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Answer to Petition, 800 E Court Street, 6.25.25.pdf

800 E. Court Street Village Limited Dividend Housing Association Limited PA, Petitioner Vs. Michigan Department Of Treasury, Respondent · 25-001630-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF ATTORNEY GENERAL 

 

 

P.O. BOX 30754 

LANSING, MICHIGAN 48909 

 

 

DANA NESSEL 

ATTORNEY GENERAL 

 

 

June 25, 2025 

 

 

 

 

 

 

 

 

Michigan Tax Tribunal 

Attn: Samantha M. Welton, Chief Clerk 

611 W. Ottawa Street, 4th Floor 

P.O. Box 30232 

Lansing, MI 48909 

 

Re: 

800 E. Court Street Village Limited Dividend Housing Association 

Limited Partnership v City of Flint and Michigan Dep’t of Treasury 

Michigan Tax Tribunal Docket No. 25-001630-TT 

 

Dear Clerk: 

 

Enclosed for submission, please find Respondent Michigan Department of 

Treasury’s Answer to Petition and a Proof of Service, regarding the above referenced 

case. 

 

If you have any questions, please do not hesitate to contact me. 

 

Sincerely, 

 

/s/ B. Thomas Golden 

 

 

B. Thomas Golden 

Jessica L. Rundle 

Assistant Attorneys General 

Revenue and Tax Division 

P.O. Box 30754 

Lansing, Michigan 48909 

(517) 335-7584 

BTG/mm 

 

Cc: 

City of Flint and Stewart L. Mandell Honigman, LLP (Via First-Class U.S. 

Mail)

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

800 E. COURT STREET VILLAGE 

LIMITED DIVIDEND HOUSING 

ASSOCIATION LIMITED 

PARTNERSHIP 

MTT Docket No. 25–001630–TT 

Petitioner, 

v 

CITY OF FLINT, and 

MICHIGAN DEPARTMENT OF 

TREASURY 

Respondents. 

_____________________________________________________________________________/

Stewart L. Mandell (P33781) 

HONIGMAN, LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, Michigan 48304 

(313) 465–7420

slmandell@honigman.com

B. Thomas Golden (P70822) 

Jessica L. Rundle (P83788) 

Assistant Attorneys General 

Revenue and Tax Division 

Attorneys for Respondent 

Michigan Department of Treasury

P.O. Box 30754

Lansing, MI 48909

(517) 335–7584

goldent2@michigan.gov

rundlej1@michigan.gov

_____________________________________________________________________________/ 

 RESPONDENT MICHIGAN DEPARTMENT OF TREASURY’S 

ANSWER TO PETITION 

Respondent, Michigan Department of Treasury (Treasury), through its 

counsel, Assistant Attorneys General B. Thomas Golden and Jessica L. Rundle, 

states for its Response to the Petition as follows:

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1.

Treasury neither admits nor denies the allegations of paragraph 1

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

2.

Treasury neither admits nor denies the allegations of paragraph 2

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

3.

Treasury admits the allegations in paragraph 3.

4.

Treasury neither admits nor denies the allegations of paragraph 4

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

5.

Treasury neither admits nor denies the allegations of paragraph 5

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

6.

Treasury neither admits nor denies the allegations of paragraph 6

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

7.

Treasury neither admits nor denies the allegations of paragraph 7

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

8.

Treasury neither admits nor denies the allegations of paragraph 8

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs.

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9.

Treasury admits the allegations set forth in paragraph 9.

10.

Treasury neither admits nor denies the allegations of paragraph 10

because Treasury lacks knowledge or information sufficient to form a belief as to 

the truth of the matter asserted and leaves Petitioner to its proofs. 

11.

Treasury neither admits nor denies paragraph 11 because it states a

legal conclusion to which no response is required. To the extent a response is 

required, Treasury denies that Petitioner qualifies for a property tax exemption 

under MCL 211.7d. 

