Bingham Solar, LLC Petitioner Vs. Township Of Bingham Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BINGHAM SOLAR, LLC 

Petitioner, 

MTT Docket No. 26-001322 

v. 

Parcel No.: 19-030-900-100-001-00 

BINGHAM TOWNSHIP, 

Respondent. 

Adam J. Brody (P62035) 

Michael D. Homier (P60318) 

Deborah I. Ondersma (P55907) 

Thomas K. Dillon (P81136) 

VARNUM LLP 

FOSTER, SWIFT, COLLINS & SMITH, PC 

Attorneys 

for Petitioner 

Attorneys for Respondent 

333 Bridge Street, N.W. 

: 

1700 E. Beltline Ave. NE, Suite 200 

P.O. Box 352 

Grand Rapids, MI 49525 

Grand Rapids, MI 49501-0352 

(616) 726-2258 

(616) 336-6000 

mhomier@fosterswift.com 

ajbrody@varnumlaw.com 

tdillon@fosterswift.com 

diondersma@varnumlaw.com 

PROOF OF SERVICE 

On September 3, 2026, I served a copy of Respondent’s Answers & Affirmative Defenses 

to Entire Tribunal Property Tax Petition, along with a copy of this Proof of Service, upon the 

parties of record at their last known business address, by first class U.S. mail, postage prepaid. 

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

belief. 

Date: 

September 3, 2026 

16845:00008:203036801-1

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001322

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Respondent

Files

Document Type: Proof of Service: Misc Documents

Attachment File Name: POS - Respondent's Answer & Affirmative Defenses

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

 MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

________________________________________________ 

 

BINGHAM SOLAR, LLC 

 

 Petitioner, MTT Docket No. 26-001322 

v. 

 Parcel No.: 19-030-900-100-001-00 

 

BINGHAM TOWNSHIP, 

 

 Respondent. 

______________________________________________________________________________ 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

Thomas K. Dillon (P81136) 

VARNUM LLP 

 

 

 

 

FOSTER, SWIFT, COLLINS & SMITH, PC 

 

Attorneys for Petitioner 

 

 

 

Attorneys for Respondent 

333 Bridge Street, N.W. 

 

 

 

1700 E. Beltline Ave. NE, Suite 200 

P.O. Box 352 

 

 

 

 

Grand Rapids, MI 49525 

Grand Rapids, MI 49501-0352 

 

 

(616) 726-2258 

 

 

 

(616) 336-6000 

 

 

 

 

tdillon@fosterswift.com 

ajbrody@varnumlaw.com 

 

 

 

diondersma@varnumlaw.com 

_____________________________________________________________________________________________ 

 

RESPONDENT’S ANSWERS & AFFIRMATIVE DEFENSES TO ENTIRE TRIBUNAL 

PROPERTY TAX PETITION 

 

Respondent, Bingham Township, by and through its attorneys, Foster, Swift, Collins 

& Smith, P.C., states as follows for its Answer to Petitioner’s Entire Tribunal Property Tax 

Petition: 

1. 

 Petitioner is a Delaware limited liability company with its principal address at 8400 

Normandale Lake Blvd, Suite 1200, Bloomington, MN 55437. 

ANSWER: 

Respondent neither admits nor denies the allegations contained in paragraph 

1 of the Petition as Respondent is without sufficient knowledge or information to form a 

belief as to the allegations. Respondent leaves Petitioner to its proofs.

Page 2

2. 

Petitioner is the owner of and/or the party in interest with respect to the subject 

personal property (the "Property") which is located in Bingham Township, Clinton County, 

Michigan and is more particularly described as: 

 

Parcel No. 

Property Address 

19-030-900-100-001-00 

Personal property located on the contiguous real 

property parcels with the following addresses: 1635 E. 

Steel Rd., E. Steel Rd., and N. Williams Rd., Saint 

Johns, MI 48879 

 

ANSWER: 

Respondent neither admits nor denies the allegations contained in paragraph 

2 of the Petition as Respondent is without sufficient knowledge or information to form a 

belief as to the allegations. Respondent leaves Petitioner to its proofs. 

