Johnsons Surplus LLC Petitioner Vs. Township Of Mottville Respondent
- Petitioner
- Johnsons Surplus LLC
- Respondent
- Township Of Mottville
Case overview
- Docket number
- 26-000962-TT
- Status
- Ready Sched Prehearing Date Certain
- 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 |
|---|---|---|---|---|---|---|
| 8 | Prehearing General Call | Not recorded | Not recorded | 10/01/2026 | Not recorded | Download |
| 7 | Proof of Service of Misc Documents was received. | Not recorded | Not recorded | 09/11/2026 | Not recorded | Download |
| 6 | Appearance | Not recorded | Not recorded | 09/11/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 5 | Answer was received | RESP | Not recorded | 09/11/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 08/06/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 06/23/2026 | 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 | 06/23/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/14/2026 | $600.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
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 NOTICE OF SEPTEMBER 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Johnsons Surplus LLC, Petitioner, v Township Of Mottville, Respondent. MTT Docket No. 26-000962 Please be advised that 26-000962 has been placed on a two-week Prehearing General Call commencing September 01, 2027. Unless ordered otherwise, parties will be notified at least 28 days before they are scheduled to appear. Scheduling will not necessarily occur in the order in which the cases are listed below. Parties are required to submit a valuation disclosure or written notification that no valuation disclosure is required by the dates indicated herein. A “valuation disclosure” is defined as documentary or other tangible evidence in a property tax proceeding that a party relies upon in support of the party’s contention as to the true cash value of the subject property or any portion thereof and contains the party’s value conclusion and data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241. Users who file documents with the Tribunal are advised that filed documents are public records and will appear for public viewing on the Tribunal’s Tax Docket Lookup. If a user wishes to file a document for consideration by the Tribunal and prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents covered by the order will not be published. Documents filed prior to the issuance of a Protective Order will be published. In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or redacting personal identifying information (PII) from all documents filed with or offered to the Tribunal rests solely with the parties and their attorneys. The Tribunal is not responsible for or required to review, redact, or screen documents at the time of filing for PII whether filed electronically or on paper. A party, representative, or interested person (i.e. third party not part of an appeal) may request that the Tribunal redact PII contained in a previously filed document by submitting a Request for Redactions. The Request for Redactions form is available on the Entire Tribunal and Small Claims pages of the Tribunal’s website. Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s website for more information.
Page 2
MTT Docket No. 26-000962 Page 2 of 3 IT IS ORDERED that the parties shall: a. If no valuation disclosure is required, notify the Tribunal and the opposing parties in writing within 21 days of entry of this order that no valuation disclosure is being filed. The notice shall indicate the reason or reasons why no valuation disclosure is required (i.e., exemption claim, etc.). b. If a valuation disclosure is required, file and exchange their valuation disclosures by May 5, 2027. Valuation disclosures will not be admitted into evidence unless disclosed and furnished in accordance with this order (even though admissible) except upon a finding of good cause by the Tribunal. IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing Statements by May 5, 2027. Witnesses, with the exception of rebuttal witnesses, will not be allowed to testify unless disclosed in the Prehearing Statement and the Prehearing Statement is furnished in accordance with this order except upon a finding of good cause by the Tribunal. Failure to file the Prehearing Statement may result in holding a party or parties in default. See TTR 237. IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on May 5, 2027, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. Discovery relative to the valuation disclosure prepared for purposes of litigating this case or the valuation expert that prepared that valuation disclosure is not permitted during “Pre-Valuation Disclosure” discovery. IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on September 1, 2027, which means all discovery has been requested, all Motions to Compel have been filed, and all requested or ordered discovery has been exchanged by that date. “Post-Valuation Disclosure”
Page 3
MTT
Page 4
STATE
Page 5
M
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL JOHNSONS SURPLUS LLC, Petitioner, MTT Docket No. 26-000962-TT V MOTTVILLE TOWNSIP, 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 Sandra L. Bosse states that on September 10, 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. Sandra L. Bosse Sandra L. Bosse
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL JOHNSONS SURPLUS LLC, Petitioner, MTT Docket No. 26-000962-TT V MOTTVILLE TOWNSIP, 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, Mottville Township, in this matter. Respectfully submitted, BAUCKHAM, THALL, SEEBER, KAUFMAN, & KOCHES P.C. Date: September 10, 2026 By: /s/ Robert E. Thall Robert E. Thall (P46421) Attorney for Respondent
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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: 26-000962 Is this case currently pending in the Small Claims Division? No Party Filing Document Respondent Files Document Type: Appearance Attachment File Name: Appearance 26-000962-TT Document Type: Proof of Service: Misc Documents Attachment File Name: POS 26-000962-TT Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL JOHNSONS SURPLUS LLC, Petitioner, MTT Docket No. 26-000962-TT V MOTTVILLE TOWNSIP, 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, Mottville Township, 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. 4. In answer to paragraph 4 of the Petition, Respondent admits the allegations therein. 5. In answer to paragraph 5 of the Petition, Respondent admits that the Petitioner has raised such issues.
