26-001296.pdf

Z On Ladd LLC Petitioner Vs. City Of Walled Lake Respondent · 26-001296-TT

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RECELVED 

SEP 0 9 2026 

MICHIGAN TAX TRIBUNAL 

OFFICE OF THE CITY ATTORNEY 

CITY OF WALLED LAKE, MICHIGAN 

1499 E. WEST MAPLE 

L.. DENNIS WHITT 

CITY MANAGER 

WALLED LAKE, MI 48390 

(248) 624-4847 

VAHAN VANERIAN, ESQ. 

vvanerian@walledlake.com 

CiTY ATTORNEY 

September 3, 2026 

Michigan Tax Tribunal 

611 W. Ottawa St. 

P.O. Box 30232 

Lansing, MI 48909-8195 

Re: 

Z On Ladd LLC v City of Walled Lake 

MTT Docket No: 26-001296 

Dear Clerk: 

Enclosed please find the following filings on behalf of Respondent, City of Walled Lake: 

o 

Respondent’s Answer and Affirmative Defenses 

o 

Respondent’s Case Information Sheet 

e 

Respondent’s Proof of Service 

Respectfully, 

Yatian C. Vanerian 

Vahan Vanerian, Esq. 

City Attorney

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 1. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Entire Tribunal Case Information Sheet - Respondent 

MTT DOCKET NO. 26-001236 

Section 1: Respondent’s Contact Information 

Filer Type: 

Locat Unit of Government 

Local Unit of Government 

City Of Walled Lake [OAKLAND} 

First Name 

ML 

Last Name 

Home Address {No., Street, £,0. 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 

M.L 

Last Name 

vahan 

vanerian 

Firm Name (if any) 

city of walled fake 

‘Address {No., Street, P.O. Box or Rural Route] 

1499 E. West Maple Rd. 

City or Town 

State 

ZiP Code 

Walled Lake 

Michigan 

48390 

Telephone Number 

248-960-8859 

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

wanerian@walled|zke.com 

Electronic Signature «wing your name below will serve as your signature

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

7 ON LADD LLC, 

MOAHR Docket No. 26-001296 

Petitioner, 

v 

CITY OF WALLED LAKE, 

Respondent. 

Jay A. Schwartz 

CITY OF WALLED LAKE 

Representative for Petitioner 

Vahan C. Vanerian (P48196) 

37887 W. Twelve Mile Rd. Ste B 

Representative for Respondent 

Farmington Hills, MI 48331 

1499 E. West Maple Rd. 

(248) 672-1922 

Walled Lake, MI 48390 

{schwartz@propertytaxreductionservices.org 

(248) 960-8899 

yvanerian@walledlake.com 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

NOW COMES Respondent, CITY OF WALLED LAKE, by and through iis Attorney, 

VAHAN C VANERIAN, and for its Answer to Petitioner’s Petition, states as follows: 

1. 

Answering paragraph 1, Respondent admits the allegations therein. 

2. 

Answering paragraph 2, Respondent admits the allegations therein. 

3. 

Answering paragraph 3, Respondent neither admits nor denies the allegations therein for 

lack of sufficient knowledge or information upon which to form 

a belief and leaves 

Petitioner to its proofs. 

4. 

Answering paragraph 4, Respondent neither admits nor denies the allegations therein for

10. 

11. 

12. 

13. 

Answering paragraph 5, Respondent neither admits nor denies the allegations therein for 

lack of sufficient knowledge or information upon which to form 

a belief and leaves 

Petitioner to its proofs. 

Answering paragraph 6, Respondent admits the allegations therein. 

Answering paragraph 7, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and 

leaves Petitioner to its proofs. 

Answering paragraph 8, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and 

leaves Petitioner to its proofs. 

Answering paragraph 9, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and 

leaves Petitioner to its proofs. 

Answering paragraph 10, Respondent admits the allegations contained therein. 

Answering Paragraph 11, Respondent admits the allegations contained therein. 

Answering Paragraph 12, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and 

leaves Petitioner to its proofs. 

Answering Paragraph 13, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and

15. 

16. 

17. 

18. 

19. 

20. 

Answering Paragraph 15, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and 

leaves Petitioner to its proofs. 

Answering Paragraph 16, Respondent admits the allegations contained therein. 

Answering paragraph 17, Respondent admits the petition alleges values in contention for 

the Subject Property but denies that Petitioner’s alleged contended values represent the 

actual or appropriate values for the Subject Property based on generally accepted property 

assessment principles and methods. 

Answering paragraph 18, Respondent neither admits nor denies the allegations contained 

therein for lack of sufficient knowledge or information upon which to form a belief and 

leaves Petitioner to its proofs. 

