Zaremba Holdings LLC, Petitioner V Township Of Gerrish, Respondent

Page 1

8 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

GOVERNOR 

LANSING 

RECEIVED 

OCT 272025 

MICHIGAN TAX TRIBUNAL 

MARLON |. BROWN, DPA 

DIRECTOR 

PROPERTY TAX APPEAL ANSWER FORM 

MTT DOCKET NO. 25-003164 

VALUATION / EXEMPTION / CLASSIFICATION APPEAL 

Section 1: Respondent’s Contact Information 

First Name 

Ml. 

Last Name 

Township of Gerrish 

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

2997 E Higgins Lake Dr 

City or Town 

State 

ZIP Code 

Roscommon 

Ml 

148653 

Telephone ""(989)82 1 -9694 

Email Address {do not enter unless you want MTT to send all correspondence via email) 

Assessor@gerrishtownship.org 

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

First Name 

ML. 

Last Name 

Julie 

A 

Tatro 

Firm Name (if any) 

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

2997 E Higgins Lake Dr 

City or Town 

State 

ZIP Code 

Roscommon 

MI 

148653 

Tefephons Number (989)82 1-9313 

Email Address (do not enter untess you want MTT to send all correspondence via email) 

assessor@lyontownship.org 

Section 3: Subject Property Information 

Does the subject property have a Principal Residence Exemption of 50% or more? 

M Yes 

No 

Are the parcels listed by Petitioner contiguous or adjoining? 

If not, list which parcels adjoin one another. 

0 Yes 

[] No 

O Not Applicable

Page 2

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Section 4: Explain Your Answer to this Appeal 

1)The petitioner failed to file an appeal of the 2024 uncapping of taxable value with the 

March 2024 board of review. The petitioner failed to file an appeal with the March 2025 

board of review. The July 2025 board of review lacks authority to act on the uncapping 

of a previous year taxable value, unless confirmed by the assessor. The tribunal lacks 

jurisdiction to hear this matter and 

| respectfully request dismissal. 

2)This property is residential. 

It contains one single family dwelling. This property is not 

zoned nor classified as commercial. 

It does not have a commercial use or purpose. 

Renting of a residential dwelling from an LLC to an individual does not constitute a 

commercial purpose or use of the property. 

Section 5: Jurisdictional Issues 

IF PETITIONER {S APPEALING THE TRUE CASH AND/OR TAXABLE VALUES 

Did Petitioner protest the assessment at a Board of Review (BOR)? 

Yes 

[Ml] No 

# yes, check which BOR Petitioner attended: [] March 

July 

J December 

if no, was the Notice of Assessment properly sent to Petitioner prior to the March BOR? [I] Yes 

[ No 

*Submit a copy of the Notice of Assessment with the Answer. 

if the July or December BOR revised the assessment(s} at issue, did it have authority? [Hl] Yes 

[ml] No 

If yes, cite the Board's authority. 

Was lhe assessment(s} at issue established as the result of a clerical error or mutual mistake of fact? [Hl] Yes 

[2] No 

If yes, explain 

Is Petitioner appealing from a State Tax Commission Order? 

(} Yes 

[| No 

If so, what is the Issue date? 

IF PETITIONER IS APPEALING THE UNCAPPING OF TAXABLE VALUE

Page 3

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Did Petitioner request a Poverty Exemption ata BOR? [| Yes 

[No 

If Yes, check which BOR Petitioner attended: O March 

[Hl] July 

O December 

List the date the BOR denied Petitioner's Poverty Exemption: 

IF PETITIONER IS APPEALING THE DENIAL OF AN EXEMPTION 

OTHER THAN POVERTY, PRINCIPAL RESIDENCE, OR QUALIFIED AGRICULTURAL EXEMPTIONS 

Did Petitioner request the exemption ata BOR? OJ Yes 

O No 

If Yes, check which BOR Petitioner attended: (m} March 

[| July 

O December 

Tax Year(s) denied: 

List the date the exemption was denied: 

What statutory section did Petitioner request the subject property be exempt? 

IF PETITIONER IS APPEALING THE CLASSIFICATION OF PROPERTY 

What do you believe the classification should be: 

Real 

Personal 

(check one) 

O 

Agricultural 

Commercial 

Industrial 

Residential 

Timber-Cutover 

Developmental 

Utility 

(check one) 

Section 6: Valuation Information use the multiple parcel form for additional, contiguous parcels. 

