Walnut Hills Family Campground, Petitioner Vs. Township Of Burns, 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 FEBRUARY 16 - 26, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Walnut Hills Family Campground,

Petitioner,

v

 

 

Township Of Burns,

Respondent.

 MTT Docket No. 25-003744

Please be advised that 25-003744 has been placed on a two-week Prehearing General 

Call commencing February 16, 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covered by the order will not be published.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. 25-003744

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 October 20, 2026. 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 October 20, 2026. 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 

October 20, 2026, 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 

February 16, 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 limited to the opposing party’s 

valuation disclosure, the opposing party’s valuation expert, and the witnesses identified 

on the opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: March 16, 2026

Page 3

MTT Docket No. 25-003744

Page 3 of 3

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 provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 4

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 FEBRUARY 16 - 26, 2027 PREHEARING GENERAL

Page 5

MTT

Page 6

M

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

RECEIVED 

DEC 11 2075 

Norman D. Shinkle 

Attorney at Law 

MICHIGAN TAX TRIBUNAI 

2683 Donna Drive, Williamston, Michigan 

48895 

Ph. 517-655-5992 normshinkle@gmail.com 

December 8, 2025 

Samantha M, Welton, Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

Dear Ms. Welton, 

MTT Docket No. 25-003744 

Enclosed please find Respondent’s Answer for the above captioned matter. 

Attempts to file this electronically failed. 

Respectfully, Y, 

N 

[4 

Norman D. Shinkle 

Cc. Brian M. Lum, Attorney for Petitioner with the Entire Tribunal Special Assessment Answer 

Sent to Brian M Lum on December 8, 2025, by placing it in the US Mail with first class postage 

paid by Norman 

R. Shinkle. 

JZ 

Norman D. Shinkle on 12-8-25

Page 2

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Walnut Hills Family Campground & RV Park, LLC 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

Vv 

MTT Docket No.25:003744 

Township of Burns 

Respondent(s) 

ENTIRE TRIBUNAL SPECIAL ASSESSMENT ANSWER 

1. 

x__Admit ___ Deny. 

If denied, state the parcel number identified on the Entire 

Tribunal Special Assessment Tax Petition: 

2. 

X__ 

Admit 

Deny. 

If denied, list the classification of the parcel number 

identified on the Petition 

3. 

x__ Admit 

Deny. 

If denied, indicate what the special assessment was levied 

for 

4. 

Xx Admit __ Deny. 

If denied, please indicate the proper jurisdiction (if known) 

5. 

x Admit __ Deny. 

If denied, please explain: 

The action that prompted this Appeal is Respondent's decision 

6. 

Xx 

Admit __ Deny. 

If denied, please indicate the date of the hearing held to 

confirm the special assessment 

7. 

X__ 

Admit 

Deny 

Neither Admit Nor Deny. 

if denied, list the separate facts 

upon which Respondent relies in support of the denial (attach additional page if 

necessary):

Page 3

MTT Docket No. 

= 00972 

Page 2 of 3 

8. 

10. 

11. 

12. 

13. 

14. 

x__Admit __ Deny. 

If denied, please indicate the number of years covered by 

the special assessment 

x Admit ___ Deny. 

if denied, please indicate the total amount levied against the 

subject parcel 

Admit 

Deny x __ Neither Admit Nor Deny. 

If denied, list the separate facts 

upon which Respondent relies in support of the denial (attach additional page if 

necessary: 

The question is the value of 24/7 ambulance service to Petitioner's property. 

It is 

not $130.00. 

x 

Admit 

Deny 

Neither Admit Nor Deny. 

If denied, list the separate facts 

upon which Respondent relies in support of the denial (attach additional page if 

necessary): 

Admit 

Deny x 

Neither Admit Nor Deny. 

If denied, list the separate facts 

upon which Respondent relies in support of the denial (attach additional page if 

necessary): 

As stated in #10, the issue is the value of 24/7 ambulance service to Petitioner's property. Southwest 

Shiawassee Emergency Services Alliance, (SSESA) allocated its costs per unit of government. 

Respondent's special assessment covers their share of that allocated cost. Petitioner owns 240 lots 

for campers. Respondent assessed each lot at 50% of the unit price. Petitioner asserts that the 

value of ambulance service is less than 1% of the already discounted assessment. 

Admit 

Deny 

x__ 

Neither Admit Nor Deny. 

If denied, list the separate facts 

upon which Respondent relies in support of the denial (attach additional page if 

necessary): 

Respondent will show the value of the ambulatory service to its residents and Petitioner. Special 

assessments are often used for EMS services. Our task is to determine the value of this EMS 

Service to Petitioner's 240 lots licensed for camping. The attachments to Respondent's 

Prehearing Statement indicate the costs associated with SSESA providing this service.

