Oakland Hills Country Club, Petitioner Vs. Township Of Bloomfield, Respondent

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 

Oakland Hills Country Club, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000554 

 

Bloomfield Township, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

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 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 26-000554 

Page 2 of 2 

 

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, 

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, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

and (xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

Entered: May 5, 2026 

 

 

 

 

By: /s/ Jason C. Grinnell_ 

 

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

Wl 

GC 

RECEIVED 

APR 29 2025 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS yicHIGAN TAX TRIBUNAL 

MICHIGAN TAX TRIBUNAL 

OAKLAND HILLS COUNTRY CLUB, 

Petitioner, 

\2 

MTT Docket No. 26-000554 

BLOOMFIELD TWP., 

Respondent. 

/ 

AMENDED STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The parcel is located in Oakland County. 

2: 

The case is pending in the X Entire Tribunal OR __ Small Claims Division. 

3. 

Property Parcel No: C-19-33-201-031. 

4. 

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

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2026 

$53,554,640 

$26,777,320 

$25,793,970 

5: 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value* 

2026 

$53,554,640 

$26,777,320 

$4,399,637 

Previous Year TV 

Inflation Rate 

TV x Inflation Rate* 

2022 TV Calculation 

2,788,980 

1.033 

2,881,010 

2023 TV Calculation 

2,881,010 

1.050 

3,025,060 

2024 TV Calculation 

3,025,060 

1.050 

3,176,310

Page 2

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.: 

Honigman LLP 

Giarmarco, Mullins & Horton, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

By: /s/ Stewart L. Mandell 

By: /s/ Anthony K, Chubb 

Stewart L.. Mandell (P33781) 

Anthony K. Chubb (P72608) 

Jackie J. Cook (P68781) 

Stephen J. Hitchcock (P15005) 

660 Woodward Avenue 

101 W. Big Beaver Road 

2290 First National Building 

Troy, MI 48084 

Detroit, M1 48226-3506 

(248) 457-7000 

(313) 465-7420 

achubb@gmhlaw.com 

slmandell@honigman.com 

sh@gmhlaw.com 

jcook@honigman.com 

Dated: April 28, 2026 

Dated: April 28, 2026

Page 3

Honigman LLP 

COSTS ADVANCED ACCOUNT 

040702 

Invoice Date 

Invoice Number 

Invoice Narrative 

Payment Amount 

4/29/26 

040702 

281122/578841/DLS 

#EEG50,00% 

4+ 

Stipulation Filing Fee 

21074678.1

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Page 1

Oakland Hills Country Club, 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

RECEIVED 

APR 9.9 2026 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

Bloomfield Township, 

Respondent. 

MTT Docket No. 26-000554 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

slmandell@honigman.com 

icook@honigman.com 

Anthony K. Chubb (P72608) 

Stephen J. Hitchcock (P15005) 

Attorneys for Respondent 

Giarmarco, Mullins & Horton, PC 

101 W. Big Beaver Road, 10th Floor 

Troy, Michigan 48084 

(248) 457-7000 

achubb@gmbhlaw.com 

sjih@gmhlaw.com 

The Parties’ Joint Response To Order Entered April 23, 2026 

Through their counsel, the Parties submit this Joint Response to the Tribunal’s April 23, 

2026 Order (the “Order”). 

Pursuant to the Order, Petitioner Oakland Hills Country Club 

is 

submitting this Response and Respondent Bloomfield Township has joined in this submission. 

Attached to this Response is an Amended Stipulation for Entry of Consent Judgment (the 

“Amended Stipulation”). 

The Tribunal’s efiling system 

is down at this time, therefore this

Page 2

The Amended Stipulation changes the calculations of the subject tax parcels 2026 taxable 

value. 

The Amended Stipulations calculations of the 2026 taxable value are in the table that is 

below. 

Previous Year TV 

~~ Inflation Rate 

TV x Inflation Rate 

2022 TV Calculation 

2023 TV Calculation 

2024 TV Calculation 

2025 TV Calculation 

2026 TV Calculation 

2,788,980 

1.033 

2,881,010 

2,881,010 

1.050 

3,025,060 

3,025,060 

1.050 

3,176,310 

3,176,310 

1.031 

4,283,970 

4,283,970 

1.027 

4,399,637 

The Amended Stipulation’s changes in the calculations for the 2026 taxable value are as follows: 

1) 

The 2025 taxable value includes an addition for a storage structure that is not part of 

the clubhouse that a fire destroyed in 2022. The inclusion of this addition is proper. 

