STELLAR V E BAY ANS 26-000995-TT10002320260730092437.pdf
Stellar Hospitality Traverse City LLC Petitioner Vs. Township Of East Bay Respondent · 26-000995-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL STELLAR HOSPITALITY TRAVERSE CITY LLC, \% Petitioner, MTT Docket No. 26-000995-TT EAST BAY CHARTER TOWNSHIP, Respondent. Laura M. Hallahan (P42101) Robert E. Thall (P46421) Attorney for Petitioner Bauckham, Thall, Seeber, Kaufman 1750 S. Telegraph Rd., Ste. 202 & Koches, P.C. Bloomfield Hills, MI 48302-0179 Attorney for Respondent (248) 731-3089 470 W. Centre Ave., Ste. A lhallahan@hallahanlaw.com Portage, MI 49024 (269) 382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, East Bay Charter Township, states the following in response to the respective paragraphs of the Petition filed in this matter: 1. 2. inapplicable. 3. In answer to paragraph 1 of the Petition, Respondent admits the allegations therein. In answer to paragraph 2 of the Petition, no response is required as this is In answer to paragraph 3 of the Petition, Respondent admits the allegations therein.
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7. In answer to paragraph 7 of the Petition, Respondent admits the allegations therein. 8. In answer to paragraph 8 of the Petition, Respondent admits the allegation therein. 9. In answer to paragraph 9 of the Petition, Respondent admits the allegations therein, except that the Respondent denies the value contentions of the Petitioner as untrue. 10. In answer to paragraph 10, including (a) through (d), of the Petition, Respondent denies the allegations therein as untrue. WHEREFORE, Respondent respectfully requests that the Tribunal enter an Order denying the relief requested by Petitioner and uphold and affirm the valuation as established by the Respondent and require Petitioner to pay Respondent’s costs and attorney fees. AFFIRMATIVE DEFENSES Please take notice that Respondent may rely on one or more of the following affirmative defenses: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 3. The service of process was insufficient. 4. The subject property is under assessed and/or the taxable value and/or state equalized value of the subject property is too low, and should therefore be appropriately increased to comply with the mandate of the applicable provisions of law. S. Respondent reserves the right to file such additional affirmative defenses as may become apparent pursuant to discovery procedures during the pendency of this matter.
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Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN & KOCHES, PC. Date: July 30, 2026 By: Robert E. Thall Attorney for Respondent