Renosol Corp, Petitioner V City Of Clare, 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 

Renosol Corp, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-003291 

 

City of Clare, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER OF DISMISSAL 

 

The Tribunal has considered the file in this case and finds that it has no authority over 

Petitioner’s appeal. The pleadings and accompanying documentation indicate that 

Petitioner is appealing the taxable value and exempt status for Parcel No. 051-990-226-

01 for the 2025 tax year. The Tribunal has no authority over that parcel under MCL 

211.9m(2)(c), however, because Petitioner failed to appeal an assessor denial of the 

exemption claim to the March Board of Review (BOR) or, alternatively, failed to appeal 

the BOR decision to the Tribunal within 35 days of that decision.1 No BOR decision 

was provided.2 However, the petition in this case was filed on September 2, 2025. The 

statutory requirement of the timeframe of the BOR indicates that the board’s business 

should have been resolved more than 35 days prior to that date.3 The appeal appears 

to be filed beyond the statutory timeframe. 

 

Petitioner’s failure to file the appeal by the statutory deadline is a failure to invoke the 

Tribunal’s statutory jurisdiction over this proceeding.4 In SixArp, the Michigan Supreme 

Court reiterated previous appellate decisions in its reasoning that the Tribunal’s 

jurisdiction is statutory by nature. 

 

MCL 205.735a(3) “is not a notice statute, but is a jurisdictional statute that 

governs when and how a petitioner invokes the Tax Tribunal’s jurisdiction.” 

We therefore overrule Parkview5 to the extent that it incorrectly held that the 

protest requirement of . . . the precursor to MCL 205.735a . . . is a mere 

“procedural requirement for perfecting an appeal in the Tax Tribunal” and 

not an express limitation on the MTT’s jurisdiction. Instead, the protest 

requirement of MCL 205.735a(3) may only be waived by the court if 

 

1 MCL 211.9m(2)(c) states in pertinent part: “An appeal of a denial by the March board of review may be 

made by filing a petition with the Michigan tax tribunal within 35 days of the denial notice.” 

2 Petitioner’s motion at Appendix 10. 

3 See MCL 211.30(7). “The appropriate assessing officer shall deliver the completed assessment roll to 

the county equalization director not later than the tenth day after the adjournment of the board of review, 

or the Wednesday following the first Monday in April, whichever date occurs first.” 

4 See SixArp, LLC v Byron Twp, __Mich __; __ NW3d __ (2025) (Docket No 166190) at 8. 

5 Parkview Memorial Ass’n v City of Livonia¸ 183 Mich App 116; 454 NW2d 169 (1990).

Page 2

MTT Docket No. 25-003291 

Page 2 of 3 

 

necessary to remedy a constitutional due-process violation that deprived 

the taxpayer of their ability to invoke the right to protest.6 

 

The Tribunal finds that the same reasoning relied upon by the Six Arp court is 

applicable to MCL 211.9m(2)(c) in this case. The Legislature created a statutory 

jurisdiction requirement that the BOR decision be appealed by filing a petition with the 

Tribunal within 35 days of the day of the BOR notice. This statutory subsection, like 

MCL 205.735a(3), controls the Tribunal’s jurisdiction over an appeal. The Tribunal has 

no equitable power to disregard a statutory filing deadline.7 “If an assessment for a 

particular tax year is not protested to the Board and appealed to the Tribunal via timely 

petition, the Tribunal lacks jurisdiction to consider challenges to that tax year.”8 

 

The Tribunal notes that Petitioner is attempting to appeal a Summary of Changes letter 

issued by the Michigan Department of Treasury. This is not a final decision of a taxing 

agency, and as such, the Tribunal lacks authority to take jurisdiction based on the 

provided letter. As explained above, the Tribunal lacks any equitable authority to 

consider a potential due-process violation. Jurisdiction as a result of a failure of a unit of 

government to comply with a statutory obligation, if there was any, may be vested upon 

the Tribunal by a judicial body only as a matter of equity.9 Lacking jurisdiction, the only 

appropriate action is dismissal. Therefore, 

 

IT IS ORDERED that the case is DISMISSED. 

 

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

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

 

6 See SixArp at 8 (citations omitted). 

7 The Tribunal’s powers are limited to those authorized by statute and do not include powers of equity. 

See Federal-Mogul Corp v Dep’t of Treasury, 161 Mich App 346 (1987), Elec Data Sys Corp v Flint Twp, 

253 Mich App 538 (2002), and VanderWerp v Plainfield Twp, 278 Mich App 624 (2008). 

8 See Forbes v City of Ann Arbor, unpublished per curiam opinion of the Michigan Court of Appeals, 

issued May 11, 2023 (Docket No 361648). 

9 See SixArp at 4, 8. The court held respectively that “the Court of Appeals remedied the violation by 

vesting the MTT with jurisdiction to consider the exemption claim as a matter of

Page 3

MTT

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

PROPERTY TAX APPEAL PETITION FORM

VALUATION / EXEMPTION / CLASSIFICATION APPEAL

MOAHR DOCKET NO. 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or Non-Property tax 

disputes.

