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Groesbeck Cp & Mp Investments LLC, Roseville Investment Holding LLC Petitioners Vs. City Of Fraser Respondent · 26-002524-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Groesbeck CP & MP Investments LLC & Roseville 

Investment Holding LLC, 

 

Petitioner, 

 

vs. 

 

City of Fraser, 

 

Respondent. 

MTT Docket No. 26-002524 

 

_____________________________________________________________________________/ 

 

CLARK PATTAH 

Representative for Petitioner 

2207 Orchard Lake Road 

Sylvan Lake, MI 48320-1786 

(248) 939-1400 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent City of Fraser, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1 as to the parcel number, 

address, classification, County, and school district. 

 

2. 

Respondent admits that no Board of Review protest was made. 

 

3. 

Respondent admits the allegations in Paragraph 3. 

 

4. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 4 and leaves Petitioner to its proofs.

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Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

 

5. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 5 and leaves Petitioner to its proofs. 

 

6. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal, but 

denies that those issues have merit and also denies that Petitioner is entitled to any relief. 

 

7. 

Respondent admits the allegations in Paragraph 7. 

 

8. 

The 2026 values for the property identified above as established by Respondent’s 

Board of Review are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

$6,861,600 

$3,430,800 

$2,976,919 

9. 

Respondent contends that the 2026 values for the property identified above are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

$6,861,600 

$3,430,800 

$2,976,919 

 

10. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

$8,875,600 

$4,437,800 

$4,162,953 

 

11. 

Petitioner is not entitled to the relief requested in Paragraph 11, including all 

subparagraphs, for the reason that Petitioner’s amounts do not reflect the accurate valuations for 

this property. Furthermore, the assessed, state equalized and/or taxable values do not exceed 

permitted amounts, do not exceed the percentage for true cash value permitted by law, were 

correctly determined and are based upon correct application of proper principals, and the values 

and Respondent’s mode of assessment are non-discriminatory and constitutional. 

 

WHEREFORE, Respondent City of Fraser requests 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.

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Entire Tribunal Property Tax Answer 

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HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Seth O’Loughlin______________ 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 18, 2026 

 

 

 

(248) 731-3089 

 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent City of Fraser asserts the following affirmative defenses: 

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. 

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 has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question.

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Entire Tribunal Property Tax Answer 

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6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

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. 

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 raise additional affirmative defenses as the same 

may become known to it during the course of these proceedings.

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Entire Tribunal Property Tax Answer 

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HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Seth O’Loughlin______________ 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 18, 2026 

 

 

 

 

 

(248) 731-3089 

 

 

 

 

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to 

Petition and Affirmative Defenses to: 

 

Clark Pattah 

clark@pattahdevelopment.com 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

__/s/ Seth O’Loughlin______________ 

Dated: September 18, 2026 

Seth O’Loughlin

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