Sams Real Estate Business Trust, Petitioner Vs. City Of Auburn Hills, 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 

Sams Real Estate Business Trust, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002396 

 

City of Auburn Hills, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ 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%, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-002396 

Page 2 of 2 

 

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

8.66%. 

 

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. 

 

 

 

 

 

 

 

 

By _______________________________ 

Entered: August 7, 2025 

 

 

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

61304820.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SAM'S REAL ESTATE BUSINESS, 

 

 

Petitioner, 

 

v 

MTT Docket No. 25-002396 

 

AUBURN HILLS, 

 

 

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: 63-02-14-04-127-009. 

 

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 

2025

$8,667,640

$4,333,820

$3,760,900

 

 

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 

2025

$6,458,112

$3,229,056

$3,229,056

 

 

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.:

Page 2

MTT Docket No. 25-002396 

Stipulation for Entry of Consent Judgment 

 

 

 

2 

61304820.1 

 

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be 

made payable jointly to Petitioner named herein and its counsel, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660 

Woodward, Suite 2290, Detroit, MI 48226. Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

 

All interest due hereunder is waived if, and only if, all refunds otherwise 

due are paid within 60 days of the entry of the consent judgment, however, 

otherwise interest shall be paid as provided in the Tax Tribunal Act, 

including MCL 205.737. 

 

 

 

HONIGMAN LLP

HALLAHAN & ASSOCIATES, P.C.

Attorneys for Petitioner

Attorneys for Respondent

 

 

By: _______________________________ 

By: _____________________________ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com

Laura M. Hallahan (P42101) 

1750 Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3090 

lhallahan@hallahanlaw.com 

 

 

 

Dated: __________________ 

 

Dated: ____________________ 

 

 

 

( 

 

 

/s/ Daniel L. Stanley 

 

 

 

 Laura M. Hallahan (w/permission)

July 23, 2025 

 

 

 

 

 July 23, 2025

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Page 1

61304820.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SAM'S REAL ESTATE BUSINESS, 

 

 

Petitioner, 

 

v 

MTT Docket No. 25-002396 

 

AUBURN HILLS, 

 

 

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: 63-02-14-04-127-009. 

 

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 

2025

$8,667,640

$4,333,820

$3,760,900

 

 

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 

2025

$6,458,112

$3,229,056

$3,229,056

 

 

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.:

Page 2

MTT Docket No. 25-002396 

Stipulation for Entry of Consent Judgment 

 

 

 

2 

61304820.1 

 

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be 

made payable jointly to Petitioner named herein and its counsel, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660 

Woodward, Suite 2290, Detroit, MI 48226. Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

 

All interest due hereunder is waived if, and only if, all refunds otherwise 

due are paid within 60 days of the entry of the consent judgment, however, 

otherwise interest shall be paid as provided in the Tax Tribunal Act, 

including MCL 205.737. 

 

 

 

HONIGMAN LLP

HALLAHAN & ASSOCIATES, P.C.

Attorneys for Petitioner

Attorneys for Respondent

 

 

By: _______________________________ 

By: _____________________________ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com

Laura M. Hallahan (P42101) 

1750 Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3090 

lhallahan@hallahanlaw.com 

 

 

 

Dated: __________________ 

 

Dated: ____________________ 

 

 

 

( 

 

 

/s/ Daniel L. Stanley 

 

 

 

 Laura M. Hallahan (w/permission)

July 23, 2025 

 

 

 

 

 July 23, 2025

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SAM’S REAL ESTATE BUSINESS TRUST, 

 

 

 

Petitioner, 

 

v 

 

CITY OF AUIBURN HILLS, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-002396 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

660 Woodward Avenue 

2290 First National Building 

Detroit, MI 48226-3506 

(313) 465-7622 

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 SEVERED PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Auburn Hills, 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 necessary to respond to the allegations in 

Paragraph 1 and leaves Petitioner to its proofs. 

2. 

Respondent admits the allegations in Paragraph 2 insofar as it is the entity that 

assesses and collects property taxes with relation to the parcel identified in the Petition. 

3. 

Respondent admits the allegations in Paragraph 3 as to the stated values.

Page 2

2

4. 

Respondent admits that subject property is classified as commercial. With respect 

to the remaining allegations in Paragraph 4, Respondent lacks knowledge or information sufficient 

to form a belief as to the truth of the allegations contained therein and leaves Petitioner to its 

proofs. 

5. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies 

that Petitioner’s claims have merit. 

6. 

Respondent denies the allegations in Paragraph 6. 

7. 

Respondent neither admits nor denies the statement in Paragraph 7 for the reason 

that no assertion was made. In further answer, Petitioner only sets forth a hypothetical condition 

(i.e., “if P.A. 174 of 2006 requires a board of review protest . . .) but then fails to state whether or 

not a protest was made. 

