24-003423.pdf

Courser Community Center Inc, Petitioner V Township Of Rolland, Respondent · 24-003423-TT

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RECEIVED 

MTT DOCKET No.: 24-003423 

APR 15 2025 

SUPPORT DOCUMENTS CONTENTS 

MICHIGAN TAX TRIBUNAL 

1. Facebook membership sheet (2 pages) 

2. Courser Community Center Background (2 pages) 

3. 

Assessors Reply to Appeal (2 page) 

4. 

Reply to Assessors Answer (2 pages) 

5. 

IRS-501C3 TAX CODE 

6. 

Michigan Property Tax Exemption Explanation (5 pages) 

7. 

Photos - showing 

a. Interior work & cleanup 

b. Exterior work & cleanup 

¢. MISCELLANEOUS

Save the Blanchard 

Elementary School 

© Public group - 506 members 

QD PDH gr 

ET) 

We 

Share 

Joined 

New people and Pages who join this group will appear here. Learn More 

i Find a member 

- Save the Blanchard Elemen... 

[Wl tite 

Share 

Joined 

Amy Graham 

@ Message 

Owner/Property Manager at Amy's Crafting Corner 

Paula Jean

DAES dL VVaTTidiL 

Sandy Bellingar 

Works at New Beginnings Christian Family Fellowship 

Sherry Courser 

Kimberly J. Camp Smith 

Admin 

Top contributor 

Blanchard, Michigan 

Kathie Boyer 

Lansing Community College 

Deb Narducci-Courser 

Librarian at Retired 

Renee Jones-Chapman 

Central Michigan University 

Ervin L. Moore 

Realtor/Broker at Eagle Realty 

JoAnne Camp 

Blanchard High school Michigan 

Tina Murray 

Works at Isabella Bank 

Shane Smith 

& Message 

& Message 

@ Message 

@ Message 

& Message 

& Message 

€ Message 

@ Message 

@ Message 

© Message

Courser Community Center (background) 

| first heard about the Facebook site “SAVE THE BLANCHARD 

ELEMENTARY SCHOOL” in 2019. 

As time went on-the 

membership grew and grew until it reached over 500 members.(see 

cover sheet) 

| joined and agreed with them that they had a solid 

plan in order to SAVE the school 

| attended in the 1960's. 

October 

25, 2016 The school and four city blocks had been sold to 

a Greg & Brenda Schankin for $12,000 October 25, 2016 and was 

TAX EXEMPT for no reason that anyone could or would talk about. 

They were receiving over $300 per month by CMS Internet for 

allowing CMS to place a tower at the school. 

ary 16, 

2020 

| contacted the leaders of the “Save the School” 

group (Kim Smith. Tina Murray and Renee Chapman) and decided to 

buy the school and donate it to them for their idea of having a 

community center. 

| was able to buy it for $45,000 (plus fees of apx. 

$4,000). |insisted that they set up a 501C3 for tax reasons on my 

attorney’s advice. My closing was on January 16, 2020. 

December 12, 2024 was the actual date that 

| was finally able to 

sign the deed over to “THE COURSER COMMUNITY CENTER”. They 

had been doing a lot of work (see enclosed pictures) in and around 

the building plus: estimates for repairs, getting donations, having 

meetings for residents, many fund raising activities, etc., etc., etc. 

They did contact the assessor about the “tax exempt” property

to give them the deed. We also received the Winter 2024 ($2080.88 

paid late $2349.55) tax bill and the Summer tax bill in 2024 ($715.77) 

We also received the Winter tax bill ($2128.87) due before 

| was able 

to get the deed to them. We all thought we were operating under the 

tax exempt status! 

Now here’s the problem — The total amount of our funds (donations, 

can drives, meals, etc.) was $10,248.90. The total property taxes 

were $5862.52. Liability insurance was over $1100.00 per year. 

Electric bills, dumpsters ($400 each x 4) — we cleared out all the 

asbestos as recommended by the hazardous inspection company. 

We also discovered that the Gym roof needed replacement 

($52,000) and the Rubber roof at over $125,000. We sure could have 

used that extra tax money! 

I did find out that Blanchard (the assessor and the Rolland Township 

Board) showed no help. There had been a number of break ins prior 

to my purchase, BUT there were at least five more since 

1 boughtitin 

2020. Kim even caught three high school age kids and the police got 

there in time to catch them, but the Prosecutor’s office declined to 

follow through. They did over $30,000 in damage that time.

