Bloomfield Bpa LLC Petitioner Vs. Township Of Bloomfield Respondent

Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

Bloomfield BPA, LLC, 

 

 

 

Petitioner, 

 

v 

 

Bloomfield Township, 

 

 

 

Respondent. 

 

 

 

 

MTT Docket No. 26-001415 

 

Parcel No. C-19-28-352-003 

 

 

_____________________________________________________________________________/ 

 

JOSHUA T. SHILLAIR (P72674) 

COLLIERS INTERNATIONAL 

Attorney for Petitioner 

400 W. 4th Street, Suite 350 

Royal Oak, MI 48067 

(248) 226-1632 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent City of Southfield, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the assertions set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

Respondent denies that multiple parcels are at issue. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent admits the allegations in Paragraph 3.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 6 

 

4. 

Respondent admits that the property is commercial improved but lacks the 

information and knowledge necessary to respond to the remainder of the allegations set forth in 

Paragraph 4 and, therefore, leaves Petitioner to its proofs. 

5. 

Respondent admits no protest to the March Board of Review was made but 

neither admits nor denies the remainder of the allegations set forth in Paragraph 5 as the General 

Property Tax Act speaks for itself. 

6. 

Respondent admits the allegations in Paragraph 6. 

7. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but 

denies that those issues have merit and further denies Petitioner is entitled to any relief. 

8. 

Respondent acknowledges Petitioner’s belief as to an issue with the 2026 tax year 

but denies any issue with said year. 

9. 

The values for the property identified above as established by Respondent’s 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

$1,983,420 

$991,710 

$741,400 

 

10. 

Respondent denies the allegations in Paragraph 10, including subparagraphs (a) 

through (d), for the reason that the same are untrue. Furthermore, the assessed, state equalized 

and/or taxable values do not exceed permitted amounts, do not exceed the percentage for true 

cash value permitted by law, were correctly determined and are based upon correct application of 

proper principles, and the values and Respondent’s mode of assessment are non-discriminatory 

and constitutional.

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 6 

 

11. 

Respondent contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

$1,983,420 

$991,710 

$741,400 

$1,983,420 

 

12. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

13. 

Respondent denies the allegations in Paragraph 13 for the reason that the same are 

untrue. Furthermore, the assessed, state equalized and/or taxable values do not exceed permitted 

amounts, do not exceed the percentage for true cash value permitted by law, were correctly 

determined and are based upon correct application of proper principles, and the values and 

Respondent’s mode of assessment are non-discriminatory and constitutional. 

14. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to said relief for the reasons stated in the 

preceding paragraphs. 

 

WHEREFORE, Respondent, Bloomfield Township, requests 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. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/ Seth A. O’Loughlin___________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 17, 2026 

(248) 731-3089

Page 4

Entire Tribunal Property Tax Answer 

Page 4 of 6 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Bloomfield Township, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 

(1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose

Page 5

Enti

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001415

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Bloomfield (OAKLAND)

First Name

M.I.

Last Name

Home Address (No., Street, P.O. Box or Rural Route)

City or Town

State

ZIP Code

Telephone Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

Address (No., Street, P.O. Box or Rural Route)

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

mtt@hallahanlaw.com

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

Seth A. O'Loughlin

/s/

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Bloomfield BPA LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001415

Township Of Bloomfield,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.1 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: September 16, 2026

1 “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5).

Page 2

MTT Docket No. 26-001415

Page 2 of 2

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Bloomfield BPA LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001415

Township Of Bloomfield,

Respondent.

ORDER OF DEFAULT

The Tribunal has reviewed the file in the above-captioned case and finds that:

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.2 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: September 16, 2026

2 “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5).

Page 4

MTT Docket No. 26-001415

Page 2 of 2

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLOOMFIELD B.P.A., LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

Bloomfield Township, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

Bloomfield Township 

Assessing Office 

4200 Telegraph Road 

P.O. Box 489 

Bloomfield Twp, Michigan 48303-0489 

(248) 433-7700 

 

 

 

_____________________________________________________________________________/ 

 

2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, BLOOMFIELD B.P.A., LLC, has the legal residence or 

principal office address of 6495 TELEGRAPH RD,BLOOMFIELD HILLS, MI 48301-

1759. Petitioner is a party in interest with respect to property taxes on property parcel 

no(s). (hereinafter referenced as the Subject Property) C -19-28-352-003. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous. 

2. The Subject Property is located in Oakland County.

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, Bloomfield Township of Oakland County, assesses and collects property 

taxes on the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. The Subject 

Property is presently used or available for use for Commercial purposes. Petitioner 

believes that the Subject Property was originally designed to be used for Commercial 

purposes. 

5. Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

6495 TELEGRAPH RD, BLOOMFIELD HILLS, MI 48301-1759 

7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

8. The tax year(s) at issue are: 2026 

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2026 

C -19-28-352-

003 

$1,983,420.00 

$991,710.00 

$741,400.00 

 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, 

are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: 

a. The assessment, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable value are 

based upon an erroneous determination of the true cash value of that portion 

of the Subject Property that is taxable under Michigan law, and are based 

upon the application of wrong principles; and 

d. The assessment, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

C -19-28-352-

003 

$820,000.00 

$410,000.00 

$410,000.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2026 

C -19-28-352-003 

$581,710.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 4 of 5 

 

WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an 

Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject 

Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

COLLIERS INTERNATIONAL 

 

 

 

 

 

 

Representative for Petitioner 

 

 

 

 

 

 

 

By:_/s/ Joshua T. Shillair__Dated:05/26/2026 

 

 

 

 

 

 

Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

400 E 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com

Page 5

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 5 of 5 

 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

BLOOMFIELD B.P.A., LLC

Home Address (No., Street, P.O. Box or Rural Route)

6495 TELEGRAPH RD

City or Town

BLOOMFIELD HILLS

State

Michigan

ZIP Code

48301-1759

Telephone Number

2482261632

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

tax.efile@colliers.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

Address (No., Street, P.O. Box or Rural Route)

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

tax.efile@colliers.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

6495 TELEGRAPH RD

BLOOMFIELD HILLS

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48301-1759

Taxing Authority (City or Township)

Township Of Bloomfield (OAKLAND) 

County

Oakland

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

C -19-28-352-003.

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

991710

Current Taxable Value as established by the Board of Review:

741400

What do you believe is the fair market value (also known as True Cash Value)?

820000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

410000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ /s/Joshua T. Shillair

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686937335

Supporting Waiver Documents:

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Bloomfield BPA LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001415

Township Of Bloomfield, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: August 11, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: 19-28-352-003 

MTT Docket No.: 26-001415 

Page 1 of 2 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLOOMFIELD B.P.A., LLC, 

 

Petitioner, 

v 

MTT Docket No. 26-001415 

BLOOMFIELD TOWNSHIP, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Senior Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

Bloomfield Township 

Assessing Office 

4200 Telegraph Road 

P.O. Box 489 

Bloomfield Twp, Michigan 48303-0489 

(248) 433-7700 

_____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

STATE OF MICHIGAN 

) 

 

)ss 

COUNTY OF OAKLAND 

) 

 

Jennifer Lunsford, states that on 8/6/2026, in compliance with TTR 221, she did place in the US 

mail a copy of Petitioner’s 2026 Entire Tribunal Property Tax Petition with docket number as well 

as this Proof of Service of Petition for the above captioned appeal to the units of government listed 

on the second page of this Proof of Service of Petition. 

 

/s/Jennifer Lunsford 

Jennifer Lunsford 

 

Karen Cameron states that she submitted electronically on 8/6/2026, to the Michigan Tax Tribunal 

a copy of this Proof of Service of Petition at eFile through www.etaxappeal.lara.state.mi.us. 

 

/s/Karen Cameron 

Karen Cameron

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: 19-28-352-003 

MTT Docket No.: 26-001415 

Page 2 of 2 

 

By Certified Mail 

 

Assessor’s Office 

Bloomfield Township 

Assessing Office 

4200 Telegraph Road 

P.O. Box 489 

Bloomfield Twp, Michigan 48303-0489 

 

Office of the Township Clerk 

Bloomfield Township 

Clerk's Office 

4200 Telegraph Road 

Bloomfield Hills, MI 48302 

 

By First Class Mail 

 

Director of Equalization 

Oakland County 

Equalization Director 

250 Elizabeth Lake Road, Suite 1000W 

Pontiac, MI 48341 

 

County Clerk’s Office 

Oakland County 

Clerk’s Office 

1200 N Telegraph Road 

Pontiac, MI 48341 

 

Secretary of the School Board 

Bloomfield Hills Schools 

7273 Wing Lake Road 

Bloomfield Hills, MI 48301 

 

Treasurer for the State of Michigan 

Michigan Department of Treasury 

Lansing, MI 48922

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001415

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: POS_BLOOMFIELD_B.P.A._LLC_26-001415

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 1 of 5 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLOOMFIELD B.P.A., LLC, 

 

Petitioner, 

 

v 

 

 

 

 

 

 

MTT Docket No. 

 

Bloomfield Township, 

 

Respondent. 

_____________________________________________________________________________/ 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

Representative for Petitioner 

400 W 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com 

Karen.Cameron@Colliers.com 

 

Bloomfield Township 

Assessing Office 

4200 Telegraph Road 

P.O. Box 489 

Bloomfield Twp, Michigan 48303-0489 

(248) 433-7700 

 

 

 

_____________________________________________________________________________/ 

 

2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. The Petitioner in this matter, BLOOMFIELD B.P.A., LLC, has the legal residence or 

principal office address of 6495 TELEGRAPH RD,BLOOMFIELD HILLS, MI 48301-

1759. Petitioner is a party in interest with respect to property taxes on property parcel 

no(s). (hereinafter referenced as the Subject Property) C -19-28-352-003. If the Subject 

Property in this petition includes more than one (1) real property tax parcel, the Subject 

Property’s tax parcels are contiguous. 