Page 4

MTT Docket No. LS ~o6317 

Page 30of 3 

15. 

List any separate and specific facts upon which Respondent relies to support 

every ground on which Respondent relies and also has the burden of proof 

(attach additional page if necessary): 

Please see the attachments to Respondent's Prehearing Statement. 

16. 

List affirmative defenses and the separate and specific facts upon which 

Respondent relies in support of those affirmative defenses (attach additional 

age if necessary): 

Please see the attachments to Respondent's Prehearing Statement. 

Signature of 

spondeply Pup 

epresontaie or, if none, Respondent: 

7 

re 

4 

S 

Printed Name of Respondent's Authorized Representative or, if none, Respondent: 

Norman D. Shinkle 

Email Address: normshinkle@gmail.com 

Mailing Address: 

2683 Donna Drive, Williamston M| 48895 

Telephone Number: 517 655-5992 

Date: December 8, 2025

Page 5

Norman D. Shinkle 

2683 Donna Drive 

Williamston, M1 48895 

Vis 

Sg) 020 

GRAND RAPIDS MI 493 

© DEC 2025 PME L 

Samantha M. Welton, Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, Ml 48909 

Hp 

hgh 

[IRD 

pg HE 

HT

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 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Walnut Hills Family Campground & RV Park, LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

\ 

MTT Docket No. 25-003744 

Burns Township 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Alexa Passalacqua 

states that on November 25, 2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. 

Assessor (via certified mail): 

Burns Township Assessor: Diane Dowler, 11236 Reid Road, Swartz Creek, MI 48473 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

Burns Township Supervisor: Casey Glass, 10355 Bath Road, PO Box 397, Byron MI 

48418 

3. 

County Equalization Director (via first class mail or personal service): 

Shiawassee Co. Equalization Director: Mr. Peter Preston, 208 N. Shiawassee St., 

Corunna, Mi 48817 

4. 

County Clerk (via first class mail or personal service): 

Shiawassee Co. Clerk: Caroline Wilson, 208 N. Shiawassee St., Corunna, Mi 48817 

5. 

Secretary of the local school board (via first class mail or personal service): 

Byron Area School Board Secretary: Jeanette Prestonise, 312 W. Maple Ave, Byron, 

MI 48418 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan

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 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Walnut Hills Family Campground & RV Park, LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 

Burns Township 

Respondent(s) 

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

1. 

Property Parcel No: 016-08-400-008-04 

2. 

The property identified above is X real personal. 

3. 

The special assessment levied is for 

Ambulance services provided by Southwest Shiawassee Emergency Services Alliance in accordance with the 

Emergency Services Agreement dated March 2021 and First Amendment of October 2023 as extended or amended. 

4. 

The taxing authority levying the special assessment is 

Township of Burns 

5. 

The action that prompted this appeal is 

Assessing a single parcel as multiple units and excessive ambulance charges. 

6. 

The hearing held to confirm the special assessment was held on 

October 6, 2025. 

7. 

Petitioner did 

(did/did not) protest the special assessment at this hearing. 

If a 

protest was not made, list the separate and specific facts upon which Petitioner 

relies to invoke the Tribunal’s authority over the special assessment at issue 

(attach additional page if necessary): 

Petitioner protested at the October 6, 2025 meeting. 

A portion of the October board meeting 

minutes were published by the Argus Press stating "Terry Schalk, Walnut Hills Family

Page 2

MTT Docket No. 

Page 2 of 2 

9. 

The total amount levied against the subject parcel is $ 15,600.00 ($130 per “unit") 

10. 

Petitioner contends that the total amount levied should be $ The amount for a single unit $130 

11. 

The amount in dispute is $ $15,470 

12. 

Petitioner requests the following relief (attach additional page if necessary): 

13. 

See Attachment to Entire Tribunal Special Assessment Petition - Parcel No. 

016-08-400-008-02. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

See Attachment to Entire Tribunal Special Assessment Petition - Parcel No. 

016-08-400-008-02. 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

a 

( 12.194) 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Brian M. Lum, Grua, Freeman, Tupper & Young, PLC 

Email Address: blum@wedolawinlansing.com 

Mailing Address: 

Grua, Freeman, Tupper & Young, PLC 

Attn: 

Brian M. Lum 

2401 E. Grand River Ave. 

Lansing, MI 48912 

Telephone Number: (517) 487-8300 

Date: 

LL [4 [20 = 5-1

Page 3

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

Parcel No. 016-08-400-008-02 

ATTACHMENT TO ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

PROPERTY PARCEL NO. 016-08-400-008-02 

Number 12 of Petition: Petitioner requests the following relief 

REQUESTED RELIEF 

WHEREFORE, Petitioner respectfully requests the following relief: 

1. 

A fair and reasonable application of the Ambulance Assessment in relation to the benefit 

received, in this case the amount charged for the single parcel/unit Petitioner owns in Burns 

Township being $130 per year. 