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

ORLENE HAWKS 

GOVERNOR 

LANSING 

DIRECTOR 

This abandoncd school property was transfered fram Mr Courser to the Courser 

Community Center in 2021 

, with the intention to refurbish the buitding and tun it into a. 

community center. They obtained their 501¢3 and applied for exemption. It was granted 

and continued through the 2022 assessment/tax year. It was assessed on the 2023 roll 

wheu the township saw no movement toward using it for the charitable intentions. The 

2023 non-exempt stats was not appeated. 

Since 2021 the building has failen inte even more disrepair and there has been little or 

10 movement to make it usable, The organization has not been occupying or using the 

building for their chadtable mission and cannot predict whea the situation will change. 

The Township decided to continue assessing the parce? on the 2024 assessment roll for 

this reason. 

Section 5: Jurisdictional Issues 

IF PETITIONER 1S APPEALING THE TRUE CASH AND/OR TAXABLE VALUES 

Did Patitioncr protest ihe assessment 21 2 Board of Review {BOR)? 

If yes, check which BOR Petitioner attended: 

110, was the Notice of Assessment properly sont to Petitioner prior to the March BOR? Submit a copy of the Notice of Assessment with the Answer. 

If the July or December BOR revised the assessment(s) at issue, did it have authority? 

I€yes, cite the Board's authority. 

Was the assessment(s) at issue established as the result of & clerical error or mutual mistake of fact? 

If'yes, explain. 

Is Petitioner appealing from a State Tax Commission Order? 

IF 50, what is the issue date? 

IF PETITIONER 1S APPEALING THE UNCAPPING OF TAXABLE VALUE

This abandoned school property was transferred from Mr. Courser to the Courser 

Community Center in 2081 with the intention to refurbish the building and turn it into a 

community center. They obtained their 501C3 and applied for exemption. 

It was 

granted and continued through the 2022 assessment/tax year. 

It was assessed on the 

2023 roll when the township saw no movement toward using it for the charitable 

intentions. The 2023 non-exempt status was not appealed. 

Since 2021 the building has fallen into even more disrepair and there has been little or 

no movement to make it usable. The organization has not been occupying or using 

the building for their charitable mission and cannot predict when the situation will 

change. The Township decided to continue assessing the parcel on the 2024 roll for 

this reason.

PROPERTY TAX APPEAL 

DOCKET 24-003423 

DOCUMENTATION and REPLY TO ASSESSOR 

1. 501C3 (see IRS letter attached) 1“ 

2. 

“It was assessed on the 2023 roll when the township saw no 

movement toward using it for the charitable intentions. 

ANSWER: We always felt that the Township (board) was 

against us. We never had any of the 5 board members join the 

“SAVE THE BLANCHARD ELEMETRY SCHOOL” OR MAKE 

DONATIONS! We always had it open for anyone to play 

basketball, field games, etc. LOOK AT THE ENCLOSED 

PICTURES! 

3. “The 2023 non-exempt status was not appealed.” 

ANSWER: Our fault —no one knew about this process! 

4. “Since 2021 the building has fallen into even more disrepair 

and there has been little or no movement to make it usable.” 

ANSWER: Three local teens were arrested for causing over 

$30,000 in damages. Gym was being used and we had many, 

many volunteers working inside (see pictures). We spent days 

and days filling dumpsters with debris 

5. “The organization has not been occupying or using the building 

for their charitable mission and cannot predict when the 

situation will change”.

want and need is a grant. Caseyville got the one last summer 

that we really wanted. 

It was for $1,000,000 (google it if you 

don’t believe me). 

. “The TOWNSHIP decided to continue assessing the parcel on 

the 2024 roll”. 

ANSWER: Thanks. We decided to sell the school buildings and 

use the old baseball field once we are able to obtain a grant. 

FINAL: We still expect to receive a refund of all the taxes that 

we paid that should have been exempt from or not even 

charged in the first place.

Department of the Treasury 

Date: 

A 

y 

Internal Revenue Service 

04/17/2021 

hot oe” 

! 

Tax Exempt and Government Entities 

: 

Employer 

ID number: 

re 

P.O. Box 2508 

Cincinnati, OH 45201 

Person to contact: 

Name: Suzanne Dragoo 

ID number JN 

Telephone: 877-829-5500 

COURSER COMMUNITY CENTER INC 

Accounting period ending: 

PO BOX 93 

December 31 

BLANCHARD, MI 49310 

Public charity status: 

170(b)(1HA) VI) 

Form 990 / 990-EZ / 990-N required: 

Yes 

Effective date of exemption: 

November 5, 2020 

Contribution deductibility: 

Yes 

Addendum applies: 

No 

We're pleased to tell you we determined you're exempt from federal income tax under Internal Revenue Code 

(IRC) Section 501(c)(3). Donors can deduct contributions they make to you under IRC Section 170. You're also 

qualified to receive tax deductible bequests, devises, transfers or gifts under Section 2055, 2106, or 2522. This 

letter could help resolve questions on your exempt status. Please keep it for your records. 