12.

Treasury denies the allegation in paragraph 12. Treasury further

states, upon information and belief, that Petitioner has not filed a Request for New 

Senior Citizen/Disabled Housing Exemption in 2025; however, Petitioner’s Request 

for New Senior Citizen/Disabled Housing Exemption filed in 2024 is the subject of 

litigation in MTT Docket No. 24-004101-TT. 

Wherefore, Respondent Michigan Department of Treasury asks that this 

Tribunal deny Petitioner’s requested relief, and grant Respondents such other relief 

as this Tribunal deems appropriate.

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AFFIRMATIVE DEFENSES 

Respondent, Michigan Department of Treasury, asserts the following 

affirmative defenses: 

1.

To the extent that Petitioner has not filed a new claim for exemption

under MCL 211.7d in 2025, as required by MCL 211.7d(2), and Treasury has 

neither approved nor denied that claim, this court lacks jurisdiction. 

2.

To the extent that Petitioner’s Petition is based on the 2024 claim for

exemption denied by Treasury, and not a subsequent claim for exemption under 

MCL 211.7d, this case must be dismissed under MCR 2.116(C)(6) because another 

action has been initiated between the same parties involving the same claim (MTT 

Docket No. 24-004101-TT). 

3.

To the extent that Petitioner has not filed a new claim for exemption

under MCL 211.7d in 2025, as required by MCL 211.7d(2), and Treasury has 

neither approved nor denied that claim, Petitioner has failed to state a claim on 

which relief can be granted. 

4.

Petitioner has failed to show that it fulfills the requirements of

MCL 211.7d. 

5.

To the extent Petitioner is contesting the classification of the subject

property, this Tribunal lacks jurisdiction to consider classification disputes; 

Petitioner failed to dispute the classification in accordance with MCL 211.34c(6). 

6.

Treasury reserves the right to raise additional affirmative defenses as

the same may become known during the course of these proceedings.

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Respectfully Submitted, 

/s/ B. Thomas Golden_______ 

B. Thomas Golden (P70822) 

Jessica L. Rundle (P83788) 

Assistant Attorneys General 

Revenue and Tax Division 

Attorneys for Respondent 

Michigan Department of Treasury

P.O. Box 30754

Lansing, MI 48909

(517) 335–7584

goldent2@michigan.gov

rundlej1@michigan.gov

Dated: June 25, 2025

Page 7

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

800 E. COURT STREET VILLAGE 

LIMITED DIVIDEND HOUSING 

PARTNERSHIP, 

Petitioner, 

v 

CITY OF FLINT AND 

MICHIGAN DEPARTMENT OF 

TREASURY, 

Respondents. 

MTT Docket No. 25-001630-TT 

 / 

Stewart L. Mandell (P33781) 

HONIGMAN, LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(313) 465-7420

slmandell@honigman.com

B. Thomas Golden (P70822)

Jessica L. Rundle (P83788)

Assistant Attorneys General

Attorneys for Respondent

Michigan Department of Treasury

Revenue and Tax Division

Attorneys for Respondent

P.O. Box 30754

Lansing, MI 48909

(517) 335-7584

Goldent2@michigan.gov

Rundlej1@michigan.gov

 / 

PROOF OF SERVICE 

Michelle Moore, states that on this 25th day of June 2025, I served 

Respondent Michigan Department of Treasury’s Answer to Petition, along with a 

copy of this Proof of Service upon the following:

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Stewart L. Mandell 

Honigman, LLP 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

City of Flint 

1101 S. Saginaw St. 

Flint, MI 48502 

by depositing the same in a receptacle of the United States Post Office in the City of 

Lansing, Michigan, enclosed in an envelope, plainly addressed, bearing postage 

fully prepaid. 

I declare that the above statement is true to the best of my knowledge, 

information, and belief. 

/s/ Michelle Moore 

Michelle Moore, Legal Secretary

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