That the special Ambulance Assessment be applied to Petitioner as the owner of a single 

parcel as it has historically been assessed, rather than the individual number of campsites 

which SSESA is clearly using as a money grab to try and shore up their own financial 

mismanagement. 

. 

In a letter dated September 11, 2025 from Kyle A. O’Meara, Senior Associate at Fahey 

Schultz Burzych Rhodes, to Tim DeLau, Board Chairperson of the Southwest Shiawassee 

Emergency Services Alliances (“SSESA™) he states “As you may recall, in 2023, SSESA 

asked the Township to voluntarily renegotiate its services agreement with SSESA to, 

among other things, adjust its unit charge criteria to charge campgrounds within the 

Township at half a unit per campsite. 

Prior to this service agreement adjustment, 

campgrounds would qualify as commercial property that would be charged a unit per 

five full 

(sic) full-time employees.” (Exhibit 

2) This renegotiation clearly targeted 

campgrounds to saddle them with an unsustainable share of the Ambulance Assessment, 

without providing any additional benefit to the Parcel or Petitioner. The Petitioner has not 

had an ambulance called to its campground in the last two (2) years, however SSESA 

through its renegotiated contract with the Township (not with the Petitioner), as long as 

they are allowed 

to 

get away with 

this, would increase the Petitioner’s Ambulance

Page 4

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

Parcel No. 016-08-400-008-02 

Agreement between Burns Township and SSESA dated March 

1, 2021 

(Exhibit 

3), 

referring to a commercial property with fewer than 5 full-time employees. This adjustment 

would result in the petitioner's special assessment being $130.00, rather than $15,600.00 

(approximately 7% of the entire township’s special Ambulance Assessment for a single 

parcel of property). 

5. 

SSESA previously 

sent 

a Seasonal Campground Memo 

to 

Burns Township 

dated 

September 5, 2024 (“Seasonal Campground Memo”)(Exhibit 4). 

Page 2, paragraph 3 of 

the 

Seasonal Campground Memo 

states “When adopting 

a 

Special Assessment 

a 

municipality must balance the benefit and the burden so that a property remains in balance 

and not unfairly assessed compared to the benefit it receives.” 

In this case, there is no balance between the benefit and the burden and the Petitioner is 

clearly being unfairly assessed compared 

to 

the benefit received. 

The Petitioner’s 

Ambulance Assessment has increased nearly 12,000% however, the Petitioner and its 

parcel have received no benefit 

at 

all. 

There have been no ambulance runs to the 

Petitioner’s campground for the past two years and in prior years there have only been 

minimal ambulance runs to the campground. This is clearly an unfair assessment against 

the Petitioner’s parcel compared to the benefit received which is nothing. Petitioner should 

not be charged 12,000% higher

Page 5

ENTI

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

Walnut Hills Family Campground, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-003744

Township Of Burns, 

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: November 7, 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

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Walnut Hills Family Campground & RV Park, LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 

Burns Township 

Respondent(s) 

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

1. 

Property Parcel No: 016-08-400-008-04 

2. 

The property identified above is X real personal. 

3. 

The special assessment levied is for 

Ambulance services provided by Southwest Shiawassee Emergency Services Alliance in accordance with the 

Emergency Services Agreement dated March 2021 and First Amendment of October 2023 as extended or amended. 

4. 

The taxing authority levying the special assessment is 

Township of Burns 

5. 

The action that prompted this appeal is 

Assessing a single parcel as multiple units and excessive ambulance charges. 

6. 

The hearing held to confirm the special assessment was held on 

October 6, 2025. 

7. 

Petitioner did 

(did/did not) protest the special assessment at this hearing. 

If a 

protest was not made, list the separate and specific facts upon which Petitioner 

relies to invoke the Tribunal’s authority over the special assessment at issue 

(attach additional page if necessary): 

Petitioner protested at the October 6, 2025 meeting. 

A portion of the October board meeting 

minutes were published by the Argus Press stating "Terry Schalk, Walnut Hills Family

Page 2

MTT Docket No. 

Page 2 of 2 

9. 

The total amount levied against the subject parcel is $ 15,600.00 ($130 per “unit") 

10. 

Petitioner contends that the total amount levied should be $ The amount for a single unit $130 

11. 

The amount in dispute is $ $15,470 

12. 

Petitioner requests the following relief (attach additional page if necessary): 

13. 

See Attachment to Entire Tribunal Special Assessment Petition - Parcel No. 

016-08-400-008-02. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

See Attachment to Entire Tribunal Special Assessment Petition - Parcel No. 

