Carrollton Twp Answer and Affirmative Defenses to Petition 26-000828.pdf
Yeager Asphalt Petitioner Vs. Township Of Carrollton Respondent · 26-000828-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL YEAGER ASPHALT, Petitioner, v MTT Docket No.26-000828 CARROLLTON TOWNSHIP, Respondent. REID A. DUFORD AUTHORIZED REPRESENTATIVE 412 E. Saginaw Road Sanford, MI 48657 (989) 280-1715 rduford45@yahoo.com THOMAS D. LANDA (P78201) NICHOLAS R. SCHNEIDER (P88238) McGRAW MORRIS MASUD P.C. Attorneys for Respondent 2075 W. Big Beaver Road, Suite 750 Troy, MI 48084 (248) 502-4000 tlanda@mcgrawmorris.com nschneider@mcgrawmorris.com RESPONDENT’S ANSWER TO 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION Respondent, Carrollton Township (“Respondent”), through its attorneys, McGraw Morris Masud P.C., states as follows for its answer to Yeager Asphalt’s (“Petitioner”) Petition: 1. Respondent neither admits nor denies the allegations in paragraph 1 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 2. Respondent neither admits nor denies the allegations in paragraph 2 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 3. Petitioner failed to make any allegations in paragraph 3 of the Complaint and therefore no response by Respondent is required.
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2 4. Respondent neither admits nor denies the allegations in paragraph 4for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 5. Respondent neither admits nor denies the allegations in paragraph 5 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 6. Respondent neither admits nor denies the allegations in paragraph 6 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 7. Respondent neither admits nor denies the allegations in paragraph 7 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 8. Petitioner failed to make any allegations in paragraph 8 of the Complaint and therefore no response by Respondent is required. 9. Petitioner failed to make any allegations in paragraph 9 of the Complaint and therefore no response by Respondent is required. 10. Respondent neither admits nor denies the allegations in paragraph 10 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 11. Admitted. 12. Respondent neither admits nor denies the allegations in paragraph 12 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs.
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3 13. Respondent neither admits nor denies the allegations in paragraph 13 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 14. Admitted. 15. Petitioner failed to make any allegations in paragraph 15 of the Complaint and therefore no response by Respondent is required. 16. Respondent neither admits nor denies the allegations in paragraph 16 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 17. Denied as untrue. 18. Respondent neither admits nor denies the allegations in paragraph 18 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 19. Petitioner failed to make any allegations in paragraph 19 of the Complaint and therefore no response by Respondent is required. To the extent a response is required, Respondent denied that Petitioner is entitled to the requested relief. 20. Respondent neither admits nor denies the allegations in paragraph 20 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. WHEREFORE, Respondent Carrollton Township requests that the Tribunal deny any and all relief sought by Petitioner and grant Respondent any other relief it deems just and equitable.
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4 Respectfully submitted, MCGRAW MORRIS MASUD P.C. /s/______________________ Thomas D. Landa (P78201) Nicholas R. Schneider (P88238) Attorneys for Respondent 2075 W. Big Beaver Road, Ste. 750 Troy, MI 48084 Date: August 17, 2026 (248) 502-4000
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5 AFFIRMATIVE DEFENSES TO PETITION 1. Respondent used the proper means and method to establish the assessment and made a proper assessment according to Michigan Law. 2. Respondent reserves the right to add, amend, or delete any and all Affirmative Defenses up to and including trial. Respectfully submitted, MCGRAW MORRIS MASUD P.C. /s/______________________ Thomas D. Landa (P78201) Nicholas R. Schneider (P88238) Attorneys for Respondent 2075 W. Big Beaver Road, Ste. 750 Troy, MI 48084 Date: August 17, 2026 (248) 502-4000
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6 PROOF OF SERVICE The undersigned certifies that a copy of the foregoing Respondent’s Answer To 2026 Entire Tribunal Property Tax Petition And Affirmative Defenses To Petition was served upon all attorney(s) of record of all party(ies) to the above cause at the respective addresses disclosed in the pleadings on August 17, 2026 by: ☒U.S. Mail ☐Fax ☐Hand Delivery ☐Overnight Courier ☒E-Mail ☐E-File/E-Serve ☐Other: _____________________ I declare under the penalty of perjury that the statement above is true to the best of my information, knowledge and belief. /s/ April M. Leve April M. Leve