel No. 41-13-17-451-050 

 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Steve Johnson 

MICHIGAN TAX APPEAL SERVICES 

Representative for Petitioner 

436 N Center Street 

Northville, MI 48167 

(248) 392-4342 

info@mitaxappeal.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorney for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

/ 

 

 

 

 

RESPONDENT’S APPEARANCE 

NOW COMES attorney Toby Koenig, of the law firm of Bloom Sluggett, PC, and 

hereby enters his appearance on behalf of Respondent City of Walker in this matter. 

 

 

 

Dated: October 22, 2026 

Respectfully submitted by, 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

 

Toby Koenig (P72367) 

Attorneys for Respondents City of Walker

Page 2

2 

 

4908-3158-7801, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

PENG CHANG 2, LLC, 

 

 

Petitioner, 

 

v 

 

CITY OF WALKER, 

 

 

Respondent. 

 

MTT Docket No. 26-001350 

 

Parcel No. 41-13-17-451-050 

 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

Steve Johnson 

MICHIGAN TAX APPEAL SERVICES 

Representative for Petitioner 

436 N Center Street 

Northville, MI 48167 

(248) 392-4342 

info@mitaxappeal.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorney for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

/ 

 

 

 

 

RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

Respondent, City of Walker, through its attorneys, hereby submits this Answer to 

Petitioner’s Petition filed in this matter. 

(1) Admitted. 

 

(2) Admitted. 

 

(3) There are no allegations in paragraph 3 of the petition and therefore no response is 

required. 

 

(4) Respondent neither admits nor denies the allegations made in paragraph 4 of the petition 

as Respondent is without sufficient information and/or knowledge to form a belief as to the 

truthfulness and therefore leaves Petitioner to its proofs. 

 

(5) There are no allegations in paragraph 5 of the petition and therefore no response is 

required. 

 

(6) Admitted.

Page 3

3 

 

4908-3158-7801, v. 1 

(7) There are no allegations in paragraph 7 of the petition and therefore no response is 

required. 

 

(8) There are no allegations in paragraph 8 of the petition and therefore no response is 

required. 

 

(9) There are no allegations in paragraph 9 of the petition and therefore no response is 

required. 

 

(10) Admitted. 

 

(11) Admitted. 

 

(12) Respondent lacks sufficient information and/or knowledge as to Petitioner’s legal 

residence and/or principal office address and therefore leaves Petitioner to its proofs. 

 

(13) Paragraph 13 merely restates Petitioner’s claim and therefore no response is required; 

Respondent denies that the property is improperly assessed and further denies that Petitioner is 

entitled to any relief. 

 

(14) Admitted. 

 

(15) There are no allegations in paragraph 15 of the petition and therefore no response is 

required. 

 

(16) Admitted. 

 

(17) Denied as untrue. 

 

(18) Respondent admits that Petitioner asserts the values in dispute based on the allegations 

in paragraph 17; however, Respondent denies that the subject property is improperly assessed and 

further denies that Petitioner is entitled to any relief. 

 

(19) Paragraph 19 contains a request for relief to which no response is required; 

Respondent denies that Petitioner is entitled to any relief, requested or otherwise. 

 

(20) Denied as untrue. 

 

AFFIRMATIVE DEFENSES 

1. 

Petitioner has failed to state a claim upon which relief can be granted. 

 

2. 

Petitioner’s claims against Respondent are barred because the valuation methods 

used by Respondent comply with the Constitution, state law, and prevailing Michigan State Tax 

Commission procedures. 

 

3. 

Respondent’s assessment reflects 50% of the subject property’s true cash value and 

the values on the roll, including the taxable value, comply with MCL 211.27a.

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4 

 

4908-3158-7801, v. 1 

 

4. 

Petitioner may not be a party in interest capable of bringing this appeal as to the 

parcel at issue in this matter. 

 

5. 

Petitioner’s claims may be barred in whole or in part for failing to allege sufficient 

facts to invoke the Tax Tribunal’s jurisdiction. 

 

6. 

Respondent reserves the right to identify further affirmative defenses as may 

become known through discovery. 

 

WHEREFORE, Respondent requests that the Tribunal dismiss Petitioner’s appeal with 

prejudice and award Respondent its costs, attorney fees, and all such further and additional relief 

as this Tribunal may deem appropriate. 

 

 

 

 

Dated: October 22, 2026 

Respectfully submitted by, 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

 

Toby Koenig (P72367) 

Attorneys for Respondent City of Walker 

 

 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom 

Sluggett, PC, and that on October 22, 2026, she served a copy of Respondent’s Appearance and 

Answer to Petition with Affirmative Defenses and Proof of Service by first class mail and e-mail 

upon Steve Johnson at: 

 

Steve Johnson 

Michigan Tax Appeal Services 

436 N Center Street 

Northville, MI 48167 

info@mitaxappeal.com 

 

 

 

 

 

 

 

 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 

 

 Tonya Voakes

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