2. The Subject Property is located in Oakland County.

Page 2

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 2 of 5 

 

3. Respondent, Bloomfield Township of Oakland County, assesses and collects property 

taxes on the Subject Property. 

4. The Subject Property is real property and is classified as Commercial. The Subject 

Property is presently used or available for use for Commercial purposes. Petitioner 

believes that the Subject Property was originally designed to be used for Commercial 

purposes. 

5. Protest to the 2026 Board of Review was not made and is not required by law for the 

Subject Property. 

6. The Subject Property’s address is: 

6495 TELEGRAPH RD, BLOOMFIELD HILLS, MI 48301-1759 

7. This appeal involves issues relating to: (a) valuation, (b) assessment, (c) taxable value 

and (d) uniformity. 

8. The tax year(s) at issue are: 2026 

9. The values for the Subject Property as established by Respondent’s Board of Review are: 

 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable 

Value 

2026 

C -19-28-352-

003 

$1,983,420.00 

$991,710.00 

$741,400.00 

 

10. The 2026 assessment, assessed value, state equalized value and taxable value imposed 

upon all parcels of the Subject Property, and the taxes to be levied and collected thereon, 

are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: 

a. The assessment, assessed value, state equalized value and/or taxable value 

exceeds the amounts permitted by the Michigan Constitution, applicable 

statutes and case law;

Page 3

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 3 of 5 

 

b. The assessment, assessed value, state equalized value and/or taxable value are 

at higher percentages of true cash value than permissible under the Michigan 

Constitution, applicable statutes and case law; 

c. The assessment, assessed value, state equalized value and/or taxable value are 

based upon an erroneous determination of the true cash value of that portion 

of the Subject Property that is taxable under Michigan law, and are based 

upon the application of wrong principles; and 

d. The assessment, assessed value, state equalized value and/or taxable value, 

and the mode of assessment adopted by Respondent, discriminate against 

Petitioner and denies Petitioner its constitutional rights to uniformity, equal 

protection and dues process of law. 

11. Petitioner contends that the actual values for the Subject Property are: 

Tax Year 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

C -19-28-352-

003 

$820,000.00 

$410,000.00 

$410,000.00 

 

 

12. The amount of value in contention for the Subject Property is: 

 

Tax Year 

Parcel Number 

Assessed Value in Contention 

2026 

C -19-28-352-003 

$581,710.00 

 

13. Petitioner relies on the following specific facts to support the relief requested: Market 

sales and income data indicates that the subject property’s assessed value, state equalized 

value and taxable value exceed 50% of its actual market value. In addition, the cost less 

depreciation method Respondent utilizes to establish the Subject Property’s assessment at 

issue is not related to the Subject Property’s actual market value.

Page 4

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 4 of 5 

 

WHEREFORE, Petitioner requests that this Honorable Michigan Tax Tribunal enter an 

Order reducing the 2026 assessed value, state equalized value and taxable value for the Subject 

Property to the values stated in Paragraph 11 above and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

 

 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

COLLIERS INTERNATIONAL 

 

 

 

 

 

 

Representative for Petitioner 

 

 

 

 

 

 

 

By:_/s/ Joshua T. Shillair__Dated:05/26/2026 

 

 

 

 

 

 

Joshua T. Shillair, Esq. (P72674) 

Vice President | Tax Appeal 

400 E 4th Street, Suite 350 

Royal Oak, MI 48067 

O: 248-226-1632 

F: 248-226-1633 

Joshua.Shillair@Colliers.com

Page 5

2026 Entire Tribunal Property Tax Petition & Proof of Service 

BLOOMFIELD B.P.A., LLC v Bloomfield Township 

Parcel Number: C -19-28-352-003 

MTT Docket No.: 

 

Page 5 of 5 

 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

BLOOMFIELD B.P.A., LLC

Home Address (No., Street, P.O. Box or Rural Route)

6495 TELEGRAPH RD

City or Town

BLOOMFIELD HILLS

State

Michigan

ZIP Code

48301-1759

Telephone Number

2482261632

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

tax.efile@colliers.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Joshua

M.I.

Thomas

Last Name

Shillair

Firm Name (if any)

Colliers International

Address (No., Street, P.O. Box or Rural Route)

400 W 4th Street, Suite 350

City or Town

Royal Oak

State

Michigan

ZIP Code

48067

Telephone Number

248-226-1632

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

tax.efile@colliers.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

6495 TELEGRAPH RD

BLOOMFIELD HILLS

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48301-1759

Taxing Authority (City or Township)

Township Of Bloomfield (OAKLAND) 

County

Oakland

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

C -19-28-352-003.

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

991710

Current Taxable Value as established by the Board of Review:

741400

What do you believe is the fair market value (also known as True Cash Value)?

820000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

410000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ /s/Joshua T. Shillair

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052686937335

Supporting Waiver Documents:

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