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review 

Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Section 1: Petitioner’s Contact Information

Filer Type: Organization 

First Name

M.I.

Last Name/Company Name

Renosol Corp

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

14 Consumers Energy Pkwy

City or Town

Clare

State

Michigan

ZIP Code

48617

Telephone Number

9898940300

Fax Number

E-mail Address

loree.voorhees@renosol.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

Tina

M.I.

Last Name

Fisher

Firm Name (if any)

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

3110 Fashion Square Blvd

City or Town

Saginaw

State

Michigan

ZIP Code

48603

Telephone Number

989-790-3080

Fax Number

E-mail Address 

tinfis@rbf-cpa.com

Section 3: Subject Property Information

How many parcels are you appealing?

1

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.

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

14 Consumers Energy Parkway

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Clare

Michigan

48617

Taxing Authority (City or Township)

City Of Clare (CLARE)

County 

Clare

Section 4: Issues Being Appealed (check all that apply)

Eligible Manufacturing Personal Property (ESA)

 

Section 5: Explain the Reason for this Appeal

The taxpayer relocated to City of Clare in 2024. So had two locations to file personal property taxes for. Filed Form 5278 on February 13 for both parcels. At the 

time of filing, there was no parcel number assigned to Clare property, so only included real property parcel number 051-023-400-23. Tax calculated on this parcel 

was $8,188. Bay City parcel calculated tax of $4,233. As you can see on their account, $4,233 was paid 7/25/25 and $8,188 paid on 8/8/25, both paid in a timely 

manner. After the Dept of Treasury rejected the Clare parcel on the ESA annual return, we contacted the assessor and she provided the parcel number 051-990-226-

01. Filed the annual return again to add the parcel, and it rejected again. So we are appealing parcel 051-990-226-01 to qualify for the eligible manufacturing 

personal property tax exemption. 

Section 6: Jurisdictional Issues

Year(s) you are appealing:

2025

Did you protest the assessment at a Board of Review (BOR)? No

If Yes, check which BOR you attended AND upload the BOR decision: 

If No, check the applicable reason(s):

Not required to attend, Assessment Change Notice was not sent to Petitioner

Did you request a Poverty Exemption at the BOR? 

If Yes, check which BOR considered your application AND upload the BOR decision: 

 March  July  December

If No, explain why:

Section 7: Valuation Information *Use the multiple parcel form for additional, contiguous parcels.

Parcel Identification Number: 

Classification of Property:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Current Assessed Value (also known as State Equalized Value) as established by the BOR:

Current Taxable Value as established by the BOR:

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

 

Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

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

Section 8: Classification Information *Only the MI Dep’t of Treasury may appeal this issue to the Tribunal*

Parcel Identification Number:

 

Current Classification of Property as established by Board of Review:

What do you believe is the property’s classification?

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

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

Fee Information

Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition?

No

Are you appealing ONLY the denial of a Poverty Exemption?

Yes

If you answered yes to either or both of these questions, you are not required to pay any filing fees.

The filing fee is based on the greater of the 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, not to exceed a total filing fee of $1,000.

If your property is residential property (see MCL 205.762) and

the State Equalized Value or Taxable Value in contention is: Filing Fee is:

$100,000.00 and under $125.00

$100,000.01 to $500,000.00 $200.00

$Over $500,000.00 $300.00

If your property is NOT residential property (see MCL 205.762) and

the State Equalized Value or Taxable Value in contention is: Filing Fee is:

$100,000.00 and under $250.00

* Plus $25.00 for each additional parcel, as indicated above.

If your property is NOT residential property and the State Equalized Value or Taxable Value in contention is $100,000.01 or greater the appeal does not qualify for 

Small Claims. Therefore, an Entire Tribunal petition must be filed.

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Renosol Corp,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003291

City Of Clare,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: October 29, 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

Page 2

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

Renosol Corp,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003291

City Of Clare,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: October 29, 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

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

Michigan Department of Treasury - Essential Services Assessment (ESA) 

5349 (10-15), page 1 

ESA — Summary of Changes 

Issued under authority of Public Act 92 of 2014, as amended 

Michigan Department of Treasury 

Essential Services Assessment (ESA) 

P.O. Box 30710 

Lansing, MI 48909 

517-241-0310 

RENOSOL CORP 

www.michigan.gov/esa 

14 CONSUMERS ENERGY PKWY 

CLARE, MI 48617-9540 

Notice Date: 

September 2, 2025 

Tax Year: 

025 

Changes were made to the Essential Services Assessment (ESA) return for the taxpayer listed at the top of this 

correspondence. The 'Description' column below details the item(s) changed on the taxpayer's ESA return. These 

changes are reflected in the 'As Corrected’ column in the list below. 

Description 

As Filed 

As Corrected 

Explanation 

iabili 

Recalculation due to adjustment(s) 

26a. Total Tax Liability 

$12,421.00 

$4,233.00 

on return. 

