Bps Land LLC Petitioner Vs. Township Of Bloomfield Respondent
- Petitioner
- Bps Land LLC
- Respondent
- Township Of Bloomfield
Case overview
- Docket number
- 26-002509-TT
- Status
- Disposed
- CaseType
- ET Property
- Division
- ET
- County
- Oakland
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 16 | Consent Judgment | Not recorded | 15 | 10/12/2026 | Not recorded | Download |
| 15 | An Amended Stipulation has been received | Not recorded | Not recorded | 09/25/2026 | $0.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 14 | Order Denying Motion | Not recorded | Not recorded | 09/24/2026 | Not recorded | Download |
| 13 | Prehearing General Call | Not recorded | Not recorded | 09/16/2026 | Not recorded | Download |
| 12 | A Stipulation has been received. | Not recorded | Not recorded | 09/12/2026 | $50.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 11 | Proof of service of petition was received. | PET | Not recorded | 08/06/2026 | Not recorded | Download |
| 10 | Order Setting Aside R Default | Not recorded | Not recorded | 09/04/2026 | Not recorded | Download |
| 9 | Proof of service was received. | Not recorded | Not recorded | 08/27/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 8 | Order of Default of Respondent | Not recorded | Not recorded | 08/27/2026 | Not recorded | Download |
| 7 | Order Setting Aside P Default | Not recorded | Not recorded | 08/27/2026 | Not recorded | Download |
| 6 | Response to Order | PET | Not recorded | 07/06/2026 | $150.00 | Download |
| 5 | Answer was received | RESP | Not recorded | 08/13/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Order of Default of Petitioner | Not recorded | Not recorded | 06/29/2026 | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 06/29/2026 | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 06/29/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 03/25/2026 | $275.00 | Download |
Documents
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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 BPS Land LLC, MICHIGAN TAX TRIBUNAL Petitioner, v MTT Docket No. 26-002509 Bloomfield Township, Presiding Judge Respondent. Rosemary Anger ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT CONSENT JUDGMENT The Tribunal has considered the file in this case and the submitted Stipulation for Entry of Consent Judgment (Stipulation) and finds that the Stipulation meets all filing and statutory requirements.1 As such, the Tribunal shall enter the Stipulation. Therefore, IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise indicated. IT IS FURTHER ORDERED that the officer charged with maintaining the assessment rolls for the tax years at issue shall correct or cause the assessment rolls to be corrected to reflect the property’s true cash and taxable values as provided in this Consent Judgment within 20 days of the entry of the Consent Judgment.2 IT IS FURTHER ORDERED that the officer charged with collecting or refunding the affected taxes shall collect taxes and any applicable interest or issue a refund as required by the Consent Judgment within 28 days of the entry of the Consent Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a proportionate share of any property tax administration fees paid and of penalty and interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, separately indicate the amount of the taxes, fees, penalties, and interest being refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless otherwise indicated, bear interest from the date of payment to the date of judgment and the judgment shall bear interest to the date of its payment. A sum determined by the Tribunal to have been underpaid shall not bear interest for any time period prior to 28 days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, (ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 1 See MCL 211.27a. 2 See MCL 205.755.