2) 

Because the 2025 taxable value is 4,283,970, the 2026 taxable value is 4,399,637. 

The Parties hope that the Tribunal finds the above explanation of the 2025 taxable value, 

as well as the revised calculation of the 2026 taxable value and the Amended Stipulation, to be 

fully responsive to the Order. 

The Parties respectfully request that the Tribunal enter a Consent 

Judgment that grants and adopts the Parties” Amended Stipulation for Entry of Consent Judgment. 

Honigman LLP 

Attorneys for Petitioner 

By: /s/ Stewart L. Mandell 

Giarmarco, Mullins & Horton, P.C. 

Attorneys for Respondent 

By: /s/ Anthony K. Chubb 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

660 Woodward Avenue 

2290 First National Building 

Anthony K. Chubb (P72608) 

Stephen J. Hitchcock (P15005) 

101 W. Big Beaver Road 

Troy, MI 48084

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

OAKLAND HILLS COUNTRY CLUB, 

Petitioner, 

v 

MTT Docket No. 26-000554 

BLOOMFIELD TWP, 

Respondent. 

/ 

AMENDED STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

1. 

The parcel is located in Oakland County. 

2. 

The case is pending in the X Entire Tribunal OR __ Small Claims Division. 

3. 

Property Parcel No: C-19-33-201-031. 

4. 

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

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2026 

$53,554,640 

$26,777,320 

$25,793,970 

5. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value* 

2026 

$53,554,640 

$26,777,320 

$4,399,637 

Previous Year TV 

Inflation Rate 

TV x Inflation Rate* 

2022 TV Calculation 

2,788,980 

1.033 

2,881,010 

2023 TV Calculation 

2,881,010 

1.050 

3,025,060 

2024 TV Calculation 

3,025,060 

1.050 

3,176,310 

2025 TV Calculation 

3,176,310 

1.031 

4,283,970

Page 4

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.: 

Honigman LLP 

Giarmarco, Mullins & Horton, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

By: /s/ Stewart L. Mandell 

By: /s/ Anthony K. Chubb 

Stewart L. Mandell (P33781) 

Anthony K. Chubb (P72608) 

Jackie J. Cook (P68781) 

Stephen J. Hitchcock (P15005) 

660 Woodward Avenue 

101 W. Big Beaver Road 

2290 First National Building 

Troy, MI 48084 

Detroit, MI 48226-3506 

(248) 457-7000 

(313) 465-7420 

achubb@gmhlaw.com 

simandell@honigman.com 

sh@gmhlaw.com 

jcook@honigman.com 

Dated: April 28, 2026

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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 

Oakland Hills Country Club, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000554 

 

Bloomfield Township, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

ORDER REQUIRING INFORMATION 

 

On April 14, 2026, Petitioner filed a Stipulation for Entry of Consent Judgment 

(stipulation). In the stipulation, the parties provided the following statement and 

calculations to arrive at their contended taxable value (TV) for 2026. 

 

 

 

 

However, BS&A records for the subject property do not reflect the same 2025 TV the 

parties used to calculate the 2026 TV. Further, there is no evidence for the Tribunal to 

rely on to support the 2025 assessment was lowered by the Board of Review or 

appealed to the Tribunal.

Page 2

MTT Docket No. 26-000554 

Page 2 of 2 

 

Accordingly, before entering the stipulation, Petitioner must provide evidence to 

substantiate what the correct 2025 TV was for the subject property. Further, if it is 

determined that the correct TV for the subject property for tax year 2025 is $4,283,970, 

Petitioner must provide legal authority for the Tribunal to use the parties’ 2025 TV to 

calculate the 2026 taxable value. 

 

Therefore, 

 

IT IS ORDERED that Petitioner shall file the following within 14 days of the entry of this 

order: (1) evidence to support the correct 2025 TV for the subject property, and (2) proof 

evidencing service of the documentation on Respondent. 

 

Petitioner’s failure to comply with this Order within 14 days will result in the denial of the 

stipulation. 

 

 

 

Entered: April 23, 2026 

 

 

 

 

By: /s/ Jason C. Grinnell_ 

jcg 

 

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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Page 1

26-0004 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Oakland Hills Country Club, 

Petitioner, 

v. 

