Answer Collins.pdf
Sanda F Collins Trust, Petitioner Vs. City Of Birmingham, Respondent · 25-002867-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Sandra F Collins Trust, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 25-002867 Parcel No. 08-19-25-151-070 _____________________________________________________________________________/ ANSWER TO PETITION Respondent City of Birmingham, through its attorneys, Beier Howlett, P.C., responds to the allegations made in the Petition as follows: 1. Neither admit nor deny as Respondent is without sufficient information and therefore, Respondent leaves Petitioner to its proofs. 2. Admitted. 3. Admitted 4. Admitted 5. Admitted 6. Admitted. 7. Admitted 8. It is admitted that Petitioner seeks the values stated in this paragraph. Respondent denies that the requested values are appropriate or accurate. 9. Respondent admits that the amounts recited reflect Petitioner’s position as to the values in dispute, but denies any valid amount in dispute.
Page 2
10. Respondent denies that Petitioner is entitled to any relief as requested in this paragraph. 11. Respondent admits that Petitioner raises the issues referred to but denies there is any genuine issue involved. 12. Respondent denies all of the allegations in this paragraph. WHEREFORE, Respondent City of Birmingham requests that the 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. Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 7, 2025 248-282-1069/ mgibbons@bhlaw.us.com
Page 3
STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Sandra F Collins Trust, Petitioner, vs. City of Birmingham, Respondent. MTT Docket No. 25-002867 Parcel No. 08-19-25-151-070 _____________________________________________________________________________/ PROOF OF SERVICE On the date below I sent by first class mail a copy of this Answer to: Attn: Deborah I. Ondersma Varnum, LLP 333 Bridge St. N.W. P.O. Box 352 Grand Rapids, MI 49501 I declare that the statements above are true and to the best of my information, knowledge and belief. /s/ Erin Miller Erin Miller Dated: October 7, 2025