 

3. 

No real property is under appeal in this Petition. However, the Property consists 

of all personal property that is located upon the real property with the following permanent 

parcel numbers: 19-030-010-100-005-00, 19-030-010-100-010-50, and 19-030-010-100-025-

50. 

ANSWER: 

Respondent admits the allegations contained in paragraph 3 of the Petition. 

4. 

Respondent, Bingham Township, ("Respondent"), assesses, levies and collects 

the property taxes on the Property. 

ANSWER: 

Respondent admits the allegations contained in paragraph 4 of the Petition. 

5. 

The Property is in Clinton County and is located within the St. Johns Public 

School District. 

ANSWER: 

Respondent admits the allegations contained in paragraph 5 of the 

Petition. 

 

6. 

The 2026 Personal Property Statement for the subject Property was timely filed 

on February 17, 2026. Given the timely filing of the Personal Property Statement, no appeal 

to the March 2026 Board of Review was required. However, an appeal to the March Board

Page 3

of Review was made. The 2026 March Board of Review denied Petitioner’s requested 

relief and instead increased the 2026 assessment of the Property purportedly based upon 

a mis-calculation of Respondent. 

ANSWER: 

Respondent admits the factual allegations contained in paragraph 6 of the 

Petition as Petitioner did appeal the 2026 assessment to the Township’s March Board of 

Review, which denied the petition. Respondent neither admits nor denies any legal 

conclusions contained in paragraph 6. 

7. 

The Property is classified as industrial personal property (351). 

 

ANSWER: 

Respondent admits the allegation contained in paragraph 7 of the Petition. 

 

8. 

The Property is used as part of a solar energy facility. 

 

ANSWER: 

Respondent neither admits nor denies the allegations contained in paragraph 

8 of the Petition as Respondent is without sufficient knowledge or information to form a 

belief as to the allegations. Respondent leaves Petitioner to its proofs. 

 

9. 

The tax year at issue is tax year 2026. 

 

ANSWER: 

Respondent admits the allegation contained in paragraph 9 of the Petition. 

 

10. The Tax Year 2026 values for the Property as established by Respondent through 

its Board of Review are as follows: 

Tax Year 

Parcel No. 

True Cash 

Value 

Assessed/State 

Equalized Value 

Taxable Value 

2026 

19-030-900-100-001- 

00 

$31,375,800 

$15,687,900 

$15,687,900 

 

ANSWER: 

Respondent admits the allegations contained in paragraph 10 of the Petition. 

 

11. 

Petitioner contends the correct values for the Property are: 

 

Tax Year 

Parcel No. 

True Cash 

Value 

Assessed/State 

Equalized Value 

Taxable Value 

2026 

19-030-900-100-001- 

00 

$15,500,000 

$7,750,000 

$7,750,000 

ANSWER: 

Respondent denies the allegations contained in paragraph 11 of the Petition 

as being untrue and erroneous.

Page 4

12. 

The values in dispute for the Property are: 

 

Tax Year 

Parcel/Address 

True Cash 

Value 

Assessed/State 

Equalized Value 

Taxable Value 

2026 

19-030-900-100-001- 

00 

$15,875,800 

$7,937,900 

$7,937,900 

 

ANSWER: 

Respondent admits that

Page 5

(d) 

The

Page 6

e.

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001322

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Bingham (CLINTON)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone 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

Thomas

M.I.

