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325 S Old Woodward LLC Petitioner Vs. City Of Birmingham Respondent · 26-001349-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

325 S Old Woodward LLC, 

 

 

 

Petitioner, 

vs. 

 

City of Birmingham, 

 

 

 

Respondent. 

 

 

MTT Docket No. 26-001349 

 

Parcel No. 08-19-36-208-015 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

 

Respondent City of Birmingham, through its attorneys, Beier Howlett, P.C., responds to 

the allegations made in the Petition as follows: 

1. Admitted. 

2. Admitted. 

3. Admitted. 

4. Admitted. 

5. Neither admit nor deny as Respondent is without sufficient information and therefore, 

Respondent leaves Petitioner to its proofs. 

6. Neither admit nor deny as Respondent is without sufficient information and therefore, 

Respondent leaves Petitioner to its proofs. 

7. Respondent denies all of the allegations in this paragraph including, without limitation; 

those contained in subparts (a) through (d). 

WHEREFORE, Respondent City of Birmingham requests that 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.

Page 2

Respectfully submitted, 

BEIER HOWLETT, P.C. 

/s/ Michael C. Gibbons 

 

Michael C. Gibbons (P51304) 

Attorneys for Respondent 

3001 W. Big Beaver Rd., Ste. 600 

Troy, MI 48084 

Date: October 12, 2026 

 

 

248-282-1069/ mgibbons@bhlaw.us.com

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

325 S Old Woodward LLC, 

 

 

 

Petitioner, 

vs. 

 

City of Birmingham, 

 

 

 

Respondent. 

 

 

MTT Docket No. 26-001349 

 

Parcel No. 08-19-36-208-015 

_____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

On the date below I sent by first class mail a copy of this Answer to: 

Aaron M. Fales 

330 Hamilton Row, Suite 350 

Birmingham, MI 48009 

 

I declare that the statements above are true and to the best of my information, knowledge and 

belief. 

 

 

 

 

/s/ Erin Miller 

 

 

 

Erin Miller 

Dated: October 12, 2026

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