016-08-400-008-02. 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

a 

( 12.194) 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Brian M. Lum, Grua, Freeman, Tupper & Young, PLC 

Email Address: blum@wedolawinlansing.com 

Mailing Address: 

Grua, Freeman, Tupper & Young, PLC 

Attn: 

Brian M. Lum 

2401 E. Grand River Ave. 

Lansing, MI 48912 

Telephone Number: (517) 487-8300 

Date: 

LL [4 [20 = 5-1

Page 3

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

Parcel No. 016-08-400-008-02 

ATTACHMENT TO ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

PROPERTY PARCEL NO. 016-08-400-008-02 

Number 12 of Petition: Petitioner requests the following relief 

REQUESTED RELIEF 

WHEREFORE, Petitioner respectfully requests the following relief: 

1. 

A fair and reasonable application of the Ambulance Assessment in relation to the benefit 

received, in this case the amount charged for the single parcel/unit Petitioner owns in Burns 

Township being $130 per year. 

That the special Ambulance Assessment be applied to Petitioner as the owner of a single 

parcel as it has historically been assessed, rather than the individual number of campsites 

which SSESA is clearly using as a money grab to try and shore up their own financial 

mismanagement. 

. 

In a letter dated September 11, 2025 from Kyle A. O’Meara, Senior Associate at Fahey 

Schultz Burzych Rhodes, to Tim DeLau, Board Chairperson of the Southwest Shiawassee 

Emergency Services Alliances (“SSESA™) he states “As you may recall, in 2023, SSESA 

asked the Township to voluntarily renegotiate its services agreement with SSESA to, 

among other things, adjust its unit charge criteria to charge campgrounds within the 

Township at half a unit per campsite. 

Prior to this service agreement adjustment, 

campgrounds would qualify as commercial property that would be charged a unit per 

five full 

(sic) full-time employees.” (Exhibit 

2) This renegotiation clearly targeted 

campgrounds to saddle them with an unsustainable share of the Ambulance Assessment, 

without providing any additional benefit to the Parcel or Petitioner. The Petitioner has not 

had an ambulance called to its campground in the last two (2) years, however SSESA 

through its renegotiated contract with the Township (not with the Petitioner), as long as 

they are allowed 

to 

get away with 

this, would increase the Petitioner’s Ambulance

Page 4

ENTIRE TRIBUNAL SPECIAL ASSESSMENT PETITION 

Parcel No. 016-08-400-008-02 

Agreement between Burns Township and SSESA dated March 

1, 2021 

(Exhibit 

3), 

referring to a commercial property with fewer than 5 full-time employees. This adjustment 

would result in the petitioner's special assessment being $130.00, rather than $15,600.00 

(approximately 7% of the entire township’s special Ambulance Assessment for a single 

parcel of property). 

5. 

SSESA previously 

sent 

a Seasonal Campground Memo 

to 

Burns Township 

dated 

September 5, 2024 (“Seasonal Campground Memo”)(Exhibit 4). 

Page 2, paragraph 3 of 

the 

Seasonal Campground Memo 

states “When adopting 

a 

Special Assessment 

a 

municipality must balance the benefit and the burden so that a property remains in balance 

and not unfairly assessed compared to the benefit it receives.” 

In this case, there is no balance between the benefit and the burden and the Petitioner is 

clearly being unfairly assessed compared 

to 

the benefit received. 

The Petitioner’s 

Ambulance Assessment has increased nearly 12,000% however, the Petitioner and its 

parcel have received no benefit 

at 

all. 

There have been no ambulance runs to the 

Petitioner’s campground for the past two years and in prior years there have only been 

minimal ambulance runs to the campground. This is clearly an unfair assessment against 

the Petitioner’s parcel compared to the benefit received which is nothing. Petitioner should 

not be charged 12,000% higher

Page 5

ENTI

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: Individual

First Name/Company Name

Walnut Hills Family Campground & RV Park, LLC

M.I.

Last Name

N/A

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

1883 W. Royal Hunte Drive

Suite #200A

City or Town

Cedar City

State

Utah

ZIP Code

84720

Telephone Number

9897154295

Fax Number

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

matt@gathergroundsresorts.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

M.

Last Name

Lum

Firm Name (if any)

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

2401 E. Grand River Ave.

City or Town

Lansing

State

Michigan

ZIP Code

48912

Telephone Number

517-487-8300

Fax Number

517-487-8306

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

blum@wedolawinlansing.com

Section 5: Issue

Please designate one: 

Special Assessment – Fill out Sections 4, & 8 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]

7685 E. Lehring Rd.

Durand

Michigan

48429

Taxing Authority (City or Township)

Township Of Burns (SHIAWASSEE)

County

Shiawassee

If you are appealing more than one parcel, are they contiguous or adjoining? No

(*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)

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

Classification of Property: 

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

Current Taxable Value as established by the Board of Review:

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

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

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:

Ambulance Assessement

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

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

October 6, 2025

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/ Brian M. Lum

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.