Parcel Identification Number: 

72-004-480-025-0000 

Classification of Property: 

Real 

Personal 

(check one) 

Agricultural 

Commercial 

Industrial 

Residential 

Timber-Cutover 

Developmental 

Utility 

(check one) 

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

774,100 

Current Taxable Value as established by the BOR: 

709,431 

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

1,548,200 

Multiply the True Cash Value by .5 and enter here. This is your contention of Assessed Value. 

774,100 

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

2025 taxable value equals the 2025 capped value

Page 4

pgp 

of Treas: 

THIS 

IS NOT A TAX BILL 

L-4400 

Notice of Assessment, Taxable Valuation, and Property Classification 

This form is issued under the authority of P.A. 206 of 1893, Sec. 211.24 (c) and Sec.211.34¢, as amended. This is a model assessment notice to be used by the local assessor. 

FROM 

PARCEL IDENTIFICATION 

GERRISH TOWNSHIP 

2997 E HIGGINS LAKE DR 

PARCEL NUMBER: 

004-480-025-0000 

ROSCOMMON, Mi 48653-7718 

PROPERTY ADDRESS: 

139 PINE BLUFFS ROAD 

ROSCOMMON, M1 48653 

OWNER'S NAME & ADDRESS/PERSON NAMED ON ASSESSMENT ROLL: 

PRINCIPAL RESIDENCE EXEMPTION 

% Exempt 

As "Homeowners Principal Reside 

00% 

"wy 

0, 

ZAREMBA HOLDINGS LLC 

% Exempt 

As "Qualified Agricultural Property 

00% 

20055 WESTVIEW DR 

% Exempt 

As 

"MBT Industral Personal”: 

00% 

NORTHVILLE, MI 48167-9206 

% Exempt 

As "MBT Commercial Personal™: 

00% 

Exempt 

As "Qualified Forest Property” 

[] Yes 

No 

Exempt 

As "Development Property 

~~ [_] Yes 

No 

LEGAL DESCRIPTION: 

L-713 P-190 243 LOTS 25 & 26 PINE BLUFFS 

ACCORDING TO MCL 211.34c

Page 5

Mich

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

Zaremba Holdings LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003164

Township Of Gerrish,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Users who file documents with the Michigan Tax Tribunal are advised that filed 

documents are public records and will appear for public viewing on the Tax 

Docket Lookup. Users who file documents are responsible for ensuring sensitive or 

personal identifying information is withheld or redacted. See TTR 209. If a user wishes 

to file a document for consideration by the Michigan Tax 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.

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

Page 2

MTT Docket No. 25-003164

Page 2 of 6

submitting a Request for Redactions. The Request for Redactions form will be 

available on the Entire Tribunal and Small Claims pages of our website. 

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this 

case through an informal settlement conference. An informal settlement conference 

is a meeting between the parties and/or their representatives to discuss the issues in a 

case in an effort to settle the case. This process may be an alternative to a hearing with 

a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

NOTE: The parties may not request an informal settlement conference to discuss an 

appeal of a principal residence exemption that was denied by either the Michigan 

Department of Treasury or a County. Also, state taxes levied by the Michigan 

Department of Treasury, such as income taxes, are not subject to the informal 

settlement conference process.

MEDIATION: Parties have the option of handling this case through mediation. 

Mediation is a voluntary process where a mediator facilitates communication between 

the parties, assists in identifying issues, and helps explore solutions to promote a 

mutually acceptable settlement. This process may be an alternative to a hearing with a 

judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

If you have any questions, please contact the Tribunal by phone at (517) 335-9760 or 

email taxtrib@michigan.gov.

By: Tribunal Clerk

Entered: December 8, 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 3

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

Zaremba Holdings LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003164

Township Of Gerrish,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your

Page 4

MTT

Page 5

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

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

Zaremba Holdings, LLC

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

20055 Westview Dr.

City or Town

Northville

State

Michigan

ZIP Code

48167

Telephone Number

989-799-5000

Fax Number

E-mail Address

abalzer@shinnerscook.com

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

First Name

Andrew

M.I.