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MTT Docket No. 26-002509 Page 2 of 2 2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at the rate of 5.9%, (viii) after June 30,
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL BPS LAND LLC, Petitioner, vs. BLOOMFIELD TOWNSHIP, Respondent. MTT Docket No. 26-002509 _____________________________________________________________________________/ IVAN AMMORI THE AMMORI GROUP Representative for Petitioner 77 E. Long Lake Rd., Fl 1 Bloomfield Hills, MI 48304-2328 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 _____________________________________________________________________________/ STIPULATION FOR ENTRY OF CONSENT JUDGMENT 1. The case is pending in the _X__ Entire Tribunal ___ Small Claims Division. 2. Property Parcel Nos: C-19-06-205-018 and C-19-06-205-017 3. The property is located in Oakland County, MI. 4. The 2026 values for the property identified above as established by Respondent’s Board of Review are: (TCV=true cash value, AV=assessed value, TV=taxable value) Parcel Number Original TCV Original AV Original TV C-19-06-205-018 $119,020 59,510 $52,940 C-19-06-205-017 $285,280 $142,640 $52,940 5. The 2026 values for the property identified above as stipulated by the parties for settlement purposes are:
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MTT Docket No. 26-002509 Stipulation for Entry of Consent Judgment, Page 2 of 2 (TCV=true cash value, SEV=state equalized value, TV=taxable value) Parcel Number Original TCV Original AV Original TV C-19-06-205-018 $35,000 $17,5000 $17,500 C-19-06-205-017 $35,000 $17,5000 $17,500 6. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years (attach additional page if necessary): ____________________________________________________ 7. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc. (attach additional page if necessary): The parties agree that the stipulation regarding the subject property’s assessed and taxable values is strictly for settlement purposes only, and only for the years involved, and for no other purpose whatsoever. Petitioner hereby waives interest attributable to the reduction for all taxing authorities. Signature of Petitioner’s Authorized Representative or, if none, Petitioner: /s/ Ivan Ammori Ivan Ammori Signature of Respondent’s authorized representative: /s/ Laura M. Hallahan Laura M. Hallahan
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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: 26-002509 Is this case currently pending in the Small Claims Division? No Party Filing Document Joint Files Document Type: Response to Order Attachment File Name: Stipulation for Consent Judgment Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER DENYING STIPULATION FOR ENTRY OF CONSENT JUDGMENT The Tribunal has reviewed the case file and the Stipulation for Entry of Consent Judgment filed on September 12, 2026 and finds that the parties have failed to provide the correct true cash value indicated by the assessed value established by Respondent’s Board of Review, for the 2026 tax year. Therefore, IT IS ORDERED that the Stipulation for Entry of Consent Judgment is DENIED. IT IS FURTHER ORDERED that this case shall remain on the previously-scheduled Prehearing General Call and a Prehearing Conference will be scheduled accordingly. IT IS FURTHER ORDERED that because this Stipulation for Entry of Consent Judgment is no longer pending before the Tribunal, a new stipulation is required for any future settlement. However, if the new stipulation is filed within 14 days of the issuance of this order, no additional filing fee is required. By: /s/ Patricia L. Halm Entered: September 24, 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
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER DENYING STIPULATION FOR ENTRY OF CONSENT JUDGMENT The Tribunal has reviewed the case file and the Stipulation for Entry of Consent Judgment filed on September 12, 2026 and finds that the parties have failed to provide the correct true cash value indicated by the assessed value established by Respondent’s Board of Review, for the 2026 tax year. Therefore, IT IS ORDERED that the Stipulation for Entry of Consent Judgment is DENIED. IT IS FURTHER ORDERED that this case shall remain on the previously-scheduled Prehearing General Call and a Prehearing Conference will be scheduled accordingly. IT IS FURTHER ORDERED that because this Stipulation for Entry of Consent Judgment is no longer pending before the Tribunal, a new stipulation is required for any future settlement. However, if the new stipulation is filed within 14 days of the
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STATE
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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 NOTICE OF AUGUST 16- 31, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE BPS Land LLC, Petitioner, v Township Of Bloomfield, Respondent. MTT Docket No. 26-002509 Please be advised that 26-002509 has been placed on a two-week Prehearing General Call commencing August 16, 2027. Unless ordered otherwise, parties will be notified at least 28 days before they are scheduled to appear. Scheduling will not necessarily occur in the order in which the cases are listed below. Parties are required to submit a valuation disclosure or written notification that no valuation disclosure is required by the dates indicated herein. A “valuation disclosure” is defined as documentary or other tangible evidence in a property tax proceeding that a party relies upon in support of the party’s contention as to the true cash value of the subject property or any portion thereof and contains the party’s value conclusion and data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241. Users who file documents with the Tribunal are advised that filed documents are public records and will appear for public viewing on the Tribunal’s Tax Docket Lookup. If a user wishes to file a document for consideration by the Tribunal and prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents covered by the order will not be published. Documents filed prior to the issuance of a Protective Order will be published. In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or redacting personal identifying information (PII) from all documents filed with or offered to the Tribunal rests solely with the parties and their attorneys. The Tribunal is not responsible for or required to review, redact, or screen documents at the time of filing for PII whether filed electronically or on paper. A party, representative, or interested person (i.e. third party not part of an appeal) may request that the Tribunal redact PII contained in a previously filed document by submitting a Request for Redactions. The Request for Redactions form is available on the Entire Tribunal and Small Claims pages of the Tribunal’s website. Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s website for more information.