Last Name

Dillon

Firm Name (if any)

Foster Swift Collins & Smith PC

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

1700 E. Beltline Ave. NE

Suite 200

City or Town

Grand Rapids

State

 Michigan

ZIP Code

49525

Telephone Number

(616) 726-2258

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

tdillon@fosterswift.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Thomas K. Dillon

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

BINGHAM SOLAR, LLC 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. 26-001322-TT 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No.: 19-030-900-100-001-00 

BINGHAM TOWNSHIP, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

 

_____________________________________ 

 

PROOF OF SERVICE 

On the date below, I sent by U.S. certified mail, return receipt requested, a copy of the 

(1) Entire Tribunal Property Tax Petition; (2) Notice of Docket Number MTT Docket No. 26-

001322-TT; and (4) Proof of Service to: 

ASSESSOR 

Camden Lindsey, Assessor 

Bingham Township 

2057 North Lansing Street 

Saint Johns, MI 48879 

BINGHAM TOWNSHIP CLERK 

Amy Wirth, Clerk 

Bingham Township 

2057 North Lansing Street 

Saint Johns, MI 48879

Page 2

2 

 

On the date below, I sent by U.S. first class mail, a copy of the foregoing documents to: 

EQUALIZATION DIRECTOR 

Eric Harger, Equalization Director 

Clinton County 

100 E. State Street 

Suite 2600 

St. Johns, MI 48879 

COUNTY CLERK 

Stephanie L. Dush, County Clerk 

Clinton County 

100 E. State Street 

Suite 2600 

St. Johns, MI 48879 

SECRETARY OF SCHOOL BOARD 

Robert Watson, Secretary 

St. Johns Public School District 

501 W. Sickles 

St. Johns, MI 48879 

STATE TREASURER 

Michigan Department of Treasury 

State Treasurer 

430 West Allegan 

Lansing, MI 48922 

 

I declare that the statement above is true to the best of my information, knowledge and 

belief. 

 

Dated: August 7, 2026 

 

 

 

__/s/ Debbie Ryerson ____ 

 

 

 

 

 

 

 

 

Debbie Ryerson 

 

 

 

29426405.1

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001322

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: BINGHAM SOLAR - PROOF of SERVICE re Petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

BINGHAM SOLAR, LLC 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. _______________ 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No.: 19-030-900-100-001-00 

BINGHAM TOWNSHIP, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

 

_____________________________________ 

 

PETITION 

 

Petitioner, Bingham Solar, LLC (“Petitioner”), by and through its attorneys, VARNUM, 

LLP, states the following for its Petition against Respondent, Bingham Township: 

1. 

Petitioner is a Delaware limited liability company with its principal address at 8400 

Normandale Lake Blvd, Suite 1200, Bloomington, MN 55437. 

2. 

Petitioner is the owner of and/or the party in interest with respect to the subject 

personal property (the "Property") which is located in Bingham Township, Clinton County, 

Michigan and is more particularly described as:

Page 2

2 

 

 

Parcel No. 

Property Address 

19-030-900-100-001-00 

 

Personal property located on the contiguous real 

property parcels with the following addresses: 1635 E. 

Steel Rd., E. Steel Rd., and N. Williams Rd., Saint 

Johns, MI 48879

 

3. 

No real property is under appeal in this Petition. However, the Property consists of 

all personal property that is located upon the real property with the following permanent parcel 

numbers: 19-030-010-100-005-00, 19-030-010-100-010-50, and 19-030-010-100-025-50. 

4. 

Respondent, Bingham Township, ("Respondent"), assesses, levies and collects the 

property taxes on the Property. 

5. 

The Property is in Clinton County and is located within the St. Johns Public School 

District. 

6. 

The 2026 Personal Property Statement for the subject Property was timely filed on 

February 17, 2026. Given the timely filing of the Personal Property Statement, no appeal to the 

March 2026 Board of Review was required. However, an appeal to the March Board of Review 

was made. The 2026 March Board of Review denied Petitioner’s requested relief and instead 

increased the 2026 assessment of the Property purportedly based upon a mis-calculation of 

Respondent. 

7. 

The Property is classified as industrial personal property (351). 

8. 

The Property is used as part of a solar energy facility. 

9. 

The tax year at issue is tax year 2026.

Page 3

3 

 

10. 

The Tax Year 2026 values for the Property as established by Respondent through 

its Board of Review are as follows: 

Tax Year 

Parcel No. 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026 

19-030-900-100-001-

00

$31,375,800 

$15,687,900 

$15,687,900 

 

11. 

