Morbark LLC, Petitioner Vs. Township Of Fremont, Respondent

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 

Morbark LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001756 

 

Fremont Township, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms, and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2020, through June 30, 2022, at the rate of 4.25%, 

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after 

December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 

2023, through December 31, 2023, at the rate of 8.25%, (v) after December 31, 2023, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001756 

Page 2 of 2 

 

through June 30, 2024, at the rate of 9.30%, (vi) after June 30, 2024, through December 

31, 2024, at the rate of 9.50%, (vii) after December 31, 2024, through June 30, 2025, at 

the rate of 9.47%, and (viii) after June 30, 2025, through December 31, 2025, at the rate 

of 8.66%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

 

By _____________________________ 

Entered: October 30, 2025 

jc 

 

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 TAX TRIBUNAL 

MORBARK LLC, 

Petitioner, 

MTT Docket No. 25-001756 

FREMONT TWP. - ISABELLA, 

Respondent. 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

The parcel is located in Isabella County. 

The case is pending in the X Entire Tribunal OR __ Small Claims Division. 

Property Parcel No: 07-015-30-002-03. 

The values for the property identified above as established by Respondent’s Board of 

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$18,893,200 

$9,446,600 

$9,096,884 

5. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2025 

$16,200,000 

$8,100,000 

$8.100.000 

If stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or 

years (attach additional page if necessary): 

62566188.1

Page 2

MTT Docket No. 25-001756 

Stipulation for Entry of Consent Judgment 

7. 

List separately any special terms or conditions being proposed by the parties that would 

affect the execution of this Consent Judgment including, but not limited to, the joint 

payment of the refund, the waiver of interest, etc.: 

All interest due hereunder is waived if, and only if, all refunds otherwise due are paid 

within 60 days of the entry of the consent judgment, however, otherwise interest shall be 

paid as provided in the Tax Tribunal Act, including MCL 205.737. 

IT IS 

FURTHER ORDERED AND ADJUDGED that refunds shall be 

made payable jointly 

to Petitioner named herein and 

its counsel, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660 

Woodward, Suite 2290, Detroit, MI 48226. 

Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

HONIGMAN LLP 

FOSTER, SWIFT, COLLINS & 

SMITH, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

bw DiS) 

TH Ls 

Daniel L. Stanley (P57052 

222 North Washington 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

Dated: 

10/29) 2525 

62566188.1 

Michael D. Homier (P60318) 

Thomas K. Dillon (P81136) 

1700 E. Beltline NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2230 

mhomier@fosterswift.com 

tdillon@fosterswift.com 

Dated: October 29, 2025

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MORBARK LLC, 

Petitioner, 

MTT Docket No. 25-001756 

FREMONT TWP. - ISABELLA, 

Respondent. 

/ 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

The parcel is located in Isabella County. 

The case is pending in the X Entire Tribunal OR __ Small Claims Division. 

Property Parcel No: 07-015-30-002-03. 

The values for the property identified above as established by Respondent’s Board of 

Review are: 

Tax 

True Cash 

Assessed 

Taxable 

Year 

Value 

Value 

Value 

2025 

$18,893,200 

$9,446,600 

$9,096,884 

5. 

The values for the property identified above as stipulated by the parties for settlement 

purposes are: 

Tax 

True Cash 

State Equalized 

Taxable 

Year 

Value 

Value 

Value 

2025 

$16,200,000 

$8,100,000 

$8.100.000 

If stipulation addresses tax years other than the tax year originally appealed or tax years 

added through motions to amend that have been granted by the Tribunal, list the separate 

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or 

years (attach additional page if necessary): 

62566188.1

Page 2

MTT Docket No. 25-001756 

Stipulation for Entry of Consent Judgment 

7. 

List separately any special terms or conditions being proposed by the parties that would 

affect the execution of this Consent Judgment including, but not limited to, the joint 

payment of the refund, the waiver of interest, etc.: 

All interest due hereunder is waived if, and only if, all refunds otherwise due are paid 

within 60 days of the entry of the consent judgment, however, otherwise interest shall be 

paid as provided in the Tax Tribunal Act, including MCL 205.737. 

IT IS 

FURTHER ORDERED AND ADJUDGED that refunds shall be 

made payable jointly 

to Petitioner named herein and 

its counsel, 

Honigman LLP, and sent to Stewart L. Mandell, Honigman LLP, 660 

Woodward, Suite 2290, Detroit, MI 48226. 

Calculations of the refund 

amount shall also be sent to Petitioner’s counsel at the same address. 

HONIGMAN LLP 

FOSTER, SWIFT, COLLINS & 

SMITH, P.C. 