Dear Applicant: 

Organizations exempt under IRC Section 501(c)(3) are further classified as either public charities or private 

foundations. We determined you're a public charity under the IRC Section listed at the top of this letter. 

If we indicated at the top of this letter that you're required to file Form 990/990-EZ/990-N, our records show 

you're required to file an annual information return (Form 990 or Form 990-EZ) or electronic notice (Form 

990-N, the e-Postcard). If you don't file a required return or notice for three consecutive years, your exempt 

status will be automaticaily revoked. 

If we indicated at the top of this letter that an addendum applies, the enclosed addendum is an integral part of 

this letter. 

For important information about your responsibilities as a tax-exempt organization, go to www.irs.gov/charities. 

Enter "4221-PC" in the search bar to view Publication 4221-PC, Compliance Guide for 501(c)(3) Public 

Charities, which describes your recordkeeping, reporting, and disclosure requirements.

DICKINSON WRIGHT 

Michigan Property Tax Exemption for Charitable 

Institutions Is Again Construed Broadly by the State 

Supreme Court 

October 2017 

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Executive Summary 

Property owned and occupied by charitable institutions solely for their charitable purposes is exempt from 

Michigan property tax. Some assessors denied exemptions to charities that charged fees for their services, 

arguing that they were acting like a business. In 2006, the Michigan Supreme Court clarified the rules 

cancerning the exemption for charities and reaffirmed that a charity may charge for its services and that 

there no required monetary threshold of charity required. If the “overall nature” of the institution is 

charitable, the entity can qualify as a charity regardless of how much money it devotes to charitable 

activities in a particular year. The Court provided six guidelines for determining whether an entity is a 

charity. The third guideline was that the entity not discriminate among those intends to be served. Some 

assessors and the tax tribunal construed that as requiring that applicants for the charitable exemption not 

discriminate based on ability to pay. By this logic, while a charity could charge for services, it would be 

required to offer free or subsidized services to those who could not afford the charge. Admissions or other

«cannot pay the charges. The decision is potentially helpful to all charities that charge for their services. 

The Statutory Exemption 

MCL 21.70(1) provides Michigan's property tax exemption for charities as follows: 

Real or personal property owned and occupied by a nonprofit charitable institution while occupied by that 

nonprofit charitable institution solely for the purposes for which that nonprofit charitable institution was 

incorporated is exempt from the collection of taxes under this act. 

The Lead case, Wexford, Provided Six Guidelines for a Chartable Institution 

Following a review of earlier decisions, the Court provided six guidelines for determining whether an entity 

is a charitable institution for purposes of the property tax exemption: 

1. A “charitable institution” must be a nonprofit institution. 

2. A “charitable institution” is one that is organized chiefly, if not solely, for charity. 

3. A “charitable institution” does not offer its charity on a discriminatory basis by choosing who, among the 

group it purports to serve, deserves the services. Rather, a “charitable institution” serves any person who 

needs the particular type of charity being offered. 

4. A “charitable institution” brings people’s minds or hearts under the influence of education or religion; 

relieves peoples bodies from disease, suffering, or constraint; assists people to establish themselves for 

life; erects or maintains public buildings or works; or otherwise lessens the burdens of government. 

5. A “charitable institution” can charge for its services as long as the charges are not more than what is 

needed for its successful maintenance. 

6. A “charitable institution” need not meet any monetary threshold of charity to merit the charitable 

institution exemption; rather, if the overall nature of the institution is charitable, it is a “charitable 

institution” regardless of how much money it devotes to charitable activities in a particular year. 

Wexford Med Group v City of Cadillac, 474 Mich 192, 215 (2006)

leave to appeal and in lieu of granting leave to appeal vacated the decision and remanded. 

Tax Tribunal and the Court of Appeals had construed the anti-discrimination requirement as requiring 

exemption applicants make their services available without regard to ability to pay. While a fee could be 

charged to those who could afford it, the exemption applicant could not turn away someone who could not 

afford to pay. To do so discriminated among those intended to be served by the organization's charity. 

Applying that logic, organizations would have to consider applicants for their services on a first come first 

serve basis regardless of ability to pay. While acknowledging that the wording of its Wexford decision could 

lead to that conclusion, the Court rejected that conclusion, as unsustainable, and inconsistent with the 

other guidelines. The court held that any analysis of fees should be undertaken under the fifth test, not the 

discrimination test. 

