2026 Petition - Sturgis.pdf

Heartland Recreational Vehicles LLC Petitioner Vs. City Of Sturgis Respondent · 26-001409-TT

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STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

HEARTLAND RECREACTIONAL VEHICLES LLC, 

Petitioner, 

vs. 

CITY OF STURGIS, 

Respondent. 

/ 

 

 

 

MTT Docket #26- 

 

Parcel No. 052-950-800-01 

 

 

 

 

PETITION 

 

 

HEARTLAND RECREATIONAL VEHICLES LLC (“Petitioner”), through its 

attorneys, Law Office of Aaron M. Fales, P.C., says: 

 

1. 

Petitioner's principal office address is 2831 Dexter Dr., Elkhart, IN 

46514. Petitioner is a party in interest with respect to property taxes on 

contiguous real property tax parcel no. 052-950-800-01 ("Petitioner's Property"), at 

1200 Haines Blvd., Sturgis, MI 49091. 

 

2. 

Respondent, City of Sturgis assesses and collects property taxes on 

Petitioner's Property. 

 

3. 

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

Parcel #052-950-800-01 to be $5,294,185 and assessed Petitioner's Property at 

$5,705,100 resulting in a state equalized value of the same amount based on the 

tenative equalization factor.

4. 

Petitioner's Property is classified as Industrial Real Property. 

Petitioner's Property is industrial property. Petitioner believes that Petitioner's 

Property was designed to be used as a Industrial 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. 

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 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. 

 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an 

Order reducing the 2026 taxable value of Petitioner's Parcel #052-950-800-01 

from $5,294,185 to $2,000,000, and reducing the 2026 assessed and state 

equalized values of Petitioner's Property from $5,705,100 to $2,000,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such 

reductions, plus interest and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: May 20, 2026 

Respectfully submitted, 

 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

 

 

By: _________________________ 

 

Aaron M. Fales (P72864) 

 330 Hamilton Row, Ste 350 

 Birmingham, MI 48009 

 (248) 767-9840

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