26 - Sturgis POS.pdf

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

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

HEARTLAND RECREATIONAL VEHICLES LLC, 

Petitioner, 

Vv. 

MTT Docket # 26-001409 

CITY OF STURGIS, 

Respondent. 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

} ss. 

COUNTY OF OAKLAND) 

Aaron M. Fales, being duly sworn, deposes and says that on September IS 

202 he served a 

copy of Petitioner's Petition on the parties named on the attached list. 

ee 

Aaron M. Fales

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

Cis 

STURGIS 

130 N. NOTTAWA 

STURGIS. mi 49091 

STURGS 

130 NO NCTTAWA 

STURGIS, mil 45091 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

SV. JOSEPH COUNTY 

PO 

BOX 189 

wo 49032-0189 

TEMIRE 

DIRECTOR OF EQUALIZATION 

ST. JOSEPH COUNTY 

PO BCX 182 

CENTREVILLE 

ral 49032-0789 

SECRETARY OF SCHOOL BOARD 

STURGIS PUBLIC SCHOOLS 

107 Ww. WEST STREET 

STURGIS. PAI 49091-1477 

STATE TB{ ASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREA 

5 LDING 

430 W. ALLLGAN ST. 

LANSING. MI] 48922

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Heartland Recreational Vehicles LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

v 

MTT Docket No.: 26-001409 

City Of Sturgis, 

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 shail 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), “[tlhe 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: August 11, 2026 

PROOF OF SERVICE 

| 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

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

HEARTLAND RECREACTIONAL VEHICLES LLC, 

Petitioner, 

MTT Docket #24- 001409 

vs. 

CITY OF STURGIS, 

Parcel No. 052-950-800-01 

Respondent. 

; 

PETITION 

HEARTLAND 

RECREATIONAL 

VEHICLES 

LLC 

(“Petitioner”), 

through 

ifs 

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 

parly 

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

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. 

é. 

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 af higher percentages of {rue 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

{d} 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable 

value, 

and 

the 

mode 

of 

assessment 

adopted 

by 

Respondent, 

discriminate against Pefitioner 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. 

Respectfully submitted, 

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

Attorney for Petitioner 

PA 

4 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste 350 

Birmingham, MI 48009 

(248) 767-9840 

By: 

Dated: May 20, 2026

← View full record