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MTT Docket No. 26-002509 Page 2 of 3 IT IS ORDERED that the parties shall: a. If no valuation disclosure is required, notify the Tribunal and the opposing parties in writing within 21 days of entry of this order that no valuation disclosure is being filed. The notice shall indicate the reason or reasons why no
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MTT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL BPS LAND LLC, Petitioner, vs. BLOOMFIELD TOWNSHIP, Respondent. MTT Docket No. 26-002509 _____________________________________________________________________________/ IVAN AMMORI THE AMMORI GROUP Representative for Petitioner 77 E. Long Lake Rd., Fl 1 Bloomfield Hills, MI 48304-2328 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 _____________________________________________________________________________/ STIPULATION FOR ENTRY OF CONSENT JUDGMENT 1. The case is pending in the _X__ Entire Tribunal ___ Small Claims Division. 2. Property Parcel Nos: C-19-06-205-018 and C-19-06-205-017 3. The property is located in Oakland County, MI. 4. The 2026 values for the property identified above as established by Respondent’s Board of Review are: (TCV=true cash value, AV=assessed value, TV=taxable value) Parcel Number Original TCV Original AV Original TV C-19-06-205-018 $119,200 59,510 $52,940 C-19-06-205-017 $285,280 $142,640 $52,940 5. The 2026 values for the property identified above as stipulated by the parties for settlement purposes are:
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MTT Docket No. 26-002509 Stipulation for Entry of Consent Judgment, Page 2 of 2 (TCV=true cash value, SEV=state equalized value, TV=taxable value) Parcel Number Revised TCV Revised AV Revised TV C-19-06-205-018 $35,000 $17,500 $17,500 C-19-06-205-017 $35,000 $17,500 $17,500 6. If stipulation addresses tax years other than the tax year originally appealed or tax years added through motions to amend that have been granted by the Tribunal, list the separate facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or years (attach additional page if necessary): ____________________________________________________ 7. List separately any special terms or conditions being proposed by the parties that would affect the execution of this Consent Judgment including, but not limited to, the joint payment of the refund, the waiver of interest, etc. (attach additional page if necessary): The parties agree that the stipulation regarding the subject property’s assessed and taxable values is strictly for settlement purposes only, and only for the years involved, and for no other purpose whatsoever. Petitioner hereby waives interest attributable to the reduction for all taxing authorities. Signature of Petitioner’s Authorized Representative or, if none, Petitioner: Ivan Ammori Signature of Respondent’s authorized representative: Laura M. Hallahan /s/ Laura M. Hallahan
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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: 26-002509 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Stip for Consent Judgment Attachment File Name: Stipulation for Consent Judgment - BPS Land Fee Information Filing Fee: $ 50.00 Payment Information Payment: $ 50.00
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RECEIVED AUG 1 02026 _ RIBUNAL STATE OF MICHIGAN MICHIGAN TAX T DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL BPS LAND, LLC, Petitioner, Vs. MTT Docket No. 26-002509 Bloomfield Township, Respondent. / PROOF OF SERVICE (Property Tax Petition) On the date below I sent by certified mail, return receipt requested, a copy of the Petition to: Township Assessor Township Supervisor Bloomfield Township Bloomfield Township 4200 Telegraph Rd 4200 Telegraph Rd PO Box 489 PO Box 489 Bloomfield Hills, MI 48303-0489 Bloomfield Hills, MI 48303-0489 On the date below 1 sent by first class mail a copy of the Petition to: Equalization Director County Clerk Oakland County Oakland County 250 Elizabeth Lake Rd, Ste 1000W 1200 N. Telegraph Rd, Bldg 12E Pontiac, MI 48341 Pontiac, MI 48341 Secretary, Board of Education State Treasurer School District of the City of Pontiac Department of Treasury 47200 Woodward Avenue 430 W. Allegan Street Pontiac, MI 48342 Lansing, MI 48922 [ declare that the statements above are true to the best of my information, knowledge and belief. V4
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Traninfo:4606 261065691 03/27/26 Chk: 102 Ants $275.00 ID: 1645 TELEGRARH LLC STATE OF MICHIGAN RECEIVED DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MAR 30 2026 BPS LAND, LLC, MICHIGAN TAX TRIBUNAL Vv Petitioner, MICHIGAN TAX TRIBUNAL Docket No, 26- 002509 CHARTER TOWNSHIP OF BLOOMFIELD, "Parcel No.: C-19-06-205-018, Respondent, and additional parcels PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) Petitioner, by and through its representative, The Ammori Group, contends: I. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use C-19-06-205-018 Vacant 202-Commercial | Vacant C-19-06-205-017 Vacant 202-Commercial | Vacant XI N/A. Ifthe assessment at issue was protested, the protest was made to Respondent’s: 0 March, O July, O December Board of Review. Respondent, identified above, assesses and collects taxes on the subject property. The subject property is located in the County of Oakland and school district of Pontiac City School District. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject propety. The Petitioner’s principal office/legal residence address is: 77 E. Long Lake Rd., Floor 1, Bloomfield Hills, MI 48304-2328.