The Wexford discrimination test is intended to exclude organizations that discriminate by imposing 

purposeless restrictions on the beneficiaries of the charity - restrictions that bear no reasonable relationship 

to an organization's legitimate charitable goals. The legitimate goals of a charity are stated in test four. The 

“reasonable relationship” test should be construed quite broadly to prevent unnecessarily limiting the 

restrictions a charity may choose to place on its services. Thus Baruch’s requirement that an individual be a 

resident and make 24 monthly payments before being accepted into its charitable Income Based Program 

would violate the third Wexford test only if that restriction were not reasonably related to a permissible 

charitable goal under factor four. Because the Tax Tribunal and the Court of Appeals decisions were based 

on an incorrect understanding of Wexford factor three, the Court vacated those portions of the opinions 

discussing the third factor and remanded this case to the Tax Tribunal for further proceedings. On August 22, 

2017, the parties stipulated that the third test was met because the restriction requiring 24 months of paid 

service was reasonably related to the charitable purpose of the organization. The Tribunal entered a 

judgment on August 29, 2017. (Baruch, supra, MTT No. 13-001360-TT.) 

The decision in Baruch is helpful to charitable institutions that charge fees for their services. 

This client alert is published by Dickinson Wright PLLC to inform our clients and friends of important 

developments in the field of tax law. The content is informational only and does not constitute legal or 

professional advice. We encourage you to consult a Dickinson Wright attorney if you have specific questions 

or concerns refating to any of the topics covered in here.

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Great community effort at The 

Blanchard Elementary School, future 

home of The Courser Com... See more 

1 share 

Exelon ors 

and 

ploy,

< 

Kimberly's post 

ooo 

Thank you Blanchard and to those who 

still love her. Blanchard still needs this 

school building. The local children still 

need this school building. Together we 

can accomplish much. Together we can 

make this happen. Stay tuned and 

please get involved! 

dY Like 

@ Comment 

®) Send 

pp) Share 

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We are moving forward with our 

beloved school. Rolland Courser, a 

former Blanchard High School Alumni, 

has purchased the school for our 

community. Our 501c3 paperwork is in 

the hands of the IRS. We should have it 

approved within the next couple 

months. We have a dumpster full and 

some items out by the r= ~~ 

grabs. Our next step is tt 

ut” 

removing the ceiling tiles 

(# 

fiberglass insulation. We 

| 

volunteers for this removg 

comment below if you are 

volunteer. Also, if you are v 

donate money back to this 

please see Tina at Isabella 

Blanchard. We really need you to 

partner with us. The dream is finally 

within our grasp but we cannot do it 

alone. We will post dates for workers 

needed. We hope you can join us. 

GIF} 

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"Fund raiser dinner! Come on over! Here 

until 7pm!

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Save the Blanchard 

@® Elementary School 

Kimberly J. Camp Smith 

- 

Nov 22, 2020 

+ 3 

Yesterdays work Bee! Blanchard's finest at 

work! As you can see, our current 

dumpster is full. We need the funds to 

order the next dumpster. One of our 

people paid for the current dumpster. 

Might you consider donating back to this 

project. We need your money to continue 

with this clean up. The few hundred dollars 

that were left in our account has been 

: 

ants. 

But at this 

time, we preps our local people to back this 

with their money to move forward. We 

would like to continue with clean up. 

Please donate back to the Save the 

Blanchard Elementary School at Isabella 

Bank in Blanchard. Thank you! 

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Caleb's can drive! Caleb is collecting 

cans to raise money for the future 

community center that will... See more

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ul19, 2022 

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Thank you Blanchard!! Our first cans 

and bottles!! Keep um coming!!

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Drink more soda pop!! 

Save the Blanchard 

Elementary School 

Kimberly J. Camp Smith 

- Sep 28, 

2022 

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® 02020200 0 

Caleb finished returning this load of 

cans!! $205.30, Chris White is the 

winner!! Keep the empties... See more 

phe 

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YF Aug 22,2022 

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Caleb's Can Drive!! Our first full load! 

Thanks Blanchard, for all yer empties!! 

Take some wild guesses as to how many 

$'s we end up with. Whoever guesses the 

closest will win a Buttermilk Pie!! Ready. 

Set. Go!!! P.s. keep dropping um off and we 

will take another load in a couple weeks!! 

Thank you!! And come to Taco Tuesday on 

August30th!! 

00 29 

32 comments 

4 shares 

i) Like 

Q Comment 

(~) Send 

Fg Share

Kimberly J. Camp Smith just a few of the 

: 1) 

pic from today. Thhank you everyone!! 

M 

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