The Club On Coleman LLC, Petitioner Vs. Township Of Bath, Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

THE CLUB ON COLEMAN LLC, 

 

 

Petitioner, 

 

v 

 

BATH TOWNSHIP, 

 

 

Respondent. 

MTT DOCKET No. 26-000463 

 

PARCEL NOS. 010-536-400-010-02 

 

 

______________________________________/ 

 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Ross K. Bower II (P70574) 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Respondent 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100 

Rbower@fsbrlaw.com 

 

______________________________________/ 

 

APPEARANCE 

 

FAHEY SCHULTZ BURZYCH RHODES PLC, hereby enters its Appearance on behalf 

of Respondent, BATH TOWNSHIP, in the above-entitled matter. 

 

 

 

 

 

Dated: April 2, 2026 

Respectfully submitted, 

 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Respondent 

 

 

By: __________________________________ 

 Ross K. Bower II (P70574) 

 4151 Okemos Road 

 Okemos, MI 48864 

 (517) 381-0100

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

THE CLUB ON COLEMAN LLC, 

 

 

Petitioner, 

 

v 

 

BATH TOWNSHIP, 

 

 

Respondent. 

MTT DOCKET No. 26-000463 

 

PARCEL NOS. 010-536-400-010-02 

 

 

______________________________________/ 

 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Ross K. Bower II (P70574) 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Respondent 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100 

Rbower@fsbrlaw.com 

 

______________________________________/ 

 

PROOF OF SERVICE 

Jamy A. Staffeld states that on April 2, 2026 she served a copy of Appearance and this 

Proof of Service, upon the following via first class mail: 

 

 

Stewart L. Mandell 

Honigman LLP 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

 

 

I declare that the statements above are true to the best of my information, knowledge, and 

 

belief. 

/s/ Jamy A Staffeld 

 

Jamy A. Staffeld

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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 

The Club on Coleman LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 26-000463 

 

Bath 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. 26-000463 

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: April 22, 2026 

 

 

 

 

By: /s/ Jason C. Grinnell_ 

gc 

 

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

64174797.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL

The Club on Coleman LLC, 

Petitioner, 

v 

MTT Docket No. 26-000463 

Bath Twp., 

Respondent. 

_____________________________/ 

Stipulation for Entry of Consent Judgment 

1.

The parcel is located in Ingham County.

2.

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

3.

Property Parcel No: 010-536-400-010-02

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

$30,153,400

$15,076,700

$15,076,700

5.

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

purposes are:

Tax 

Year 

True Cash 

Value 

Assessed 

Value 

Taxable 

Value 

2026

$25,410,000 

$12,705,000 

$12,705,000

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:

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

2 

64174797.1 

Honigman LLP 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Petitioner 

Attorneys for Respondent 

By: /s/ Stewart L. Mandell 

By: /s/ Ross K. Bower II 

Stewart L. Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7420

slmandell@honigman.com

Ross K. Bower II (P70574) 

Samantha R. Reetz (P86523) 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100

rbower@fsbrlaw.com

Dated: April 8, 2026 

Dated: April 8, 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

The Club on Coleman LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000463

Township Of Bath, 

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

64174797.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL

The Club on Coleman LLC, 

Petitioner, 

v 

MTT Docket No. 26-000463 

Bath Twp., 

Respondent. 

_____________________________/ 

Stipulation for Entry of Consent Judgment 

1.

The parcel is located in Ingham County.

2.

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

3.

Property Parcel No: 010-536-400-010-02

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

$30,153,400

$15,076,700

$15,076,700

5.

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

purposes are:

Tax 

Year 

True Cash 

Value 

Assessed 

Value 

Taxable 

Value 

2026

$25,410,000 

$12,705,000 

$12,705,000

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:

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

2 

64174797.1 

Honigman LLP 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Petitioner 

Attorneys for Respondent 

By: /s/ Stewart L. Mandell 

By: /s/ Ross K. Bower II 

Stewart L. Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226 

(313) 465-7420

slmandell@honigman.com

Ross K. Bower II (P70574) 

Samantha R. Reetz (P86523) 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100

rbower@fsbrlaw.com

Dated: April 8, 2026 

Dated: April 8, 2026

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

THE CLUB ON COLEMAN LLC, 

 

 

Petitioner, 

 

v 

 

BATH TOWNSHIP, 

 

 

Respondent. 

MTT DOCKET No. 26-000463 

 

PARCEL NO. 010-536-400-010-02 

 

 

______________________________________/ 

 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Ross K. Bower II (P70574) 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Respondent 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100 

Rbower@fsbrlaw.com 

 

______________________________________/ 

ANSWER TO PETITION 

 

Respondent, BATH TOWNSHIP, by and through its counsel, FAHEY SCHULTZ BURZYCH 

RHODES PLC, hereby answers Petitioner’s Petition as follows: 

1. Petitioner's principal office address is 2265 Livernois, Suite 500, Troy, MI 48083. Petitioner is 

a party in interest with respect to property taxes on tax parcel number 010-536-400-010-02 ("Petitioner's Property"), 

at 3850 Coleman Rd. located in Ingham County, Michigan. 

ANSWER: Respondent admits that the subject property includes 3850 Coleman Rd. 

Respondent states that it is without sufficient knowledge or information upon which to form a 

belief as to the truth of the remaining allegations, which are therefore deemed denied, leaving 

Petitioner to its proofs.

Page 2

2 

 

2. Respondent, Bath Twp., assesses and collects property taxes on Petitioner's Property. 

ANSWER: Respondent admits the allegations contained in the above paragraph as true. 

3. In 2026, Respondent determined the taxable value of Petitioner's Property to be $15,076,700 

and assessed Petitioner's Property at $15,076,700, which will result in a state equalized value in the same amount 

based upon the tentative equalization factor. 