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7. This appeal involves issues related to: Bd the subject property’s true cash and taxable values the subject property’s taxable value only there is a dispute as to the value of an addition or loss: OJ Yes [1 No uniformity of the subject property’s assessment the subject property’s exemption from ad valorem taxation under MCL 8. The tax year at issue is 2026. 9. The subject propeity is listed on the attachment, including, by parcel number: a, b. c. Respondent’s Board of Review established values,
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER SETTING ASIDE DEFAULT The Tribunal has considered the file in this case and finds that Respondent was held in default on August 27, 2026, and the default has been timely cured. The documents curing the default can be reviewed through the docket search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the document link next to the line item entry for the documents. Therefore, IT IS ORDERED that the Default is SET ASIDE. By: /s/ Patricia L. Halm Entered: September 4, 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
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER SETTING ASIDE DEFAULT The Tribunal has considered the file in this case and finds that Respondent was held in default on August 27, 2026, and the default has been timely cured. The documents curing the default can be reviewed through the docket search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the document link next to the line item entry for the documents. Therefore, IT IS ORDERED that the Default is SET ASIDE. By: /s/ Patricia L. Halm Entered: September 4, 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
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL BPS LAND LLC, Petitioner, vs. BLOOMFIELD TOWNSHIP, Respondent. MTT Docket No. 26-002509 _____________________________________________________________________________/ IVAN AMMORI THE AMMORI GROUP Representative for Petitioner 77 E. Long Lake Rd., Fl 1 Bloomfield Hills, MI 48304-2328 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 _____________________________________________________________________________/ PROOF OF SERVICE On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to Petition and Affirmative Defenses to: Ivan Ammori ammorigroup@gmail.com I declare that the statement above is true to the best of my information, knowledge and belief. __/s/ Laura M. Hallahan______________ Dated: August 27, 2026 Laura M. Hallahan
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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: 26-002509 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Proof of Service: Petition Attachment File Name: Proof of service Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Respondent filed proof evidencing service of the answer. However, the proof of service indicates the answer was not served on Petitioner’s authorized representative. As such, Respondent must submit proof the answer was properly served on Petitioner within 14 days of the entry of this order. See TTR 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: August 27, 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).