Attorneys for Petitioner 

Attorneys for Respondent 

bw DiS) 

TH Ls 

Daniel L. Stanley (P57052 

222 North Washington 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

Dated: 

10/29) 2525 

62566188.1 

Michael D. Homier (P60318) 

Thomas K. Dillon (P81136) 

1700 E. Beltline NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2230 

mhomier@fosterswift.com 

tdillon@fosterswift.com 

Dated: October 29, 2025

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Page 1

RECEIVED 

JUN 06 2025 Wi D 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Morbark LLC, 

Petitioner, 

Ca 

N 

«<. 

f) 

v. 

MTT Docket No. 

1 > 

( 0 

l 7 5 

[Parcel No(s). 07-015-30-002-03] 

Fremont Twp. 

- Isabella, 

Respondent. 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

that on 

S/ 30 

[ >< , she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

/s/ Lis (pact 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

FREMONT TWP. - ISABELLA 

2266 W. BLANCHARD ROAD 

MT. PLEASANT, MI 48858 

ASSESSOR 

FREMONT TWP. - ISABELLA 

2266 W. BLANCHARD ROAD 

MT. PLEASANT, MI 48858 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

ISABELLA COUNTY 

200 N. MAIN STREET 

MT. PLEASANT, MI 48858-2321 

DIRECTOR OF EQUALIZATION 

ISABELLA COUNTY 

200 N. MAIN STREET 

MT. PLEASANT, MI 48858-2321 

SECRETARY OF SCHOOL BOARD 

SHEPHERD PUBLIC SCHOOLS 

258 W. WRIGHT, P.O. BOX 219 

SHEPHERD, MJ 48883-0219 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0102

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Page 1

25-0102 

60699300.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Morbark LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 07-015-30-002-03] 

Fremont Twp. - Isabella, 

Respondent. 

_________________________/ 

PETITION 

Morbark LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 8507 S. Winn Road, Winn, MI 48896. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 07-015-30-002-

03 ("Petitioner's Property"), at 8507 S. Winn Road located in Isabella County, Michigan. If this 

petition includes more than one (1) real property tax parcel, the tax parcels are contiguous. 

2. 

Respondent, Fremont Twp. - Isabella, assesses and collects property taxes on 

Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$9,096,884 and assessed Petitioner's Property at $9,446,600, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4. 

Petitioner's Property is classified as Industrial Real. Petitioner's Property is 

presently used or available for use for Industrial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for Industrial purposes.

Page 2

2 

60699300.1 

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. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 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, 

(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.

Page 3

3 

60699300.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value of Petitioner's Property from $9,096,884 to $3,300,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $9,446,600 to $3,300,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Daniel L. Stanley (P57052) 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

 

 

/s/ Daniel L. Stanley

May 29, 2025

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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

Morbark LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001756

Township Of Fremont, 

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: July 23, 2025

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 

MORBARK LLC, 

Petitioner, 

9 

FREMONT TOWNSHIP, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 25-001756 

Parcel ID No. 07-015-30-002-03 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517)377-0714 

dstanley@honigman.com 

Michael D. Homier (P60318) 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, P.C. 

Attorneys for Respondent 

1700 East Beltline Avenue NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

mhomier@fosterswift.com 

PROOF OF SERVICE 

On June 30, 2025, 

I served a copy of Respondent Fremont Township’s Answers and 

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: 

June 30,2025 

aes ACBL 

aclyn R/JFolkema - Legal Assistant 

89469:00001:201709620-1

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

______________________ 

 

MORBARK LLC, 

 

 

Petitioner, 

 

v. 

 

FREMONT TOWNSHIP, 

 

 

Respondent. 

MTT Docket No. 25-001756 

 

Parcel ID No. 07-015-30-002-03 

 

______________________________________________________________________________ 

 

Daniel L. Stanley (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

Michael D. Homier (P60318) 

Thomas K. Dillon (P81136) 

FOSTER SWIFT COLLINS & SMITH, P.C. 

Attorneys for Respondent 

1700 East Beltline Avenue NE, Suite 200 

Grand Rapids, MI 49525 

(616) 726-2258 

tdillon@fosterswift.com 

mhomier@fosterswift.com 

______________________________________________________________________________ 

 

RESPONDENT FREMONT TOWNSHIP’S ANSWERS & AFFIRMATIVE DEFENSES 

TO ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

Respondent, Fremont Township, by and through its attorneys, Foster, Swift, Collins & 

Smith, P.C., states as follows for its Answers to Petitioner’s Entire Tribunal Property Tax Petition: 

1. 

Petitioner's principal office address is 8507 S. Winn Road, Winn, MI 48896. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 07-015-30-

002-03 ("Petitioner's Property"), at 8705 S. Winn Road located in Isabella County, Michigan. 

