Morbark - Petition.pdf

Morbark LLC, Petitioner Vs. Township Of Fremont, Respondent · 25-001756-TT

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25-0102 

60699300.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Morbark LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 07-015-30-002-03] 

Fremont Twp. - Isabella, 

Respondent. 

_________________________/ 

PETITION 

Morbark LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 8507 S. Winn Road, Winn, MI 48896. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 07-015-30-002-

03 ("Petitioner's Property"), at 8507 S. Winn Road located in Isabella County, Michigan. If this 

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

2. 

Respondent, Fremont Twp. - Isabella, assesses and collects property taxes on 

Petitioner's Property. 

3. 

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

$9,096,884 and assessed Petitioner's Property at $9,446,600, 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 Industrial Real. Petitioner's Property is 

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

Property was originally designed to be used for Industrial purposes.

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60699300.1 

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; 

(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.

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60699300.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value of Petitioner's Property from $9,096,884 to $3,300,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $9,446,600 to $3,300,000, and 

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

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Daniel L. Stanley (P57052) 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

 

 

/s/ Daniel L. Stanley

May 29, 2025

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