Tsfr Apple Venture, LLC Petitioner Vs. City Of Sturgis 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

NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

TSFR Apple Venture, LLC,

Petitioner,

v

 

 

City Of Sturgis,

Respondent.

 MTT Docket No. 26-000746

Please be advised that 26-000746 has been placed on a two-week Prehearing General 

Call commencing August 02, 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covered by the order will not be published.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. 26-000746

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 April 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 April 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 

April 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 

August 2, 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” discovery is

Page 3

MT

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TSFR APPLE VENTURE, LLC, 

Petitioner, 

MOAHR Docket No. 26-000746-TT 

\% 

CITY OF STURGIS, 

Respondent. 

Jerome P. Pesick (P29039) 

Robert E. Thall (P46421) 

Jason C. Long (P59244) 

Bauckham, Thall, Seeber, 

Williams, Williams, Rattner 

Kaufman & Koches, P.C. 

& Plunkett, PC 

Attorney for Respondent 

Attorneys for Petitioner 

470 W. Centre Ave., Suite A 

380 N. Old Woodward Ave., Ste. 300 

Portage, MI 49024-5362 

Birmingham, MI 48009 

269-382-4500 

(248) 642-0333 

thall@michigantownshiplaw.com 

ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES 

Respondent, City of Sturgis, states the following in response to the respective paragraphs 

of the Petition filed in this matter: 

1. 

In answer 

to paragraph 

1 

of the Petition, Respondent admits the allegations 

therein. 

2. 

In answer to paragraph 

2 

of the Petition, Respondent admits the allegations 

therein.

Page 2

4. 

In answer to paragraph 

4 

of the Petition, Respondent admits the allegations 

therein. 

S. 

In answer 

to paragraph 

5 

of the Petition, Respondent admits the allegations 

therein. 

6. 

In answer 

to paragraph 

6 

of the Petition, Respondent admits the allegations 

therein. 

7. 

In answer to paragraph 

7 of the Petition, Respondent admits the allegations 

therein. 

8. 

In answer 

to paragraph 

8 

of the Petition, Respondent denies the Petitioner’s 

values for the property as untrue. 

9. 

In answer to paragraph 9 of the Petition, Respondent admits the allegation therein. 

10. 

In answer to paragraph 

10 of the Petition, Respondent admits the allegations 

therein. 

11. 

In answer 

to paragraph 

11 

of the Petition, Respondent denies the allegation 

therein as untrue. 

12. 

In answer to paragraph 

12 

of the Petition, Respondent denies the allegation 

therein regarding overestimating the values 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

Page 3

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. 

S. 

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. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMAN & K 

ES, P. 

J 

Date: July 20, 2026 

A 

By: 

ps 

Rébert E. Thall, Attorney for Respondent

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

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-000746

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Sturgis (SAINT JOSEPH)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Robert

M.I.

E

Last Name

Thall

Firm Name (if any)

Bauckham, Thall, et al

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

470 W Centre Ave Suite A

City or Town

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/

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TSFR APPLE VENTURE, LLC, 

Petitioner, 

MOAHR Docket No. 26-000746-TT 

\% 

CITY OF STURGIS, 

Respondent. 

Jerome P. Pesick (P29039) 

Robert E. Thall (P46421) 

Jason C. Long (P59244) 

Bauckham, Thall, Seeber, 

Williams, Williams, Rattner 

Kaufman & Koches, P.C. 

& Plunkett, PC 

Attorney for Respondent 

Attorneys for Petitioner 

470 W. Centre Ave., Suite A 

380 N. Old Woodward Ave., Ste. 300 

Portage, MI 49024-5362 

Birmingham, MI 48009 

269-382-4500 

(248) 642-0333 

thall@michigantownshiplaw.com 

PROOF OF SERVICE 

Sandra Bosse states that on July 20, 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 attorney for Petitioner at the address as shown above. 

AA 

on, 

JU LAGE 

Sandra Bosse

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

TSFR APPLE VENTURE, LLC, 

Petitioner, 

MOAHR Docket No. 26-000746-TT 

Vv 

CITY OF STURGIS, 

Respondent. 

Jerome P. Pesick (P29039) 

Robert E. Thall (P46421) 

Jason C. Long (P59244) 

Bauckham, Thall, Seeber, 

Williams, Williams, Rattner 

Kaufman & Koches, P.C. 

& Plunkett, PC 

Attorney for Respondent 

Attorneys for Petitioner 

470 W. Centre Ave., Suite A 

380 N. Old Woodward Ave., Ste. 300 

Portage, MI 49024-5362 

Birmingham, MI 48009 

269-382-4500 

(248) 642-0333 

thall@michigantownshiplaw.com 

APPEARANCE 

Attorney Robert E. Thall of the law firm Bauckham, Thall, Seeber, Kaufman & Koches, 

P.C., enters this appearance for and on behalf of Respondent, City of Sturgis, in this matter. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMAN & KOCHES, 7 

Date: July 20, 2026 

By: 

Hy Jf 4 

RobertE. Thall, Attorney for Respondent

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000746

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

Party Filing Document 

Respondent

Files

Document Type: Appearance

Attachment File Name: 26-000746 APP09927320260720130752

Document Type: Proof of Service: Misc Documents

Attachment File Name: 26-000746 POS09927420260720130834

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

TSFR Apple Venture, LLC, 

Petitioner, 

Vv. 