Page 2
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: September 10, 2026 By: /s/ Robert E. Thall Robert E. Thall (P46421) Attorney for Respondent
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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. 26-000962 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government Township Of Mottville (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 Kalamazoo 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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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL JOHNSONS SURPLUS LLC, Petitioner, Vv. MTT Docket # 26-000962 TOWNSHIP OF MOTTVILLE, Respondent. PROOF OF SERVICE STATE OF MICHIGAN ) } ss. COUNTY OF OAKLAND} Aaron M. Fales, being duly sworn, deposes and says that on August b, 2026 he served a copy of Petitioner's Petition on the parties named on the attached list. Aaron M. Fales
Page 2
STATE OF MICHIGAN GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MARLON |. BROWN, DPA GOVERNOR LANSING DIRECTOR Johnsons Surplus LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-000962 Township Of Mottville, 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), “[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: June 23, 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 3
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Page 4
STATE OF MICHIGAN
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
JOHNSONS SURPLUS LLC,
Petitioner,
MTT Docket #26-000962
vs.
Parcel No. 75-011-004-015-00
MOTTVILLE TOWNSHIP,
Respondent.
PETITION
JOHNSONS SURPLUS LLC ("Petitioner"), through its attorneys, Law Office of
Aaron M, Fales, P.C., says:
1.
Petitioner's principal office address
is 12195 US HIGHWAY 12, White
Pigeon, MI 49099.
Petitioner is a party in interest with respect to property taxes
on real property tax parcel no(s). 75-011-004-015-00 ("Petitioner's Property"), at
12195 US 12, White Pigeon, MI, 49099.
2.
Respondent, Mottville Township assesses and collects property taxes
on Petitioner's Property.
3.
In 2026, Respondent determined the taxable value of Petitioner's
Parcel fo be $674,083 and assessed Petitioner's Property at $930,000 resulting in aPage 5
4,
Petitioner's
Property
is
classified
as
Commercial
Real
Property.
Petitioner's
Property
is
a
commercial
property.
Petitioner
believes
that
Petitioner's Property was designed to be used for commercial 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
fo
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 true cash value than permissiblePage 6
(d)
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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: 26-000962 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: Johnsons - Mottville POS Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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STATE OF MICHIGAN
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
JOHNSONS SURPLUS LLC,
Petitioner,
vs.
MOTTVILLE TOWNSHIP,
Respondent.
/
MTT Docket #26-00
Parcel No. 75-011-004-015-00
PETITION
JOHNSONS SURPLUS LLC (“Petitioner”), through its attorneys, Law Office of
Aaron M. Fales, P.C., says:
1.
Petitioner's principal office address is 12195 US HIGHWAY 12, White
Pigeon, MI 49099. Petitioner is a party in interest with respect to property taxes
on real property tax parcel no(s). 75-011-004-015-00 ("Petitioner's Property"), at
12195 US 12, White Pigeon, MI, 49099.
2.
Respondent, Mottville Township assesses and collects property taxes
on Petitioner's Property.
3.
In 2026, Respondent determined the taxable value of Petitioner's
Parcel to be $674,083 and assessed Petitioner's Property at $930,000 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 Commercial Real Property. Petitioner's Property is a commercial property. Petitioner believes that Petitioner's Property was designed to be used for commercial 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,
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(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 from $674,083 to $200,000, and reducing the 2026 assessed and state equalized values of Petitioner's Property from $930,000 to $200,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Dated: ___________, 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 May 12
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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 Johnsons Surplus LLC Home Address (No., Street, P.O. Box or Rural Route) 12195 US Hwy 12 City or Town White Pigeon State Michigan ZIP Code 49099 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] 12195 US 12 Mottville
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 49099 Taxing Authority (City or Township) Township Of Mottville (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: 75-011-004-015-00 Classification of Property: Real (check one) Commercial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 930000 Current Taxable Value as established by the Board of Review: 674083 What do you believe is the fair market value (also known as True Cash Value)? 400000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 200000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 200000 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: 26051284973554 Supporting Waiver Documents:
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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 Johnsons Surplus LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-000962 Township Of Mottville, 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: June 23, 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
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
JOHNSONS SURPLUS LLC,
Petitioner,
vs.
MOTTVILLE TOWNSHIP,
Respondent.
/
MTT Docket #26-00
Parcel No. 75-011-004-015-00
PETITION
JOHNSONS SURPLUS LLC (“Petitioner”), through its attorneys, Law Office of
Aaron M. Fales, P.C., says:
1.
Petitioner's principal office address is 12195 US HIGHWAY 12, White
Pigeon, MI 49099. Petitioner is a party in interest with respect to property taxes
on real property tax parcel no(s). 75-011-004-015-00 ("Petitioner's Property"), at
12195 US 12, White Pigeon, MI, 49099.
2.
Respondent, Mottville Township assesses and collects property taxes
on Petitioner's Property.
3.
In 2026, Respondent determined the taxable value of Petitioner's
Parcel to be $674,083 and assessed Petitioner's Property at $930,000 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 Commercial Real Property. Petitioner's Property is a commercial property. Petitioner believes that Petitioner's Property was designed to be used for commercial 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,
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(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 from $674,083 to $200,000, and reducing the 2026 assessed and state equalized values of Petitioner's Property from $930,000 to $200,000, and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs. Dated: ___________, 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 May 12
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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 Johnsons Surplus LLC Home Address (No., Street, P.O. Box or Rural Route) 12195 US Hwy 12 City or Town White Pigeon State Michigan ZIP Code 49099 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] 12195 US 12 Mottville
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Michigan 49099 Taxing Authority (City or Township) Township Of Mottville (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: 75-011-004-015-00 Classification of Property: Real (check one) Commercial (check one) Current Assessed Value (also known as State Equalized Value) as established by the Board of Review: 930000 Current Taxable Value as established by the Board of Review: 674083 What do you believe is the fair market value (also known as True Cash Value)? 400000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 200000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 200000 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: 26051284973554 Supporting Waiver Documents:
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