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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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
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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.
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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