Parcel ID :051-990-226-01 

Site Address :14 Consumers Energy Parkwa 

County 

: CLARE 

Local Unit 

: CITY OF CLARE 

Parcel ID 

Description 

As Filed 

As Corrected 

Explanation 

Department has rejected the 

051-990-226-01 

5. Parcel Number 

051-990-226-01 

051-990-226-01 

addition of this parcel as filed by 

Taxpayer. 

If you have any questions, please contact the Michigan Department of Treasury (Department) using the information at the 

top of this correspondence. 

If an outstanding tax liability is due, the taxpayer must pay the liability, plus any applicable 

late payment penalty, by April 15 of the year immediately following the assessment year in order to avoid rescission of 

any Eligible Manufacturing Personal Property (EMPP) exemption(s) by the Department. Additional information regarding 

ESA is available at www.michigan.gov/ESA. 

For Office Use Only 

BP Number: 170837 

[Wa

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

PROPERTY TAX APPEAL PETITION FORM

VALUATION / EXEMPTION / CLASSIFICATION APPEAL

MOAHR DOCKET NO. 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or Non-Property tax 

disputes.

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. Board of Review 

Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Section 1: Petitioner’s Contact Information

Filer Type: Organization 

First Name

M.I.

Last Name/Company Name

Renosol Corp

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

14 Consumers Energy Pkwy

City or Town

Clare

State

Michigan

ZIP Code

48617

Telephone Number

9898940300

Fax Number

E-mail Address

loree.voorhees@renosol.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

Tina

M.I.

Last Name

Fisher

Firm Name (if any)

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

3110 Fashion Square Blvd

City or Town

Saginaw

State

Michigan

ZIP Code

48603

Telephone Number

989-790-3080

Fax Number

E-mail Address 

tinfis@rbf-cpa.com

Section 3: Subject Property Information

How many parcels are you appealing?

1

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.

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

14 Consumers Energy Parkway

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Clare

Michigan

48617

Taxing Authority (City or Township)

City Of Clare (CLARE)

County 

Clare

Section 4: Issues Being Appealed (check all that apply)

Eligible Manufacturing Personal Property (ESA)

 

Section 5: Explain the Reason for this Appeal

The taxpayer relocated to City of Clare in 2024. So had two locations to file personal property taxes for. Filed Form 5278 on February 13 for both parcels. At the 

time of filing, there was no parcel number assigned to Clare property, so only included real property parcel number 051-023-400-23. Tax calculated on this parcel 

was $8,188. Bay City parcel calculated tax of $4,233. As you can see on their account, $4,233 was paid 7/25/25 and $8,188 paid on 8/8/25, both paid in a timely 

manner. After the Dept of Treasury rejected the Clare parcel on the ESA annual return, we contacted the assessor and she provided the parcel number 051-990-226-

01. Filed the annual return again to add the parcel, and it rejected again. So we are appealing parcel 051-990-226-01 to qualify for the eligible manufacturing 

personal property tax exemption. 

Section 6: Jurisdictional Issues

Year(s) you are appealing:

2025

Did you protest the assessment at a Board of Review (BOR)? No

If Yes, check which BOR you attended AND upload the BOR decision: 

If No, check the applicable reason(s):

Not required to attend, Assessment Change Notice was not sent to Petitioner

Did you request a Poverty Exemption at the BOR? 

If Yes, check which BOR considered your application AND upload the BOR decision: 

 March  July  December

If No, explain why:

Section 7: Valuation Information *Use the multiple parcel form for additional, contiguous parcels.

Parcel Identification Number: 

Classification of Property:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Current Assessed Value (also known as State Equalized Value) as established by the BOR:

Current Taxable Value as established by the BOR:

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

 

Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

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

Section 8: Classification Information *Only the MI Dep’t of Treasury may appeal this issue to the Tribunal*

Parcel Identification Number:

 

Current Classification of Property as established by Board of Review:

What do you believe is the property’s classification?

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

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

Fee Information

Does the subject property have a Principal Residence Exemption of at least 50% as of the date of the filing of this petition?

No

Are you appealing ONLY the denial of a Poverty Exemption?

Yes

If you answered yes to either or both of these questions, you are not required to pay any filing fees.

The filing fee is based on the greater of the 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, not to exceed a total filing fee of $1,000.

If your property is residential property (see MCL 205.762) and

the State Equalized Value or Taxable Value in contention is: Filing Fee is:

$100,000.00 and under $125.00

$100,000.01 to $500,000.00 $200.00

$Over $500,000.00 $300.00

If your property is NOT residential property (see MCL 205.762) and

the State Equalized Value or Taxable Value in contention is: Filing Fee is:

$100,000.00 and under $250.00

* Plus $25.00 for each additional parcel, as indicated above.

If your property is NOT residential property and the State Equalized Value or Taxable Value in contention is $100,000.01 or greater the appeal does not qualify for 

Small Claims. Therefore, an Entire Tribunal petition must be filed.

Page 4

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY

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.