Answering paragraph 

19, Respondent denies that Petitioner 

is entitled 

to the relief 

requested 

for the reason that the values for the Subject Property 

as established by 

Respondent are reasonable and appropriate and based on generally accepted property 

assessment principles and methods. 

Answering paragraph 20, Respondent denies the allegations contained therein for the 

reason that the same are untrue. 

WHEREFORE, Respondent, CITY OF WALLED LAKE, respectfully requests that the 

Respondent’s assessment and taxable value of the subject property be affirmed or increased, 

that a judgment of no cause for action be entered against Petitioner and in Respondent’s favor, 

and that Petitioner’s Petition be dismissed with prejudice and that Respondent be granted costs

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, CITY OF WALLED LAKE, and for its affirmative defenses, 

states as follows: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, application of wrong principles or illegality on the part of Respondent. 

3. 

Petitioner fails to allege that the mode or method of appraising its property failed 

to conform with the mode and method applied in the case of all of the properties, and/or similarly 

situated properties, in the Respondents taxing unit for the year in question. 

4. 

Petitioner fails to allege specific and sufficient facts to establish the true cash value, 

assessed value and taxable value of its propeity. 

5. 

Petitioner fails to allege specific and sufficient facts to support its allegation that 

the assessed values of its property, as equalized, is at a factor other than 50% and also fails to 

allege specific and sufficient facts to support its allegations that the property’s taxable value is 

improper. 

6. 

Petitioner fails to show that any rate other than 50% after equalization was applied 

to the true cash value of its property, as well as to the properties of all others to arrive at the 

respective equalized assessments. 

7. 

Petitioner, in essence, secks by Petition to challenge the process of county and state

A. 

The equalized assessment of the property is more than 50% of its true cash 

value and that the taxable value is in violation of applicable statutory and 

constitutional limitations. 

B. 

The property is assessed in a discriminatory manner and that the assessment 

is a higher level of true value that the average level of assessment of all 

other property within the City, excepting this property and the assessment 

on other property which is also under appeal. 

C. 

The assessment and taxable value 

are unlawful and based upon 

the 

application of wrong principles and thereby operate as a constructive fraud 

upon the taxpayer. 

The failure to raise such objections to the Respondent’s Board of Review constitutes a failure to 

exhaust the administrative remedies provided for by the General Property Tax Act, constitutes a 

waiver of any such allegations contained in the Petition, and further amounts to a failure by the 

Petitioner to appear in protest to Respondent’s Board of Review as required by the Tax Tribunal 

Act. 

9. 

Petitioner, in essence, asks that this honorable Tribunal grant it an illegal preference 

by application of a method of assessment different from that employed in the assessment of other 

properties in the Respondent’s taxing unit. 

10. 

Any decrease 

in the value of Petitioner’s property was the result of its own 

intentional acts and/or negligence and cannot be allowed to reduce an otherwise equitable tax 

burden. 

11. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner's 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

12. 

Petitioner has failed to pursue its appeal in a timely manner.

and fluctuations and any resulting decreases in value or income are not reflective or indicative of 

the property’s true cash value. 

14. 

Respondent reserves the right to add additional affirmative defenses revealed 

during the course of discovery. 

WHEREFORE, Respondent, CITY OF WALLED LAKE, denies that Petitioner is entitled 

to the relief it seeks and respectfully requests that the Respondent’s assessment and taxable value 

of the subject property be affirmed or increased and that Petitioner’s Petition be dismissed with 

prejudice and that Respondent be granted costs and attorney fees so wrongfully sustained. 

CITY OF WALLED LAKE 

By: 

 /s/ Vahan C Vanerian 

VAHAN C VANERIAN (P48196) 

Dated: September 3, 2026 

Attorney for Respondent 

1499 E. West Maple Rd. 

Walled Lake, MI 48390 

(248) 960-8899 

vvanerian@walledlake.com

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

ZONLADDLLC, 

MOAHR Docket No. 26-001296 

Petitioner, 

v 

CITY OF WALLED LAKE, 

Respondent. 

/ 

Jay A. Schwartz 

CITY OF WALLED LAKE 

Representative for Petitioner 

Vahan C. Vanerian (P48196) 

37887 W. Twelve Mile Rd. Ste B 

Representative for Respondent 

Farmington Hills, MI 48331 

1499 E. West Maple Rd. 

(248) 672-1922 

Walled Lake, MI 48390 

jschwartz@propertytaxreductionservices.org 

(248) 960-8899 

vvanerian@walledlake.com 

PROOF OF SERVICE 

The undersigned certifies that the Respondent’s Answer and Affirmative Defenses was 

served upon all parties to the above case as disclosed on the pleadings on September 3, 2026, via 

US mail and email. 

CITY OF WALLED LAKE 

/s/ Vahan C Vanerian 

By: Vahan c. Vanerian (P48196)

CITY OF WALLED LAKE 

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