ANSWER: Respondent admits the allegation contained in the above paragraph. 

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

ANSWER: Respondent admits Petitioner’s Property is classified as commercial improved, 

real property. As to the remaining allegations and what Petitioner believes, Respondent is 

without sufficient knowledge or information upon which to form a belief as to the truth of 

the allegations, which are therefore deemed denied, leaving Petitioner to its proofs. 

5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value and (d) 

uniformity. 

ANSWER: Respondent states that the legal conclusions require no answer, and to the extent 

that an answer may be required, neither admits nor denies the allegations contained in the 

above paragraph and leaves Petitioner to its proofs. 

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

the value of a loss. 

ANSWER: Respondent admits only that Petitioner makes the indicated contention but 

denies that Petitioner’s contentions have merit and asserts that the Petition should be 

dismissed, incorporating its additional answers and affirmative defenses. 

7. No March Board of Review protest was required for Petitioner’s Property.

Page 3

3 

 

 

ANSWER: Respondent states that the legal conclusions require no answer, and to the extent 

that an answer may be required, neither admits nor denies the factual allegations contained in 

the above paragraph and leaves Petitioner to its proofs. 

8. 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 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. 

ANSWER: Respondent denies the allegations contained in the above paragraph and 

subparagraphs a. through d.

Page 4

Respectfully Submitted, 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Respondent 

April 8, 2026 

AT 

Ross K Bower II (P70574) 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100 

Rbower@fsbrlaw.com

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

THE CLUB ON COLEMAN LLC, 

 

 

Petitioner, 

 

v 

 

BATH TOWNSHIP, 

 

 

Respondent. 

MTT DOCKET No. 26-000463 

 

PARCEL NOS. 010-536-400-010-02 

 

 

______________________________________/ 

 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Ross K. Bower II (P70574) 

Fahey Schultz Burzych Rhodes PLC 

Attorneys for Respondent 

4151 Okemos Road 

Okemos, Michigan 48864 

(517) 381-0100 

Rbower@fsbrlaw.com 

 

______________________________________/ 

 

 

RESPONDENT’S AFFIRMATIVE DEFENSES 

 

Respondent Bath Township, by and through its attorneys, FAHEY SCHULTZ BURZYCH 

RHODES PLC, states as follows for its Affirmative Defenses: 

1. Petitioner failed to state a claim for which its requested relief, or any other relief, may 

be granted. 

2. If the proofs shall show,

Page 6

2

Page 7

3

Page 8

STA

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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. 26-000463

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Bath (CLINTON)

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

Ross

M.I.

K

Last Name

Bower

Firm Name (if any)

Fahey Schultz Burzych Rhodes PLC

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

4151 Okemos Road

City or Town

Okemos

State

Michigan

ZIP Code

48864

Telephone Number

517-381-0100

Fax Number

517-381-5051

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

jstaffeld@fsbrlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Ross K. Bower II 

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

The Club on Coleman LLC, 

Petitioner, 

v. 

MTT Docket No. Ao (oy LZ 

[Parcel No(s). 010-536-400-010-02] 

Bath Twp., 

Respondent. 

PROOF OF SERVICE 

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

that on 

4 2-/ 2p, she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

/" s/ Nn Oraspth ER 

Lisa Joseph 

7 

26-0005 

75042191.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

BATH TWP. 

P.O. BOX 247 

BATH, MI 48808-0247 

ASSESSOR 

BATH TWP. 

P.O. BOX 247 

BATH, MI 48808-0247 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

INGHAM COUNTY 

100 E. STATE STREET, SUITE 2600 

ST. JOHNS, MI 48879-1571 

DIRECTOR OF EQUALIZATION 

INGHAM COUNTY 

100 E. STATE STREET, SUITE 2600 

ST. JOHNS, MI 48879-1571 

SECRETARY OF SCHOOL BOARD 

EAST LANSING PUBLIC SCHOOLS 

CENTRAL ADMINISTRATION, 501 BURCHAM 

EAST LANSING, MI 48823-2942 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0005 

75042191.1

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

The Club on Coleman LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

Parcel Number 010-536-400-010-02 

Bath Twp., 

Respondent. 

_________________________/ 

PETITION 

The Club on Coleman LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 2265 Livernois, Suite 500, Troy, MI 48083. 

Petitioner is a party in interest with respect to property taxes on tax parcel number 010-536-400-

010-02 ("Petitioner's Property"), at 3850 Coleman Rd. located in Ingham County, Michigan. 

2. 

Respondent, Bath Twp., assesses and collects property taxes on Petitioner's 

Property. 

3. 

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

$15,076,700 and assessed Petitioner's Property at $15,076,700, 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. 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 and (d) uniformity.

Page 2

2 

 

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. 

No March Board of Review protest was required for Petitioner’s Property. 

8. 

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 

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 assessed value, state equalized value and taxable value of Petitioner's Property from 

$15,076,700 to $12,705,000; ii) requiring Respondent to pay Petitioner the refunds attributable to 

such reductions, plus interest and costs; and iii) granting Petitioner any other relief to which it is 

entitled.

Page 3

3 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: April 2, 2026 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: ______________________________________ 

 

Stewart L. Mandell (P33781) 

660 Woodward Avenue 

2290 First National Bldg. 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

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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 - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

The Club on Coleman LLC

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

2265 Livernois

City or Town

Troy

State

Michigan

ZIP Code

48083

Telephone Number

3134657420

Fax Number

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

slmandell@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 Bath (CLINTON)

County

Clinton

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:

01053640001002

Classification of Property: Real 

Commercial

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

15076700

Current Taxable Value as established by the Board of Review:

15076700

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

25410000

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

12705000

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

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

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.