Indian Trails LLC MTT 26-001466 answer.pdf
Indian Trails LLC F/K/A Indian Trails Inc Petitioner Vs. City Of Detroit Respondent · 26-001466-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL INDIAN TRAILS, LLC f/k/a INDIAN TRAILS, INC., Petitioner, v. Docket No. 26-001466 CITY OF DETROIT, Respondent. ________________________________/ ANSWER NOW COMES RESPONDENT, CITY OF DETROIT, by and through its undersigned counsel, and in Answer to the Petition filed in this matter states as follows: 1. Respondent admits. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs. 2. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs. 3. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs. 4. Respondent admits. 5. Respondent admits. 6. Respondent admits.
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2 7. Respondent admits. 8. Respondent admits. 9. Respondent admits that the subject property is utilized as a bus terminal, however, denies as untrue that it is a “public bus terminal”. The property is leased and utilized by a private for profit business as a bus terminal 10. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues involving the subject property’s true cash value, taxable value, and exemption, however, Respondent denies that any such allegations have merit. 11. Respondent admits. 12. Respondent admits as to Petitioner’s statement as it pertains to the assessed and taxable values of the subject property, however, denies as untrue its allegation regarding the true cash value of the subject property. The 2026 true cash value for the subject property is $1,153,000. 13. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs. 14. Based solely upon Petitioner’s unsubstantiated and erroneous contentions Respondent admits. 15. Paragraph 15 references provisions of state law which speak for themselves and no response is required. Additionally, Paragraph 15 states Petitioner’s opinion and no response is necessary. To the extent a response is required, Respondent denies the statement as untrue and leaves Petitioner to its proofs.
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3 16. Request for relief and no response is necessary. To the extent a response is required, Respondent denies the statement as untrue and leaves Petitioner to its proofs. 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. This Tribunal lacks subject matter jurisdiction. 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) City of Detroit Law Department Coleman A. Young Municipal Center 2 Woodward Avenue, Suite 500 Detroit, Michigan 48226 (313) 237-3061 Dated: September 17, 2026
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4 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL INDIAN TRAILS, LLC f/k/a INDIAN TRAILS, INC., Petitioner, v. Docket No. 26-001466 CITY OF DETROIT, Respondent. ________________________________/ PROOF OF SERVICE On September 17, 2026, I sent by First Class U.S. mail a copy of Respondent’s Answer w/Affirmative Defenses in the instant matter to: Deborah J. Ondersma Adam J. Brody Varnum LLP 333 Bridge Street, N.W. P.O. Box 352 Grand Rapids, MI. 49501 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: September 17, 2026 Detroit, Michigan 48226