Petitioner contends the correct values for the Property are: 

Tax Year 

Parcel No. 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026 

19-030-900-100-001-

00

$15,500,000 

$7,750,000 

$7,750,000 

 

12. 

The values in dispute for the Property are: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026 

19-030-900-100-001-

00

$15,875,800 

$7,937,900 

$7,937,900 

 

13. 

Petitioner requests a reduction of the Property's true cash, assessed, state equalized 

and taxable values as outlined above, which values are based on the relevant market. Petitioner 

further requests a refund with interest of taxes paid due to the original, incorrect assessment, as 

well as any other relief this Tribunal deems appropriate. 

14. 

This matter involves issues relating to (a) assessment, (b) true cash value, and (c) 

taxable value. 

15. 

The 2026 values imposed on the Property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reason that: 

(a) 

The assessed, state equalized, and/or taxable values exceed the amounts 

permitted by the Michigan Constitution and applicable statutes and do not 

reflect the sales of similar properties. 

 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages 

of true cash value than permissible under the Michigan Constitution and 

applicable statutes.

Page 4

4 

 

 

(c) 

The assessed, state equalized and/or taxable values are based upon an 

erroneous determination of the true cash value of Petitioner’s Property and 

are based upon the application of wrong principles. 

 

(d) 

The assessed, state equalized and/or taxable values, and the mode of 

assessment adopted by Respondent, discriminate against Petitioner, its 

constitutional rights of uniformity, equal protection, and due process of law. 

 

 

WHEREFORE, Petitioner requests that the Tribunal grant the following relief: 

 

A. 

Reduce the assessed, state equalized and taxable values of the Property to 

$7,750,000 and order a refund with interest; and 

 

B. 

Provide such additional relief to Petitioner as this Tribunal shall deem appropriate. 

 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

Dated: May 21, 2026 

 

 

By:__/s/ Deborah I. Ondersma ____________ 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

Business Address/Telephone: 

 

 

 

 

 

 

 

333 Bridge Street, N.W. 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

 

ajbrody@varnumlaw.com

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.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Bingham Solar, LLC

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

8400 Normandale Lake Blvd.

City or Town

Bloomington

State

Minnesota

ZIP Code

55437

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Deborah

M.I.

I.

Last Name

Ondersma

Firm Name (if any)

Varnum LLP

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

P.O. Box 352

City or Town

Grand Rapids

State

Michigan

ZIP Code

49501-0352

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

1635 E. Steel Rd.

Saint Johns

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48879

Taxing Authority (City or Township)

Township Of Bingham (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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

19-030-900-100-001-00

Classification of Property: Personal (check one)

Industrial (check one)

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

15687900

Current Taxable Value as established by the Board of Review:

15687900

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

15500000

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

7750000

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

7937900

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ /s/ Deborah I. Ondersma

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052386705812

Supporting Waiver Documents:

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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

Bingham Solar, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001322

Township Of Bingham, 

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: August 6, 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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

BINGHAM SOLAR, LLC 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. _______________ 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No.: 19-030-900-100-001-00 

BINGHAM TOWNSHIP, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

 

_____________________________________ 

 

PETITION 

 

Petitioner, Bingham Solar, LLC (“Petitioner”), by and through its attorneys, VARNUM, 

LLP, states the following for its Petition against Respondent, Bingham Township: 

1. 

Petitioner is a Delaware limited liability company with its principal address at 8400 

Normandale Lake Blvd, Suite 1200, Bloomington, MN 55437. 

2. 

Petitioner is the owner of and/or the party in interest with respect to the subject 

personal property (the "Property") which is located in Bingham Township, Clinton County, 

Michigan and is more particularly described as:

Page 2

2 

 

 

Parcel No. 

Property Address 

19-030-900-100-001-00 

 

Personal property located on the contiguous real 

property parcels with the following addresses: 1635 E. 

Steel Rd., E. Steel Rd., and N. Williams Rd., Saint 

Johns, MI 48879

 

3. 

No real property is under appeal in this Petition. However, the Property consists of 

all personal property that is located upon the real property with the following permanent parcel 

numbers: 19-030-010-100-005-00, 19-030-010-100-010-50, and 19-030-010-100-025-50. 

