Record Finder / 26-001409-TT
Michigan
Heartland Recreational Vehicles LLC Petitioner Vs. City Of Sturgis Respondent
- Petitioner
- Heartland Recreational Vehicles LLC
- Respondent
- City Of Sturgis
Case overview
- Docket number
- 26-001409-TT
- Status
- Answer Due
- CaseType
- ET Property
- Division
- ET
- County
- Saint Joseph
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 7 | Proof of Service of Misc Documents was received. | Not recorded | Not recorded | 10/16/2026 | Not recorded | Download |
| 6 | Appearance | Not recorded | Not recorded | 10/16/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 5 | Answer was received | RESP | Not recorded | 10/16/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | Not recorded | Not recorded | 09/15/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 08/11/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 08/11/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/26/2026 | $600.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
POS 26-001409-TT.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL HEARTLAND RECREATION VEHICLES, LLC, Petitioner, MTT Docket No. 26-001409-TT V CITY OF STURGIS, Respondent. Aaron M. Fales (P72864) Robert E. Thall (P46421) Law Offices of Aaraon M. Fales, P.C. Bauckham, Thall, Seeber, Attorney for Petitioner Kaufman, & Koches, P.C. 330 Hamilton Row, Ste. 350 Attorney for Respondent Birmingham, MI 48009 470 W. Centre Ave., Ste. A 248-767-9840 Portage, MI 49024 afaleslaw@gmail.com 269-382-4500 thall@michigantownshiplaw.com PROOF OF SERVICE Robert E. Thall states that on October 16, 2026, she served a copy of an Appearance, Answer to Petition with Affirmative Defenses and Proof of Service in this matter by first-class mail, postage fully prepaid, upon the Petitioner at the above referenced address. /s/ Robert E. Thall Robert E. Thall
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Appearance 26-001409-TT.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL HEARTLAND RECREATION VEHICLES, LLC, Petitioner, MTT Docket No. 26-001409-TT V CITY OF STURGIS, Respondent. Aaron M. Fales (P72864) Robert E. Thall (P46421) Law Offices of Aaraon M. Fales, P.C. Bauckham, Thall, Seeber, Attorney for Petitioner Kaufman, & Koches, P.C. 330 Hamilton Row, Ste. 350 Attorney for Respondent Birmingham, MI 48009 470 W. Centre Ave., Ste. A 248-767-9840 Portage, MI 49024 afaleslaw@gmail.com 269-382-4500 thall@michigantownshiplaw.com APPEARANCE The law firm of Bauckham, Thall, Seeber, Kaufman, & Koches P.C., enters this appearance for and on behalf of Respondent, City of Sturgis, in this matter. Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN, & KOCHES P.C. Date: October 16, 2026 By: /s/ Robert E. Thall Robert E. Thall (P46421) Attorney for Respondent
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SubsequentFiling.pdfRead complete document text →
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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: 26-001409 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Appearance Attachment File Name: Appearance 26-001409-TT Document Type: Proof of Service: Misc Documents Attachment File Name: POS 26-001409-TT Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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Answer 26-001409-TT.pdfRead complete document text →
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL HEARTLAND RECREATION VEHICLES, LLC, Petitioner, MTT Docket No. 26-001409-TT V CITY OF STURGIS, Respondent. Aaron M. Fales (P72864) Robert E. Thall (P46421) Law Offices of Aaraon M. Fales, P.C. Bauckham, Thall, Seeber, Attorney for Petitioner Kaufman, & Koches, P.C. 330 Hamilton Row, Ste. 350 Attorney for Respondent Birmingham, MI 48009 470 W. Centre Ave., Ste. A 248-767-9840 Portage, MI 49024 afaleslaw@gmail.com 269-382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, City of Sturgis, states the following in response to the respective paragraphs of the Petition filed in this matter: 1. In answer to paragraph 1 of the Petition, Respondent admits the allegations therein. 2. In answer to paragraph 2 of the Petition, Respondent admits the allegations therein. 3. In answer to paragraph 3 of the Petition, Respondent admits the allegations therein. It should be noted that parcel 052-950-800-01 is Industrial Real IFT property, IFT certificate 2022- 097. 4. In answer to paragraph 4 of the Petition, Respondent admits the allegations therein.