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MTT Docket No. 26-002509 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
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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
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MTT
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER SETTING ASIDE DEFAULT The Tribunal has considered the file in this case and finds that Petitioner was held in default on June 29, 2026, and the default has been timely cured. The documents curing the default can be reviewed through the docket search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the document link next to the line item entry for the documents. Therefore, IT IS ORDERED that the Default is SET ASIDE. By: /s/ Patricia L. Halm Entered: August 27, 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
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER SETTING ASIDE DEFAULT The Tribunal has considered the file in this case and finds that Petitioner was held in default on June 29, 2026, and the default has been timely cured. The documents curing the default can be reviewed through the docket search function on the Tribunal’s website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the document link next to the line item entry for the documents. Therefore, IT IS ORDERED that the Default is SET ASIDE. By: /s/ Patricia L. Halm Entered: August 27, 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
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RECEIVED JUL 092026 MICHIGAN TAX TRIBUNAL STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON I. BROWN, DPA GOVERNOR LANSING DIRECTOR BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. Tranlnfo:4606 26136218-1 07/08/26 ORDER OF DEFAULT Chih: 112 Ant: $150.00 The Tribunal has reviewed the file in the above-captioned case bind fin dEfEEN Le Petitioner did not pay the full required fee for the filing of the petition. See TTR 223. As such, the appeal is not properly pending. See TTR 225. Petitioner must pay the additional fee amount required for the filing of the petition within 14 days of the entry of this order. Tribunal rules and information on filing fees can be found on our website at www.michigan.gov/taxtrib. Unfortunately, the payment may not be made via e-filing. Therefore, IT IS ORDERED that Petitioner 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.i 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). y By: (Halu CAA A. J | alr~ Entered: June 29, 2026 Patricia L. Halm, Tribunal Chair PROOF OF SERVICE | 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
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MTT Docket No. 26-002509 Page 2 of 2 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 205.7352.” TTR 225(5)
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BPS Land LLC $0.740 2 77 E LONG LAKE RD us POSTAGE : g BLOOMFLD HLS, MI 48304 EROM 15304 E 5 11 Stamps.com DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS Michigan Tax Tribunal PO BOX 30232 LANSING MI 48909-7732
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL BPS LAND LLC, Petitioner, vs. BLOOMFIELD TOWNSHIP, Respondent. MTT Docket No. 26-002509 _____________________________________________________________________________/ IVAN AMMORI THE AMMORI GROUP Representative for Petitioner 77 E. Long Lake Rd., Fl 1 Bloomfield Hills, MI 48304-2328 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 Bloomfield Township, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 1. Respondent admits the allegations in Paragraph 1 as to the parcel number, address, classification, County, and school district. 2. Respondent admits that no Board of Review protest was made. 3. Respondent admits the allegations in Paragraph 3. 4. Respondent lacks the information necessary to respond to the allegations in Paragraph 4 and leaves Petitioner to its proofs.
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Entire Tribunal Property Tax Answer Page 2 of 6 5. Respondent lacks the information necessary to respond to the allegations in Paragraph 4 and leaves Petitioner to its proofs. 6. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal, but denies that those issues have merit and also denies that Petitioner is entitled to any relief. 7. Respondent admits the allegations in Paragraph 7. 8. The 2026 values for the property identified above as established by Respondent’s Board of Review are: (TCV=true cash value, AV=assessed value, TV=taxable value) Parcel Number Original TCV Original AV Original TV C-19-06-205-018 $119,200 59,510 $52,940 C-19-06-205-017 $285,280 $142,640 $52,940 9. Respondent contends that the 2026 values for the property identified above are: (TCV=true cash value, AV=assessed value, TV=taxable value) Parcel Number Original TCV Original AV Original TV C-19-06-205-018 $119,200 59,510 $52,940 C-19-06-205-017 $285,280 $142,640 $52,940 10. The values in dispute for the property identified above are: (TCV=true cash value, AV=assessed value, TV=taxable value) Parcel Number Original TCV Original AV Original TV C-19-06-205-018 $0 $0 $0 C-19-06-205-017 $0 $0 $0 11. Petitioner is not entitled to the relief requested in Paragraph 11, including all subparagraphs, for the reason that Petitioner’s amounts do not reflect the accurate valuations for this property. 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
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Entire Tribunal
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Entire
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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. 26-002509 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. M Last Name Halahan 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 48302-2073 Telephone Number 2487313090 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) lhallahan@hallahanlaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Laura M. Hallahan /s/
