Petitioners Statement of Sanctionable Conduct.pages.pdf

Mindaugas Zukauskas Petitioner V Township Of Evangeline Respondent · 26-000660-TT

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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL

Mindaugas Zukauskas, Petitioner,

v.

EVANGELINE TOWNSHIP, Respondent.

Property PIN: 15-005-022-013-90

Prior Related Docket: 24-002632-TT

PETITIONER’S STATEMENT OF SANCTIONABLE CONDUCT

Petitioner respectfully moves this Honorable Tribunal to award Full Costs, Fees, and Sanctions 

against Respondent, Evangeline Township, pursuant to TTR 209 and MCL 600.2591. 

Respondent’s conduct in this matter is exceptionally egregious, characterized by a repetitive and 

intentional refusal to follow the law despite a prior Tribunal settlement on these exact issues.

I. REPETITIVE LITIGATION AND BREACH OF GOOD FAITH

Respondent is well aware of the legal status of the Subject Property. In MTT Docket 24-002632-

TT, Respondent conceded the illegal uncapping of the property only after Petitioner incurred the 

expense of filing a Tribunal appeal. Despite this prior stipulation, Respondent has willfully 

returned to its previous illegal stance, refusing to apply the "Before-and-After" valuation 

methodology for the current tax year. This "rinse and repeat" strategy of denying valid claims at 

the Board of Review to force taxpayers into the Tribunal is a textbook example of Bad Faith 

Litigation.

II. WILLFUL VIOLATION OF P.A. 446 AND STC BULLETIN 2006-03

Respondent continues to ignore Michigan Public Act 446 of 2006 and STC Bulletin 2006-03.

1.

Selective Enforcement: Respondent corrected the "pop-up" tax for Petitioner only under 

the pressure of a Tribunal docket, yet refuses to apply the same law to at least other eight 

other similarly situated parcels in the Township.

2.

Refusal to Value Restrictions: Respondent’s Assessor explicitly stated Petitioner must 

"go to the Tribunal" to get a nominal valuation for the 2 restricted acres. This is a direct 

refusal to perform a statutory duty under MCL 211.27, as the Assessor already possesses 

the evidence that the land is unbuildable.

III. REQUEST FOR COMPREHENSIVE COSTS AND SANCTIONS

Respondent’s defense is "frivolous" under MCL 600.2591(3) because Respondent has no 

reasonable basis to believe its facts or legal positions are true, given the prior settlement. 

Petitioner respectfully requests:

1.

Reimbursement for all costs and fees associated with the current appeal.

2.

Sanctions for the repetitive nature of this dispute, as Respondent is knowingly forcing 

Petitioner to spend money on experts and filing fees to correct an error Respondent has 

already admitted to in a prior docket.

3.

An Order directing Respondent to finally and permanently record the nominal valuation 

of the restricted acreage to prevent a fourth unnecessary appeal.

Respectfully submitted,

Mindaugas Zukauskas Dated: 4/17/2026

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