Last Name

Balzer

Firm Name (if any)

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

5195 Hampton Place

City or Town

Saginaw

State

Michigan

ZIP Code

48604

Telephone Number

989-799-5000

Fax Number

E-mail Address 

abalzer@shinnerscook.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]

139 Pine Bluffs Road

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Roscommon

Michigan

48653

Taxing Authority (City or Township)

Township Of Gerrish (ROSCOMMON)

County 

Roscommon

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

Uncapping of Taxable Value

 

Section 5: Explain the Reason for this Appeal

The subject property was conveyed from the Kathleen M. Bruce Qualified Principal Residence Trust u/a/d November 25, 2008 to Stephanie M. Zaremba on 

November 14, 2023. Respondent Township agrees this conveyance was exempt from uncapping pursuant. Stephanie M. Zaremba then conveyed the subject 

property to Petitioner (Zaremba Holdings, LLC). Respondent Township denies that this second conveyance is exempt from uncapping pursuant to MCL 

211.27a(7)(m), because "the exemption for commonly controlled entities only applies if a business purpose exists." Here, a business purpose does exist because 

Zaremba Holdings, LLC leases the subject property to Kathleen Bruce for $8,000 per month. Therefore, a business purpose exists, and the second conveyance 

should also be exempt from uncapping pursuant to MCL 211.27a(7)(m).

Section 6: Jurisdictional Issues

Year(s) you are appealing:

2024 and 2025

Did you protest the assessment at a Board of Review (BOR)? Yes

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

If No, check the applicable reason(s):

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: 004-480-025-0000

Classification of Property:

Real

Residential

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:

774100

Current Taxable Value as established by the BOR:

709431

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

1548200 

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

774100

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

414070

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?

No

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 AFFAIRS

LANSING

ORLENE

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

Zaremba Holdings LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003164

Township Of Gerrish,

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 14, 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

Zaremba Holdings LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003164

Township Of Gerrish,

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 14, 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 3

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

Zaremba Holdings LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003164

Township Of Gerrish,

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 14, 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

Founded 

. 

. 

= 

Gerrish Township 

2997 E. Higgins Lake Drive 

Roscommon, MI 48653 

Phone: (989) 821-9313 

1880 

Fax: (989) 821-8627 

Shinners & Cook 

Andrew J. Balzer 

5195 Hampton Place 

Saginaw, MI 48604-9576 

July 22, 2025 

RE: Request to recap taxable value 

Dear Mr. Balzer: 

The Gerrish Township Board of Review has denied your request to recap the 2024 taxable value and 

recalculate the 2025 taxable value based on the recapping. 

The transfer from the Kathleen M. Bruce Qualified Principal Residence Trust u/a/d November 25, 2008, to 

Stephanie M. Zaremba was an exempt transfer. 

The transfer from Stephanie M. Zaremba to Zaremba Holdings, LLC; however, was not an exempt transfer. The 

exemption for commonly controlled entities only applies if a business purpose exists. We have enclosed pages 

33 & 34 of the Transfer of Ownership Guidelines for your review. 

If you disagree with this determination, you may appeal to the Michigan Tax Tribunal within 35 days of the 

date of this notice. 

Respectfully, 

Crest & 

mm Qeosonnlit, 

Gerrish Township Board of Review

Page 2

4. A secondary public offering of the stock of a company (a secondary public 

offering occurs when 

a company whose stock 

is already publicly traded issues 

additional new stock for sale to the public) 

5. The trading 

of the stock of a privately held company (a privately held company 

is 

a company whose stock is not available for sale to the public) 

6. A takeover involving a public offer by someone to buy stock from present 

stockholders in 

order to gain control of 

a company 

c 

ve 

lled Entiti 

If entities are commonly controlled, is a transfer of property (or ownership interests) 

among the entities a transfer of ownership? 

No. See MCL 211.27a(7)(m). 

With regard to entities under common control, what is meant by “entities”? 

“Entities” in this context means corporations, partnerships, limited liability companies, 

limited liability partnerships, or any other legal entity. 

When are entities considered to be commonly controlled? 

The State Tax Commission has directed that Michigan Revenue Administrative Bulletin 

1989-48 is to be used in determining whether entities are commonly controlled. This 

bulletin is available on the Internet at www.michigan.govi/treasury. This bulletin details 

three categories of common 

control: 

1. 

A parent-subsidiary group of trades or businesses 

2. 

A brother-sister group of trades or businesses 

3. 

A combined group of trades or businesses (a specific combination of a parent- 

subsidiary group and a brother-sister group of trades or businesses) 

For entities to be commonly controlled under Michigan Revenue Administrative Bulletin 

1989-48, the entities must be engaged 

in 

a business or trades activity. See 

C & J 

Investments of Grayling, LLC v City of Grayling, unpublished opinion per curiam of the 

Court of Appeals, issued November 13, 2007 (Docket No. 270989). The term “common” is 

defined as “belonging equally to, or shared alike by, two or more or all 

in question.” 