MTT Docket No. _______________ 

Parcel No. C-19-33-201-031 

Bloomfield Twp., 

Respondent. 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

PETITION 

Oakland Hills Country Club (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 3951 West Maple Road. Petitioner is a party 

in interest with respect to property taxes on tax parcel number C-19-33-201-031 ("Petitioner's 

Property"), with an address of 3831 W. Maple Road, located in Oakland County, Michigan. 

2. 

Respondent, Bloomfield Township, assesses and collects property taxes on 

Petitioner's Property.

Page 2

2 

75016356.3 

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$25,793,970 and assessed Petitioner's Property at $26,777,320, which will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

4. 

Petitioner's Property is classified as Commercial Real Property. Petitioner's 

Property is presently used or available for use for commercial purposes. Petitioner believes that 

Petitioner's Property was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, (d) due process, (e) equal protection and (f) uniformity. 

7. 

Petitioner timely protested to the March Board of Review, however, no protest to 

the March Board was required. 

8. 

Pursuant to MCL 211.34d(1)(b)(v), the 2026 taxable value of Petitioner’s Property 

is $3,363,195. 

9. 

Additionally, the 2026 assessment, including state equalized value and taxable 

value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid 

and unlawful for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, are 

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

Page 3

3 

75016356.3 

Property that is taxable under Michigan law, and are based upon the application of wrong 

principles; and, 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: i) reducing the 

2026 taxable value of Petitioner's Property from $25,793,970 to $3,363,195; ii) reducing the 2026 

assessed and state equalized value of Petitioner's Property from $26,777,320 to $23,000,000; iii) 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs; and iv) granting Petitioner any other relief to which it is entitled. 

Dated: April 9, 2026

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:/s/ Stewart L. Mandell _____________________

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

660 Woodward Avenue 

2290 First National Bldg. 

Detroit, MI 48226-3506 

(313) 465-7420 

(313) 465-7270 

slmandell@honigman.com

jcook@honigman.com

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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

Oakland Hills Country Club, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000554

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: April 21, 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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Page 1

75023246.1

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

OAKLAND HILLS COUNTRY CLUB,

Petitioner,

v

MTT Docket No. 26-000554

BLOOMFIELD TWP.,

Respondent.

_____________________________/

STIPULATION FOR ENTRY OF CONSENT JUDGMENT

1.

The parcel is located in Oakland County.

2.

The case is pending in the X Entire Tribunal OR __ Small Claims Division.

3.

Property Parcel No: C-19-33-201-031.

4.

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

$53,554,640

$26,777,320

$25,793,970

5.

The values for the property identified above as stipulated by the parties for settlement

purposes are:

Tax

Year

True Cash

Value

State Equalized

Value

Taxable

Value*

2026

$53,554,640

$26,777,320

$3,363,195

*The stipulated taxable value has been calculated pursuant to MCL 211.34d(1)(b)(v) for

replacement construction resulting from the property suffering damage, starting with a fire

in 2022. Per MCL 211.34d(1)(b)(v), the calculations below started with the 2021 taxable

value of $2,788,980 and adjusted for the inflation rate multipliers in each subsequent year.

Page 2

2

75023246.1

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.:

Honigman LLP

Attorneys for Petitioner

Giarmarco, Mullins & Horton, P.C.

Attorneys for Respondent

By: /s/ Stewart L. Mandell

By: /s/ Anthony K. Chubb

Stewart L. Mandell (P33781)

Jackie J. Cook (P68781)

660 Woodward Avenue

2290 First National Building

Detroit, MI 48226-3506

(313) 465-7420

slmandell@honigman.com

jcook@honigman.com

Anthony K. Chubb (P72608)

Stephen J. Hitchcock (P15005)

101 W. Big Beaver Road

Troy, MI 48084

(248) 457-7000

achubb@gmhlaw.com

sh@gmhlaw.com

Dated: April 14, 2026

Dated: April 14, 2026

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Oakland Hills Country Club, 

Petitioner, 

v. 

MIT Docket Ne. 

[p-C00 559 

Parcel Number C-19-33-201-031 

Bloomfield Twp., 

Respondent. 

PROOF OF SERVICE 

Lisa Joseph states that on 

LH // 0 [2 b 

, she did serve a copy of Petitioner's Petition, 

with docket number, upon the parties named on the attached list. 

Lo] Fin Qpeeph. 

Lisa Joseph 

26-0004 

75016356.3

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

BLOOMFIELD TWP. 