4. 

Respondent, Bingham Township, ("Respondent"), assesses, levies and collects the 

property taxes on the Property. 

5. 

The Property is in Clinton County and is located within the St. Johns Public School 

District. 

6. 

The 2026 Personal Property Statement for the subject Property was timely filed on 

February 17, 2026. Given the timely filing of the Personal Property Statement, no appeal to the 

March 2026 Board of Review was required. However, an appeal to the March Board of Review 

was made. The 2026 March Board of Review denied Petitioner’s requested relief and instead 

increased the 2026 assessment of the Property purportedly based upon a mis-calculation of 

Respondent. 

7. 

The Property is classified as industrial personal property (351). 

8. 

The Property is used as part of a solar energy facility. 

9. 

The tax year at issue is tax year 2026.

Page 3

3 

 

10. 

The Tax Year 2026 values for the Property as established by Respondent through 

its Board of Review are as follows: 

Tax Year 

Parcel No. 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026 

19-030-900-100-001-

00

$31,375,800 

$15,687,900 

$15,687,900 

 

11. 

Petitioner contends the correct values for the Property are: 

Tax Year 

Parcel No. 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026 

19-030-900-100-001-

00

$15,500,000 

$7,750,000 

$7,750,000 

 

12. 

The values in dispute for the Property are: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026 

19-030-900-100-001-

00

$15,875,800 

$7,937,900 

$7,937,900 

 

13. 

Petitioner requests a reduction of the Property's true cash, assessed, state equalized 

and taxable values as outlined above, which values are based on the relevant market. Petitioner 

further requests a refund with interest of taxes paid due to the original, incorrect assessment, as 

well as any other relief this Tribunal deems appropriate. 

14. 

This matter involves issues relating to (a) assessment, (b) true cash value, and (c) 

taxable value. 

15. 

The 2026 values imposed on the Property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reason that: 

(a) 

The assessed, state equalized, and/or taxable values exceed the amounts 

permitted by the Michigan Constitution and applicable statutes and do not 

reflect the sales of similar properties. 

 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages 

of true cash value than permissible under the Michigan Constitution and 

applicable statutes.

Page 4

4 

 

 

(c) 

The assessed, state equalized and/or taxable values are based upon an 

erroneous determination of the true cash value of Petitioner’s Property and 

are based upon the application of wrong principles. 

 

(d) 

The assessed, state equalized and/or taxable values, and the mode of 

assessment adopted by Respondent, discriminate against Petitioner, its 

constitutional rights of uniformity, equal protection, and due process of law. 

 

 

WHEREFORE, Petitioner requests that the Tribunal grant the following relief: 

 

A. 

Reduce the assessed, state equalized and taxable values of the Property to 

$7,750,000 and order a refund with interest; and 

 

B. 

Provide such additional relief to Petitioner as this Tribunal shall deem appropriate. 

 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

Dated: May 21, 2026 

 

 

By:__/s/ Deborah I. Ondersma ____________ 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

Business Address/Telephone: 

 

 

 

 

 

 

 

333 Bridge Street, N.W. 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

 

ajbrody@varnumlaw.com

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.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Bingham Solar, LLC

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

8400 Normandale Lake Blvd.

City or Town

Bloomington

State

Minnesota

ZIP Code

55437

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Deborah

M.I.

I.

Last Name

Ondersma

Firm Name (if any)

Varnum LLP

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

P.O. Box 352

City or Town

Grand Rapids

State

Michigan

ZIP Code

49501-0352

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

1635 E. Steel Rd.

Saint Johns

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48879

Taxing Authority (City or Township)

Township Of Bingham (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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

19-030-900-100-001-00

Classification of Property: Personal (check one)

Industrial (check one)

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

15687900

Current Taxable Value as established by the Board of Review:

15687900

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

15500000

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

7750000

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

7937900

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ /s/ Deborah I. Ondersma

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052386705812

Supporting Waiver Documents:

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.