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL ENTIRE TRIBUNAL v MTT Docket No. 26-002509 Township Of Bloomfield, Respondent. ORDER OF DEFAULT The Tribunal has reviewed the file in the above-captioned case and finds that: Petitioner did not pay the full required fee for the filing of the petition. See TTR 223. As such, the appeal is not properly pending. See TTR 225. Petitioner must pay the additional fee amount required for the filing of the petition within 14 days of the entry of this order. Tribunal rules and information on filing fees can be found on our website at www.michigan.gov/taxtrib. Unfortunately, the payment may not be made via e-filing. Therefore, IT IS ORDERED that Petitioner 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.i 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:_______________________________ Entered: June 29, 2026 Patricia L. Halm, Tribunal Chair 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 i “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
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MTT Docket No. 26-002509 Page 2 of 2 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)
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR MICHIGAN TAX TRIBUNAL ·
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MTT
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Traninfo:de0h 261066451 03/27/26 Chit: 102 Ant: $275.00 1D: 1645 TELEGRAPH LLE STATE OF MICHIGAN RECEIVED DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MAR 80 2026 BPS LAND, LLC, MICHIGAN TAX TRIBUNAL v Petitioner, MICHIGAN TAX TRIBUNAL Docket No. 26- CHARTER TOWNSHIP OF BLOOMFIELD, Parcel No.: C-19-06-205-018, Respondent. and additional parcels PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) Petitioner, by and through its representative, The Ammori Group, contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use C-19-06-205-018 Vacant 202-Commercial | Vacant C-19-06-205-017 Vacant 202-Commercial | Vacant N/A. If the assessment at issue was protested, the protest was made to Respondent’s: [J March, [J July, [J December Board of Review. Respondent, identified above, assesses and collects taxes on the subject property. The subject property is located in the County of Oakland and school district of Pontiac City School District. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. The Petitioner’s principal office/legal residence address is: 77 E. Long Lake Rd., Floor 1, Bloomfield Hills, MI 48304-2328.
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7. This appeal involves issues related to: [XI the subject property’s true cash and taxable values [0 the subject property’s taxable value only there is a dispute as to the value of an addition or loss: [J Yes [0 No [O uniformity of the subject property’s assessment [0 the subject property’s exemption from ad valorem taxation under MCL 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values are based upon an erroneous determination of the true cash value of that portion of Petitioner’s property that is taxable under Michigan law and are based upon the application of wrong principles; and d. The assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection
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Pet
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002509 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: June 29, 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
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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 BPS Land LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-002509 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
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STA
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Traninfo:de0h 261066451 03/27/26 Chit: 102 Ant: $275.00 1D: 1645 TELEGRAPH LLE STATE OF MICHIGAN RECEIVED DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MAR 80 2026 BPS LAND, LLC, MICHIGAN TAX TRIBUNAL v Petitioner, MICHIGAN TAX TRIBUNAL Docket No. 26- CHARTER TOWNSHIP OF BLOOMFIELD, Parcel No.: C-19-06-205-018, Respondent. and additional parcels PROPERTY TAX PETITION (Entire Tribunal, 2026 Tax Year) Petitioner, by and through its representative, The Ammori Group, contends: 1. The property that is the subject of this appeal consists of these contiguous real property parcels: REAL PROPERTY - CONTIGUOUS Parcel Number Address Classification Use C-19-06-205-018 Vacant 202-Commercial | Vacant C-19-06-205-017 Vacant 202-Commercial | Vacant N/A. If the assessment at issue was protested, the protest was made to Respondent’s: [J March, [J July, [J December Board of Review. Respondent, identified above, assesses and collects taxes on the subject property. The subject property is located in the County of Oakland and school district of Pontiac City School District. Petitioner is a taxpayer/party-in-interest with respect to property taxes on the subject property. The Petitioner’s principal office/legal residence address is: 77 E. Long Lake Rd., Floor 1, Bloomfield Hills, MI 48304-2328.
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7. This appeal involves issues related to: [XI the subject property’s true cash and taxable values [0 the subject property’s taxable value only there is a dispute as to the value of an addition or loss: [J Yes [0 No [O uniformity of the subject property’s assessment [0 the subject property’s exemption from ad valorem taxation under MCL 8. The tax year at issue is 2026. 9. The subject property is listed on the attachment, including, by parcel number: a. Respondent’s Board of Review established values, b. Petitioner’s value contentions, and c. Values in dispute. 10. Petitioner relies upon the following to support the relief requested: The 2026 values imposed on Petitioner’s property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reasons that: a. The assessed, state equalized and/or taxable values exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessed, state equalized and/or taxable values are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessed, state equalized and/or taxable values are based upon an erroneous determination of the true cash value of that portion of Petitioner’s property that is taxable under Michigan law and are based upon the application of wrong principles; and d. The assessed, state equalized and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights of uniformity, equal protection
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Pet
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