34200 TELEGRAPH ROAD 

BLOOMFIELD TWP, MICHIGAN 48303 

ASSESSOR 

BLOOMFIELD TWP. 

34200 TELEGRAPH ROAD 

BLOOMFIELD TWP, MICHIGAN 48303 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

250 ELIZABETH LAKE RD., SUITE 1000 W. 

PONTIAC, MI 48341 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

250 E. HURON AVENUE 

PONTIAC, MI 48341 

SECRETARY OF SCHOOL BOARD 

BIRMINGHAM PUBLIC SCHOOLS 

31301 EVERGREEN ROAD 

BEVERLY HILLS, MI 48025-3800 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0004 

75016356.3

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

OAKLAND HILLS COUNTRY CLUB, 

 

Petitioner, 

 

 

 

 

 

 

MTT Docket No. 26-000554 

v. 

 

BLOOMFIELD TOWNSHIP, 

 

Respondent. 

 

 

STEWART L. MANDELL (P33781) 

JACKIE J. COOK (P68781) 

Attorney for Petitioner 

HONIGMAN LLP 

39400 Woodward Ave., Ste. 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

jcook@honigman.com 

 

ANTHONY K. CHUBB (P72608) 

STEPHEN J. HITCHCOCK (P15005) 

Attorneys for Respondent 

GIARMARCO, MULLINS & HORTON, PC 

101 W. Big Beaver Road, 10th Floor 

Troy, Michigan 48084 

(248) 457-7000 

achubb@gmhlaw.com 

sjh@gmhlaw.com 

 

 

RESPONDENT'S ANSWER TO PETITION, 

AFFIRMATIVE DEFENSES, AND PROOF OF SERVICE 

 

NOW 

COMES 

Respondent, 

BLOOMFIELD 

TOWNSHIP, 

by 

its 

attorneys, 

GIARMARCO, MULLINS & HORTON, P.C., and for its answer to the Petition, states as follows: 

1. 

In response to paragraph 1, Respondent neither admits nor denies same for lack of 

sufficient information and leaves Petitioner to its proofs. 

2. 

In response to paragraph 2, Respondent admits the same. 

3. 

In response to paragraph 3, Respondent admits the same. 

4. 

In response to paragraph 4, Respondent neither admits nor denies same for lack of 

sufficient information and leaves Petitioner to its proofs. 

5. 

In response to paragraph 5, Respondent denies same as being untrue.

Page 2

6. 

No paragraph 6, no response required. 

7. 

In response to paragraph 7, Respondent neither admits nor denies same for lack of 

sufficient information and leaves Petitioner to its proofs. 

8. 

In response to paragraph 8, Respondent denies same as being untrue. 

9. 

In response to paragraph 9, including subparagraphs a-d, Respondent denies same 

for the reason that it is untrue 

WHEREFORE, Respondent requests that the Michigan Tax Tribunal enter an Order 

dismissing Petitioner’s Petition with costs and attorney fees to Respondent. 

 

 

 

 

 

 

GIARMARCO, MULLINS & HORTON, P.C. 

 

 

 /s/ Anthony K. Chubb 

 

 

 

 

 

 

 

 

ANTHONY K. CHUBB (P72608) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

101 West Big Beaver, Tenth Floor 

 

 

Troy, MI 48084 

 

 

(48) 457-7000; Fax: (248) 404-6334 

 

 

achubb@gmhlaw.com 

Dated: April 10, 2026 

 

AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent, BLOOMFIELD TOWNSHIP, through its attorneys, 

GIARMARCO, MULLINS & HORTON, P.C., and files the following affirmative defenses to the 

Petition: 

1. 

The facts as alleged by the Petitioner do not establish mutual mistake of fact. 

2. 

Petitioner has failed to allege specific and sufficient facts upon which the mode and 

method of appraising property fails to conform with mode and method applied to all other 

properties in the community. 

3. 

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

to the true cash value of the property.

Page 3

4. 

Petitioner’s claim, if prevailed upon, would create a windfall for Petitioner and create 

a burden upon the City, schools, county taxes, and other property owners in the community. 

5. 

Petitioner is asking this Honorable Tribunal to make an underassessment based upon 

an arbitrary basis. 

6. 

A levy of all taxes are required to be made based upon the assessment of fifty (50%) 

percent of true cash value as ultimately determined by the process of county and state equalization. 

7. 

Respondent reserves the right to file additional Affirmative Defenses as may 

become apparent in this case. 

 

 

 

 

 

 

GIARMARCO, MULLINS & HORTON, P.C. 