If this petition includes more than one (1) real property tax parcel, the tax parcels are contiguous. 

ANSWER: 

Respondent neither admits nor denies the allegations regarding Petitioner’s 

principal office address and whether Petitioner is a “party in interest” 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. 

Respondent, Fremont Twp. – Isabella, assesses and collects property taxes on 

Petitioner's Property. 

ANSWER: 

Respondent admits the allegation contained in paragraph 2 of the Petition. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$9,096,884 and assessed Petitioner's Property at $9,446,600, which will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

ANSWER: Respondent admits the allegation contained in paragraph 3 of the Petition. 

4. 

Petitioner's Property is classified as Industrial Real. Petitioner's Property is 

presently used or available for use for Industrial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for Industrial purposes. 

ANSWER: 

Respondent admits that the property is classified as Industrial Real. 

Respondent neither admits nor denies the remaining allegations in paragraph 4 as 

Respondent is without sufficient knowledge or information to form a belief as to the 

remaining allegations in paragraph 4. Respondent leaves Petitioner to its proofs. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value and (d) uniformity. 

ANSWER: 

Respondent neither admits nor denies the allegations in paragraph 5 of the 

Petition and leaves Petitioner to its proofs. 

6. 

At this time, Petitioner believes, as it relates to taxable value, that there is a 

dispute relative to the value of a loss. 

ANSWER: 

As Paragraph 6 pleads no facts, this Paragraph is insufficient to raise an 

issue for appeal (TTR 227(1)) and fails to state a claim on which relief can be granted 

(MCR 2.116 (C) (8)). The allegations are denied. 

7. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, 

a board of review protest was filed in March, 2025. 

ANSWER: 

Paragraph 7 of the Petition does not contain a factual allegation requiring 

a response but is a hypothetical. To the extent that paragraph 7 contains a factual

Page 3

allegation, Respondent denies the allegation and leaves Petitioner to its proofs as to 

whether the Tribunal has jurisdiction. Respondent reserves its right to object to 

jurisdiction if Petitioner failed to comply to the requirements of MCL 205.735a. 

8. 

The 2025 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, 

(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. 

ANSWER: 

Respondent denies the allegations contained in paragraph 8 of the Petition, 

including all allegations made in subparagraphs a. through d., and leaves

Page 4

AFFIRMAT

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001756

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Fremont (ISABELLA)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Tom

M.I.

Last Name

Dillon

Firm Name (if any)

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

1700 E Beltline NE, Ste 200

City or Town

Grand Rapids

State

Michigan

ZIP Code

49525

Telephone Number

616-726-2258

Fax Number

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

25-0102 

60699300.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Morbark LLC, 

Petitioner, 

v. 

MTT Docket No. _______________ 

 

[Parcel No(s). 07-015-30-002-03] 

Fremont Twp. - Isabella, 

Respondent. 

_________________________/ 

PETITION 

Morbark LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 8507 S. Winn Road, Winn, MI 48896. 

Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 07-015-30-002-

03 ("Petitioner's Property"), at 8507 S. Winn Road located in Isabella County, Michigan. If this 

petition includes more than one (1) real property tax parcel, the tax parcels are contiguous. 

2. 

Respondent, Fremont Twp. - Isabella, assesses and collects property taxes on 

Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$9,096,884 and assessed Petitioner's Property at $9,446,600, which will result in a state equalized 

value in the same amount based upon the tentative equalization factor. 

4. 

Petitioner's Property is classified as Industrial Real. Petitioner's Property is 

presently used or available for use for Industrial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for Industrial purposes.

Page 2

2 

60699300.1 

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. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

8. 

The 2025 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, 

(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.

Page 3

3 

60699300.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 

taxable value of Petitioner's Property from $9,096,884 to $3,300,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $9,446,600 to $3,300,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Daniel L. Stanley (P57052) 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

 

 

/s/ Daniel L. Stanley

May 29, 2025

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

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Morbark LLC

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

8507 S. Winn Road

City or Town

Winn

State

Michigan

ZIP Code

48896

Telephone Number

2485668300

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Daniel

M.I.

Last Name

Stanley

Firm Name (if any)

Honigman LLP

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

222 N. Washington Sq

Suite 400

City or Town

Lansing

State

Michigan

ZIP Code

48933

Telephone Number

517-377-0714

Fax Number

517-364-9514

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

DStanley@Honigman.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

Michigan

Taxing Authority (City or Township)

Township Of Fremont (ISABELLA)

County

Isabella

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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

07-015-30-002-03

Classification of Property: Real 

Commercial

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

9446600

Current Taxable Value as established by the Board of Review:

9096884

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

6500000

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

3300000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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.

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/ Daniel L. Stanley

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.