Full record / Mansfield Storage LLC MTT# 25-002229 answer.pdf

Mansfield Storage LLC MTT# 25-002229 answer.pdf

Mansfield Storage LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002229-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

MANSFIELD STORAGE, LLC, 

 

Petitioner, 

v. 

MTT Docket No. 25-002229 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

ANSWER 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

2. Respondent admits. 

3. Respondent admits. 

4. Respondent admits. 

5. Respondent admits. 

6. Respondent admits. 

7. No response required. 

 

8. Respondent admits. 

 

9. Respondent admits. 

 

10. Respondent admits. 

 

11. Respondent admits. 

 

12. Respondent admits. 

 

13. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues

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involving true cash and taxable values. Respondent denies that any such allegations have 

merit. 

14. Respondent admits. 

 

15. Respondent admits. 

 

16. Respondent denies as untrue. By way of explanation the true cash value is $751,000 

and the assessed and taxable values are $375,500. 

17. Respondent denies Petitioner’s contentions of value are correct or accurate. 

 

18. Based solely upon Petitioner’s unsubstantiated and erroneous contentions of value 

Respondent admits. 

19. Prayer for relief, no response required. 

 

20. Respondent denies as untrue. 

 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

 

1. Petitioner’s claims are barred by the applicable statute of limitations. 

2. Petitioner has failed to state a claim for which relief may be granted. 

 

3. Petitioner lacks standing. 

 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

Respectfully Submitted, 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Mary Beth Cobbs (P40080) 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3061

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

MANSFIELD STORAGE, LLC, 

 

Petitioner, 

v. 

MTT Docket No. 25-002229 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

PROOF OF SERVICE 

 

On November 25, 2025, I mailed by first class mail a copy of Respondent’s Answer in the instant 

matter to: 

 

Christopher Wylie 

Wylie Group LLC 

17963 Maple Hill Court 

Northville, Michigan 48168 

 

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

 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Senior Assistant Corporation Counsel 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Dated:November 25, 2025 

Detroit, Michigan 48226

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