 

 

 /s/ Anthony K. Chubb 

 

 

 

 

 

 

 

 

ANTHONY K. CHUBB (P72608) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

101 West Big Beaver, Tenth Floor 

 

 

Troy, MI 48084 

 

 

(48) 457-7000; Fax: (248) 404-6334 

 

 

achubb@gmhlaw.com 

Dated: April 10, 2026 

 

PROOF OF SERVICE 

 

JOAN M. SIDLAUSKAS, being duly sworn deposes and says that on April 10, 2026, she 

did cause to be served upon all attorneys of record the foregoing document via regular first-class 

mail: 

 

Stewart L. Mandell 

Jackie J. Cook 

HONIGMAN LLP 

39400 Woodward Ave., Ste. 101 

Bloomfield Hills, MI 48304-5151 

 

 

 

 

 

 

 

/s/ Joan M. Sidlauskas 

 

 

 

 

 

 

 

 

 

 

 

Joan M. Sidlauskas

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

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 26-000554

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Bloomfield (OAKLAND)

Local Unit of Government/First Name

Anthony

M.I.

K

Last Name

Chubb

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

101 W. Big Beaver Road

City or Town

Troy

State

Michigan

ZIP Code

48084

Telephone Number

248-457-7024

Fax Number

248-457-7001

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

achubb@gmhlaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Anthony

M.I.

K

Last Name

Chubb

Firm Name (if any)

Giarmarco Mullins & Horton, PC

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

101 W. Big Beaver Road

10th Floor

City or Town

Troy

State

Michigan

ZIP Code

48084

Telephone Number

248-457-7053

Fax Number

248-457-7001

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

achubb@gmhlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Anthony K. Chubb

/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

26-0004 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Oakland Hills Country Club, 

Petitioner, 

v. 

MTT Docket No. _______________ 

Parcel No. C-19-33-201-031 

Bloomfield Twp., 

Respondent. 

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

jcook@honigman.com

PETITION 

Oakland Hills Country Club (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 3951 West Maple Road. Petitioner is a party 

in interest with respect to property taxes on tax parcel number C-19-33-201-031 ("Petitioner's 

Property"), with an address of 3831 W. Maple Road, located in Oakland County, Michigan. 

2. 

Respondent, Bloomfield Township, assesses and collects property taxes on 

Petitioner's Property.

Page 2

2 

75016356.3 

3. 

In 2026, Respondent determined the taxable value of Petitioner's Property to be 

$25,793,970 and assessed Petitioner's Property at $26,777,320, which will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

4. 

Petitioner's Property is classified as Commercial Real Property. Petitioner's 

Property is presently used or available for use for commercial purposes. Petitioner believes that 

Petitioner's Property was originally designed to be used for commercial purposes. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, (d) due process, (e) equal protection and (f) uniformity. 

7. 

Petitioner timely protested to the March Board of Review, however, no protest to 

the March Board was required. 

8. 

Pursuant to MCL 211.34d(1)(b)(v), the 2026 taxable value of Petitioner’s Property 

is $3,363,195. 

9. 

Additionally, the 2026 assessment, including state equalized value and taxable 

value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid 

and unlawful for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, are at 

higher percentages of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, are 

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

Page 3

3 

75016356.3 

Property that is taxable under Michigan law, and are based upon the application of wrong 

principles; and, 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: i) reducing the 

2026 taxable value of Petitioner's Property from $25,793,970 to $3,363,195; ii) reducing the 2026 

assessed and state equalized value of Petitioner's Property from $26,777,320 to $23,000,000; iii) 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs; and iv) granting Petitioner any other relief to which it is entitled. 

Dated: April 9, 2026

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:/s/ Stewart L. Mandell _____________________

Stewart L. Mandell (P33781) 

Jackie J. Cook (P68781) 

660 Woodward Avenue 

2290 First National Bldg. 

Detroit, MI 48226-3506 

(313) 465-7420 

(313) 465-7270 

slmandell@honigman.com

jcook@honigman.com

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

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Oakland Hills Country Club

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

3951 West Maple Road

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48301

Telephone Number

3134657420

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

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

slmandell@honigman.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

Michigan

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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

C-19-33-201-031

Classification of Property: Real 

Commercial

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

26777320

Current Taxable Value as established by the Board of Review:

25793970

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

46000000

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

23000000

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

25430775

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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.

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/ Stewart L. Mandell

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