NREG US Holdings LTD 26-000825 Answer to Petition 7-20-26.pdf
Nreg US Holdings Ltd Petitioner Vs. Township Of Pittsfield Respondent · 26-000825-TT
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1 S E C R E S T W A R D L E STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL NREG US HOLDINGS LTD, Petitioner, MTT Docket No. 26-000825 -vs- PITTSFIELD CHARTER TOWNSHIP, Respondent. _________________________________________________________________________________/ HALLAHAN & ASSOCIATES, P.C. Laura M. Hallahan (P42101) Attorney for Petitioner 1750 S. Telegraph Road Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.com SECREST WARDLE Alana E. Knox (P85859) Attorney for Respondent 2600 Troy Center Drive P.O. Box 5025 Troy, MI 48007-5025 (248) 851-9500 aknox@secrestwardle.com _________________________________________________________________________________/ RESPONDENT’S ANSWER TO PETITIONER’S PETITION (Entire Tribunal, 2026 Tax Year) NOW COMES Respondent, PITTSFIELD CHARTER TOWNSHIP, by and through its attorneys, SECREST WARDLE, and for its Answer to Petitioner’s Petition (Entire Tribunal, 2026 Tax Year), states as follows: 1. Answering paragraph 1, Respondent admits that the subject property consists of one parcel of commercial property located at 42955 Carpenter, Pittsfield Charter Township, in the Ann Arbor School District and is also identified as tax identification number L-12-13-302-001. Respondent neither admits nor denies the remainder of the allegations contained in paragraph 1 for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 2. Answering paragraph 2, Respondent states that there is no information to admit or deny
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2 S E C R E S T W A R D L E in paragraph 2. 3. Answering paragraph 3, Respondent admits the same. 4. Answering paragraph 4, Respondent admits that Petitioner NREG US Holdings LTD, is the owner of the subject property known as 42955 Carpenter. Respondent neither admits nor denies the allegations contained in paragraph 4 for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 5. Answering paragraph 5, Respondent neither admits nor denies the allegations contained in paragraph 5 for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 6. Answering paragraph 6, Respondent neither admits nor denies the allegations contained in paragraph 6 for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 7. Answering paragraph 7, Respondent admits that the tax year at issue is 2026. 8. Answering paragraph 8, Respondent admits that the subject property’s 2026 true cash, state equalized value and taxable value on the Respondent’s assessment roll are as follows: PARCEL NUMBER TRUE CASH VALUE STATE EQUALIZED VALUE TAXABLE VALUE L-12-13-302-001 $6,133,392 $3,066,696 $3,066,696 which assessed valued will result in a state equalized value in the same amount based upon the tentative equalization factor. Respondent neither admits nor denies the remainder of the allegations contained in paragraph 8 for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 9. Answering paragraph 9, Respondent denies that the subject property’s 2026 true cash, state equalized value and taxable value on the Respondent’s assessment roll should be:
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3 S E C R E S T W A R D L E PARCEL NUMBER TRUE CASH VALUE STATE EQUALIZED VALUE TAXABLE VALUE L-12-13-302-001 $4,000,000 $2,000,000 $1,000,000 10. Answering paragraph 10, Respondent neither admits nor denies the allegations contained in paragraph 10, for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 11. Answering paragraph 11, including subparagraphs a. through d., Respondent denies the allegations contained therein for the reason that the same are untrue. WHEREFORE, Respondent, PITTSFIELD CHARTER TOWNSHIP, denies that Petitioner is entitled to the relief it seeks and respectfully requests that the Respondent’s assessments and taxable values of the subject property be affirmed or increased, that Petitioner’s Petition (Entire Tribunal, 2026 Tax Year) be dismissed with prejudice and that Respondent be granted costs and attorney fees so wrongfully incurred in the defense of this matter. Respectfully submitted, SECREST WARDLE BY: /s/ Alana E. Knox ALANA E. KNOX (P85859) Attorney for Respondent 2600 Troy Center Dr., P.O. Box 5025 Troy, MI 48007-5025 (248) 851-9500 Dated: July 20, 2026 aknox@secrestwardle.com AFFIRMATIVE DEFENSES For its further Answer to Petitioner’s Petition (Entire Tribunal, 2026 Tax Year) and by way of its Affirmative Defenses, Respondent respectfully requests unto this Honorable Tribunal as follows:
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4 S E C R E S T W A R D L E 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 fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles or illegality on the part of the Respondent. 3. Petitioner fails to allege that the mode and method of appraising its property failed to conform with the mode and method applied in the case of all of the properties in the Respondent’s taxing unit for the year in question. 4. Petitioner fails to allege specific and sufficient facts to establish the true cash value, assessed value and taxable value of its property. 5. Petitioner fails to allege specific and sufficient facts to support its allegation that the assessed value of its property, as equalized, is at a factor other than 50% and also fails to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper. 6. Petitioner fails to show that any rate other than 50% after equalization was applied to the true cash value of its property, as well as to the properties of all others to arrive at the respective equalized assessments. 7. Petitioner, in essence, asks that this Honorable Tribunal grant it an illegal preference by application of a method of assessment different from that employed in the assessment other properties in the Respondent’s taxing unit. 8. 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. 9. Petitioner failed to allege to the Board of Review that: A. The equalized assessment of the property is more than 50% of its true cash value and that the taxable value is in violation of applicable statutory and constitutional limitations. B. The property is assessed in a discriminatory manner and that the assessment is a higher level of true cash value than the average
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5 S E C R E S T W A R D L E level of assessment of all other property within the Township, excepting this property and the assessment on other property which is also under appeal. C. The assessment and taxable value are unlawful and based upon the application of wrong principles and thereby operate as a constructive fraud upon the taxpayer. The failure to raise such objections to the Respondent’s Board of Review constitutes a failure to exhaust the administrative remedies provided for by the General Property Tax Act, constitutes a waiver of any such allegations contained in the Petition, and further amounts to a failure by the Petitioner to appear in protest to Respondent’s Board of review as required by the Tax Tribunal Act. 10. 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. 11. Respondent has properly and lawfully assessed Petitioner’s property and established its taxable value in accordance with statutory and constitutional requirements. 12. Petitioner has failed to pursue its appeal in a timely fashion. 13. Respondent reserves the right to add to these Affirmative Defenses any new Affirmative Defenses that discovery reveals. WHEREFORE, Respondent, PITTSFIELD CHARTER TOWNSHIP, denies that Petitioner is entitled to the relief it seeks and respectfully requests that the Respondent’s assessment and taxable value of the subject property be affirmed or increased and that Petitioner’s Petition (Entire Tribunal, 2026 Tax Year) be dismissed with prejudice and that Respondent be granted costs and attorney fees so wrongfully incurred in the defense of this matter.
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6 S E C R E S T W A R D L E Respectfully submitted, SECREST WARDLE BY: /s/ Alana E. Knox ALANA E. KNOX (P85859) Attorney for Respondent 2600 Troy Center Dr., P.O. Box 5025 Troy, MI 48007-5025 (248) 851-9500 Dated: July 20, 2026 aknox@secrestwardle.com PROOF OF SERVICE I hereby certify that on July 20, 2026, a copy of the foregoing document, Respondent’s Answer to Petitioner’s Property Tax Petition (Entire Tribunal, 2026 Tax Year) and Affirmative Defenses, was filed electronically with the Michigan Tax Tribunal, and was served upon: Hallahan & Associates, P.C. Laura M. Hallahan, Esq. 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 by depositing same in the United States mail with postage fully prepaid thereon. /s/ Tamera Briggs Tamera Briggs (10871230.1)