City of Sturgis, 

Respondent. 

Docket No. 26-000746 

Parcel No. 052-777-225-35 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas 

states 

that 

she personally served copies 

of the Entire 

Tribunal Property Tax Petition, Notice of Docket Number, and this Proof of Service, 

on the persons listed below, by placing copies of those documents in a duly stamped, 

addressed envelope and placing the envelope in the United States mail on June 18, 

2026. 

PERSONS SERVED: 

Certified Mail: 

First Class Mail: 

Clerk 

Clerk 

Secretary of School Board 

City of Sturgis 

St. Joseph County 

Sturgis Public Schools 

130 N. Nottawa St. 

Second Floor 

107 W. West St. 

Sturgis, MI 49091 

125 W. Main St. 

Sturgis, MI 49091 

P.O. Box 189 

Centreville, MI 49032 

Assessor 

Director of Equalization 

State Treasurer 

City of Sturgis 

St. Joseph County 

Michigan Dep't of Treasury 

130 N. Nottawa St. 

125 W. Main St. 

Austin Building 

Sturgis, MI 49091 

P.O. Box 189 

430 W. Allegan 

Centreville, MI 49032 

Lansing, MI 

48922 

Apr ld 

Monica Athanas

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-000746

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: TSFR Sturgis POS - Petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

TSFR Apple Venture, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 052-777-225-35 

 

v. 

 

City of Sturgis, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner TSFR Apple Venture, LLC and Modi Investments, LLC, by and 

through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows 

for its Entire Tribunal Property Tax Petition. 

The Parties 

 

1. 

Petitioner TSFR Apple Venture, LLC is a Michigan limited liability 

company with its principal place of business located in Michigan at 17800 Laurel 

Park Drive North, Suite 200c, Livonia, MI 48152.

Page 2

2. 

Respondent City of Sturgis is a Michigan city with its principal offices 

located at 130 N. Nottawa, Sturgis, Michigan 49091. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 052-777-225-35 and 

commonly known as 1310 S Centerville Road, Sturgis, Michigan 49091 (the “Subject 

Property”). 

4. 

The Subject Property is located in St. Joseph County and is within the 

Sturgis Public School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,421,800 

 710,900 

 710,900 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 900,000 

 450,000 

 450,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 521,800 

 260,900 

 260,900

Page 3

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: May 6, 2026 

 

 

Attorneys for Petitioner

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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

TSFR Apple Venture, LLC

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

17800 Laurel Park Drive North, , , MI

Suite 200c

City or Town

Livonia

State

Michigan

ZIP Code

48152

Telephone Number

248-642-0333

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

jpesick@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Williams Williams Rattner & Plunkett, PC

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

380 N Old Woodward

Ste 300

City or Town

Birmingham

State

22

ZIP Code

48009

Telephone Number

248-642-0333

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

jpesick@wwrplaw.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]

1310 S Centerville Road

Sturgis

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

49091

Taxing Authority (City or Township)

City Of Sturgis (SAINT JOSEPH) 

County

Saint Joseph

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

052-777-225-35

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:

710900

Current Taxable Value as established by the Board of Review:

710900

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

900000

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

450000

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

450000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

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/ Jerome P. Pesick

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26050684223703

Supporting Waiver Documents:

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

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

TSFR Apple Venture, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000746

City Of Sturgis, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: June 10, 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

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

TSFR Apple Venture, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 052-777-225-35 

 

v. 

 

City of Sturgis, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner TSFR Apple Venture, LLC and Modi Investments, LLC, by and 

through its attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows 

for its Entire Tribunal Property Tax Petition. 

The Parties 

 

1. 

Petitioner TSFR Apple Venture, LLC is a Michigan limited liability 

company with its principal place of business located in Michigan at 17800 Laurel 

Park Drive North, Suite 200c, Livonia, MI 48152.

Page 2

2. 

Respondent City of Sturgis is a Michigan city with its principal offices 

located at 130 N. Nottawa, Sturgis, Michigan 49091. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 052-777-225-35 and 

commonly known as 1310 S Centerville Road, Sturgis, Michigan 49091 (the “Subject 

Property”). 

4. 

The Subject Property is located in St. Joseph County and is within the 

Sturgis Public School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,421,800 

 710,900 

 710,900 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 900,000 

 450,000 

 450,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 521,800 

 260,900 

 260,900

Page 3

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: May 6, 2026 

 

 

Attorneys for Petitioner

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 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

TSFR Apple Venture, LLC

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

17800 Laurel Park Drive North, , , MI

Suite 200c

City or Town

Livonia

State

Michigan

ZIP Code

48152

Telephone Number

248-642-0333

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

jpesick@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Williams Williams Rattner & Plunkett, PC

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

380 N Old Woodward

Ste 300

City or Town

Birmingham

State

22

ZIP Code

48009

Telephone Number

248-642-0333

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

jpesick@wwrplaw.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]

1310 S Centerville Road

Sturgis

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Michigan

49091

Taxing Authority (City or Township)

City Of Sturgis (SAINT JOSEPH) 

County

Saint Joseph

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

052-777-225-35

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:

710900

Current Taxable Value as established by the Board of Review:

710900

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

900000

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

450000

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

450000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

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/ Jerome P. Pesick

Payment Information

Amount: 400

Success: True

Message: ""

Waiver Code:

Transaction Number: 26050684223703

Supporting Waiver Documents:

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