Page 2
5. In answer to paragraph 5 of the Petition, Respondent admits that the Petitioner has raised such issues. 6. In answer to paragraph 6 of the Petition, Respondent is without knowledge or information sufficient to form a belief as to the truth of the allegation contained therein. Respondent is unaware of a "dispute relative to the value of a loss". 7. In answer to paragraph 7 of the Petition and its subparts, Respondent denies the allegations therein as untrue. WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying the relief requested by Petitioner and uphold and affirm the valuations as established by the Respondent and require Petitioner to pay Respondent’s costs and attorney fees. AFFIRMATIVE DEFENSES Please take notice that Respondent may rely on one or more of the following affirmative defenses: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 3. The service of process was insufficient. 4. The subject property is under assessed and/or the taxable value and/or state equalized value of the subject property is too low, and should therefore be appropriately increased to comply with the mandate of the applicable provisions of law. 5. Respondent reserves the right to file such additional affirmative defenses as may become apparent pursuant to discovery procedures during the pendency of this matter. WHEREFORE Respondent requests that the Tribunal enter a determination of no cause in its favor, and such other and further relief as is appropriate including costs and attorney fees.
Page 3
Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN, & KOCHES, P.C. Date: October 16, 2026 By: /s/ Robert E. Thall Robert E. Thall (P46421) Attorney for Respondent
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EntireTribunalCaseISAnswer.pdfRead complete document text →
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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. 26-001409 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Sturgis (SAINT JOSEPH) 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 Robert M.I. E Last Name Thall Firm Name (if any) Bauckham, Thall, et al Address (No., Street, P.O. Box or Rural Route) 470 W. Centre Ave., Suite A City or Town Portage State Michigan ZIP Code 49024 Telephone Number 2693824500 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) thall@michigantownshiplaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Robert E Thall /s/
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26 - Sturgis POS.pdfRead complete document text →
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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
Page 2
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] 48922Page 3
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
Page 4
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 atPage 5
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 cashPage 6
{d}
The
assessment,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.
SubsequentFiling.pdfRead complete document text →
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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: 26-001409 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: 26 - Sturgis POS Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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2026 Petition - Sturgis.pdfRead complete document text →
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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.Page 2
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,
Page 3
(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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EntireTribunalCaseISPetition.pdfRead complete document text →
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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 Heartland Recreational Vehicles LLC Home Address (No., Street, P.O. Box or Rural Route) 2831 Dexter Dr. City or Town Elkhart State Indiana ZIP Code 46514 Telephone Number 2487679840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Aaron M.I. Last Name Fales Firm Name (if any) Law Office of Aaron M Fales, P.C. Address (No., Street, P.O. Box or Rural Route) 330 Hamilton Row Suite 350 City or Town Birmingham State Michigan ZIP Code 48009 Telephone Number 248-767-9840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.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] 1200 Haines Sturgis
Page 2
STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 49091 Taxing Authority (City or Township) City Of Sturgis (SAINT JOSEPH) County Saint Joseph 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: 052-950-800-01 Classification of Property: Real (check one) Industrial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 5705100 Current Taxable Value as established by the Board of Review: 5294185 What do you believe is the fair market value (also known as True Cash Value)? 4000000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 2000000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 2000000 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/ Aaron Fales Payment Information Amount: 600 Success: True Message: "" Waiver Code: Transaction Number: 26052686933806 Supporting Waiver Documents:
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ET_Notice_of_Docket_Number.2026-08-11_14-05-58.pdfRead complete document text →
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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 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 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 11, 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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2026 Petition - Sturgis.pdfRead complete document text →
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Page 1
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.Page 2
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,
Page 3
(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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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 Heartland Recreational Vehicles LLC Home Address (No., Street, P.O. Box or Rural Route) 2831 Dexter Dr. City or Town Elkhart State Indiana ZIP Code 46514 Telephone Number 2487679840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.com Section 2: Attorney/Authorized Representative’s Contact Information First Name Aaron M.I. Last Name Fales Firm Name (if any) Law Office of Aaron M Fales, P.C. Address (No., Street, P.O. Box or Rural Route) 330 Hamilton Row Suite 350 City or Town Birmingham State Michigan ZIP Code 48009 Telephone Number 248-767-9840 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) afaleslaw@gmail.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] 1200 Haines Sturgis
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 49091 Taxing Authority (City or Township) City Of Sturgis (SAINT JOSEPH) County Saint Joseph 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: 052-950-800-01 Classification of Property: Real (check one) Industrial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 5705100 Current Taxable Value as established by the Board of Review: 5294185 What do you believe is the fair market value (also known as True Cash Value)? 4000000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 2000000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 2000000 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.
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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/ Aaron Fales Payment Information Amount: 600 Success: True Message: "" Waiver Code: Transaction Number: 26052686933806 Supporting Waiver Documents:
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