Entities which are not engaged 

in 

a business activity cannot be entities under common 

control under Michigan Revenue Administrative Bulletin 1989-48. 

Example: A husband and wife own their personal residence together as tenants by the 

entireties. 

For estate planning and other purposes, they convey the property to a limited 

liability company 

of which the wife 

is the only member. The entities involved (the 

husband and wife and the 

limited liability company) cannot be considered entities under 

common control under Michigan 

Revenue Administrative Bulletin 1989-48 since no 

business activity exists in this situation. 

Note: Michigan Revenue Administrative Bulletin 1989-48 refers to Internal Revenue 

Service 

regulations concerning constructive ownership (also commonly known as 

ownership attribution). 

It is the opinion of the State Tax Commission that, although 

Michigan Revenue Administrative Bulletin 1989-48 is to be used in determining entities 

under common control, the Internal Revenue Service regulations concerning 

constructive ownership are 

to be disregarded. 

Application of the regulations regarding 

33

Page 3

constructive ownership (ownership attribution) would 

result in transfer of ownership 

exemptions that were clearly not intended by the legislature. 

Is it possible for entities not to qualify as entities under common control under 

Michigan Revenue Administrative Bulletin 1989-48 but still be considered entities 

under common 

control? 

Yes. 

If there is a business purpose, there are two circumstances that constitute 

a common 

control situation—even though the entities involved may not qualify as entities under 

common control 

under Michigan Revenue Administrative Bulletin 1989-48: 

1. 

Initial transfers by individuals of a fee simple interest in a property, made to an 

entity such as a corporation, a limited liability company or a partnership, are 

considered to be 

transfers between commonly controlled entities and not 

transfers of ownership, 

if the 

ownership interests and extent of control which 

the individuals have 

in the entity are identical to the ownership interest and extent 

of control which each of the individuals had 

in the property prior to the initial 

transfer. Transfers to limited partnerships would not qualify for the reason that 

such transfers involve a change in control. 

2. 

Transfers where lhe lee simple interest In a property is conveyed 

(retransferred) from 

an initial transferee entity, as described 

in 

1 above, to the 

individuals who made the 

initial transfer to that entity, 

if the ownership 

interests and extent of control which those individuals have in the entity at 

the time of the retransfer are identical to the ownership interests and extent 

of control which each of the individuals had 

in the property prior to the initial 

transfer and those interests have not changed the between 

the time of the 

initial transfer and the time of the retransfer. 

In

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

Zaremba Holdings, LLC

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

20055 Westview Dr.

City or Town

Northville

State

Michigan

ZIP Code

48167

Telephone Number

989-799-5000

Fax Number

E-mail Address

abalzer@shinnerscook.com

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

First Name

Andrew

M.I.

Last Name

Balzer

Firm Name (if any)

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

5195 Hampton Place

City or Town

Saginaw

State

Michigan

ZIP Code

48604

Telephone Number

989-799-5000

Fax Number

E-mail Address 

abalzer@shinnerscook.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]

139 Pine Bluffs Road

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Roscommon

Michigan

48653

Taxing Authority (City or Township)

Township Of Gerrish (ROSCOMMON)

County 

Roscommon

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

Uncapping of Taxable Value

 

Section 5: Explain the Reason for this Appeal

The subject property was conveyed from the Kathleen M. Bruce Qualified Principal Residence Trust u/a/d November 25, 2008 to Stephanie M. Zaremba on 

November 14, 2023. Respondent Township agrees this conveyance was exempt from uncapping pursuant. Stephanie M. Zaremba then conveyed the subject 

property to Petitioner (Zaremba Holdings, LLC). Respondent Township denies that this second conveyance is exempt from uncapping pursuant to MCL 

211.27a(7)(m), because "the exemption for commonly controlled entities only applies if a business purpose exists." Here, a business purpose does exist because 

Zaremba Holdings, LLC leases the subject property to Kathleen Bruce for $8,000 per month. Therefore, a business purpose exists, and the second conveyance 

should also be exempt from uncapping pursuant to MCL 211.27a(7)(m).

Section 6: Jurisdictional Issues

Year(s) you are appealing:

2024 and 2025

Did you protest the assessment at a Board of Review (BOR)? Yes

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

If No, check the applicable reason(s):

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: 004-480-025-0000

Classification of Property:

Real

Residential

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:

774100

Current Taxable Value as established by the BOR:

709431

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

1548200 

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

774100

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

414070

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?

No

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 AFFAIRS

LANSING

ORLENE

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.