8. 

Respondent denies the allegations in Paragraph 8, including subparagraphs (a)-(d), 

for the reason that the same are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of 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. 

9. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent, City of Auburn Hills, 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.

Page 3

3

HALLAHAN & ASSOCIATES, P.C. 

 

__/s/Laura M. Hallahan________________ 

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: July 23, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Auburn Hills, 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

Page 4

4

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 and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a

Page 5

5

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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. 25-002396

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Auburn Hills (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

248-731-3087

Fax Number

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: 

Kelsea M. Melcher

/s/

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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

Sams Real Estate Business Trust, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 MTT Docket No. 25-002396

City Of Auburn Hills,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on July 23, 2025, and 

finds that: a consent judgment can only be entered if a stipulation is filed after the filing 

of a petition and answer. See TTR 253 and TTR 283. Because no answer has been 

filed in this case, the stipulation cannot be entered at this time and must be denied. 

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall be placed on a Prehearing General Call 

in the normal course of scheduling.

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 _____________________________

 

 Jason C. Grinnell, Tribunal Member

Entered: July 23, 2025

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 2

MTT Docket No. 25-002396

Page 2 of 6

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

Sams Real Estate Business Trust, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 MTT Docket No. 25-002396

City Of Auburn Hills,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on July 23, 2025, and 

finds that: a consent judgment can only be entered if a stipulation is filed after the filing 

of a petition and answer. See TTR 253 and TTR 283. Because no answer has been 

filed in this case, the stipulation cannot be entered at this time and must be denied. 

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall be placed on a Prehearing General Call 

in the normal course of scheduling.

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 _____________________________

 

 Jason C. Grinnell, Tribunal Member

Entered: July 23, 2025

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 4

MTT Docket No. 25-002396

Page 4 of 6

Page 5

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

Sams Real Estate Business Trust, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 MTT Docket No. 25-002396

City Of Auburn Hills,

Respondent.

ORDER DENYING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT

The Tribunal has reviewed the case file and the stipulation, filed on July 23, 2025, and 

finds that: a consent judgment can only be entered if a stipulation is filed after the filing 

of a petition and answer. See TTR 253 and TTR 283. Because no answer has been 

filed in this case, the stipulation cannot be entered at this time and must be denied. 

IT IS ORDERED that the Parties’ Joint Stipulation for Entry of Consent Judgment is 

DENIED.

IT IS FURTHER ORDERED that this case shall be placed on a Prehearing General Call 

in the normal course of scheduling.

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 _____________________________

 

 Jason C. Grinnell, Tribunal Member

Entered: July 23, 2025

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:

Page 6

MTT

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Page 1

61304820.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SAM'S REAL ESTATE BUSINESS, 

 

 

Petitioner, 

 

v 

MTT Docket No. 25-002396 

 

AUBURN HILLS, 

 

 

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: 63-02-14-04-127-009. 

 

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 

2025

$8,667,640

$4,333,820

$3,760,900

 

 

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 

2025

$6,458,112

$3,229,056

$3,229,056

 

 

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.:

Page 2

MTT Docket No. 25-002396 

Stipulation for Entry of Consent Judgment 

 

 

 

2 

61304820.1 

 

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be 

made payable jointly to Petitioner named herein and its counsel, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660 

Woodward, Suite 2290, Detroit, MI 48226. Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

 

All interest due hereunder is waived if, and only if, all refunds otherwise 

due are paid within 60 days of the entry of the consent judgment, however, 

otherwise interest shall be paid as provided in the Tax Tribunal Act, 

including MCL 205.737. 

 

 

 

HONIGMAN LLP

HALLAHAN & ASSOCIATES, P.C.

Attorneys for Petitioner

Attorneys for Respondent

 

 

By: _______________________________ 

By: _____________________________ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com

Laura M. Hallahan (P42101) 

1750 Telegraph Road 

Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3090 

lhallahan@hallahanlaw.com 

 

 

 

Dated: __________________ 

 

Dated: ____________________ 

 

 

 

( 

 

 

/s/ Daniel L. Stanley 

 

 

 

 Laura M. Hallahan (w/permission)

July 23, 2025 

 

 

 

 

 July 23, 2025

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

Sams Real Estate Business Trust, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002396

City Of Auburn Hills, 

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 16, 2025

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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Sam's Real Estate Business Trust, 

Petitioner, 

MTT Docket No. 

2 

gy. 08 2290, 

[Parcel No(s). 63-02-14-04-127-009] 

Auburn Hills, 

Respondent. 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

that on 

(a // 5 

[ 25 

, she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

Lisa Joseph 

J’

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

AUBURN HILLS 

1827 N. SQUIRREL ROAD 

AUBURN HILLS, MI 48326-2753 

ASSESSOR 

AUBURN HILLS 

1827 N. SQUIRREL ROAD 

AUBURN HILLS, MI 48326-2753 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

SECRETARY OF SCHOOL BOARD 

PONTIAC SCHOOL DISTRICT 

47200 WOODWARD AVENUE 

PONTIAC, MI 48342-2243 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0090

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Page 1

25-0090 

60919143.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Sam's Real Estate Business Trust, 

Petitioner, 

v. 

MTT Docket No. 25-002396 

 

[Parcel No(s). 63-02-14-04-127-009] 

Auburn Hills, 

Respondent. 

_________________________/ 

Michael B. Shapiro (P20282) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

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 

lhallahan@hallahanlaw.colm 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

 

 

SEVERED PETITION 

Sam's Real Estate Business Trust (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1. 

Petitioner's principal office address is Property Tax Department, 2608 SE J Street, 

Suite 2, Bentonville, AR 72716-0555. Petitioner is a party in interest with respect to property taxes 

on tax parcel no(s). 63-02-14-04-127-009 ("Petitioner's Property"), also known as Sams Club

Page 2

2 

60919143.1 

(US04778) at 4350 Joslyn Rd located in Oakland County, Michigan. If this petition includes more 

than one (1) real property tax parcel, the tax parcels are contiguous. 

2. 

Respondent, Auburn Hills, assesses and collects property taxes on Petitioner's 

Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$3,760,900 and assessed Petitioner's Property at $4,333,820, 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 Comm/Bus Imp. Petitioner's Property is 

presently used or available for use for Retail purposes. Petitioner believes that Petitioner's Property 

was originally designed to be used for Retail purposes. 

5. 

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

value and (d) uniformity. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 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 

and operate as a fraud upon the taxpayer 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;

Page 3

3 

60919143.1 

(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 

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 reducing the 2025 

taxable value of Petitioner's Property from $3,760,900 to $2,536,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $4,333,820 to $2,536,000, and 

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

and costs.

Page 4

4 

60919143.1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Michael B. Shapiro (P20282) 

 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

/s/ Daniel L. Stanley

June 13, 2025

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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 

Sams Real Estate Business Trust, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 24-001312 & 

 

 

25-002396 

 

City of Auburn Hills, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING PETITIONER’S MOTION TO AMEND 

 

ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT 

DOCKET NUMBER 25-002396 

 

On May 14, 2025, Petitioner filed a motion requesting that the Tribunal permit it to 

amend the petition filed in this case to include the 2025 tax year. 

 

On June 4, 2025, Respondent filed a response to the motion. In the response, 

Respondent states that valuation disclosures and prehearing statements are due on 

September 19, 2025, leaving an insufficient amount of time for Respondent to “conduct 

discovery or prepare a valuation disclosure relevant to the 2025 tax year. . . .” 

Respondent therefore requests if the motion is granted, the 2025 tax year be severed 

from this appeal and assigned its own docket number. 

 

The Tribunal has considered the motion, the response, and case file and finds that 

Petitioner timely filed its Motion to Amend, included the necessary information and filing 

fee, and otherwise met all requirements, as set forth in MCL 205.737 and MCL 

205.735a. Due to the stage in which this case is at, however, and in the interest of 

judicial efficiency, the 2025 tax year shall be severed from this case and assigned to a 

new docket number. Therefore, 

 

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED. 

 

IT IS FURTHER ORDERED that Petitioner’s assessment appeal for the 2025 tax year is 

SEVERED and ASSIGNED to Docket No. 25-002396. 

 

IT IS FURTHER ORDERED that Petitioner shall file a petition pertaining to the 2025 tax 

year within 21 days of entry of this order.1 The petition shall note the docket number 

 

1 See TTR 233.

Page 2

MTT Docket No. 24-001312 & 25-002396 

Page 2 of 2 

 

assigned by the Tribunal for the 2025 tax year and if filed utilizing the Tribunal’s e-filing 

system, must be filed on the assigned 2025 docket number as a “Severed Petition.”2 

 

IT IS FURTHER ORDERED that the Tribunal shall issue a Notice of Docket after receipt 

of the petition for the 2025 tax year. 

 

Failure to comply with this order may result in dismissal of the appeal for the 2025 tax 

year.3 

 

 

Entered: June 12, 2025 

 

 

 

By _____________________________ 

kac/jcr 

 

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 

 

 

2 Alternatively, the petition may be downloaded from the Tribunal’s website at www.michigan.gov/taxtrib 

and mailed to the Tribunal via United States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, 

Lansing, MI 48909. The petition may also be delivered to the Tribunal via overnight carrier (UPS, FedEx, 

or DHL) at: Michigan Tax Tribunal, 2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933. 

3 See TTR 237.

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