Motion to Amend to Add 2026 (D & M v Waterford 25-002183) 5-21-26.pdf
D & M Plumbing Specialists Inc, Petitioner Vs. Township Of Waterford, Respondent · 25-002183-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL D & M PLUMBING SPECIALISTS, INC., Petitioner, v MTT Docket No. 25-002183 TOWNSHIP OF WATERFORD, Respondent. _______________________________________________________________________________ PROPERTY TAX REDUCTION SERVICES, LLC By: Jay Schwartz Representative for Petitioner 37887 W. Twelve Mile Road, Suite B Farmington Hills, Michigan 484331 (248) 672-1922 jschwartz@propertytaxreductionservices.org CHARTER TOWNSHIP OF WATERFORD By: Paula Moore, Assessor Representative for Respondent 5200 Civic Center Drive Waterford, Michigan 48329 (248) 674-6270 pmoore@waterfordmi.gov ______________________________________________________________________________ PETITIONER’S MOTION TO AMEND TO CONTEST 2026 ASSESSED AND TAXABLE VALUES Petitioner, D & M Plumbing Specialists, Inc., by and through its Representative, Property Tax Reduction Services, LLC, and for its Motion to Amend to Contest 2026 Assessed and Taxable Values state: 1. Petitioner filed an Entire Tribunal Tax Petition in this matter for the 2025 tax year. 2. Petitioner seeks to amend the Petition to add an appeal for the 2026 tax year. 3. Petitioner brings this Motion pursuant to TTR 205.1202(c) and TTR 205.1230. 4. This amendment involves issues relating to the property’s true cash, state equalized and/or taxable values. 5. The values for the property identified herein, as established by Respondent, are: Tax Year Parcel Number True Cash Value Assessed Value Taxable Value 2026 W-13-20-126-002 $1,198,080 $599,040 $522,870
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2 6. Petitioner contends that the values for the property(ies) identified herein are: Tax Year Parcel Number True Cash Value State Equalized Value Taxable Value 2026 W-13-20-126-002 $850,000 $425,000 $425,000 7. The values in dispute for the property(ies) identified herein are: Tax Year Parcel Number True Cash Value State Equalized Value Taxable Value 2026 W-13-20-126-002 $348,080 $174,040 $97,870 8. The 2026 assessment, including the state equalized values and taxable values, imposed on Petitioner’s property(ies), and the taxes to be levied and collected thereon, are invalid and unlawful, and operate as a fraud upon the taxpayer for the reasons that: a. The assessments, including the state equalized values and/or taxable values, exceed the amounts permitted by the Michigan Constitution and applicable statutes; b. The assessments, including state equalized values and/or taxable values, are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes; c. The assessments, including taxable values and/or state equalized values, are based upon an erroneous determination of true cash value of that portion of Petitioner’s Property(ies) that are taxable under Michigan law and are based upon the application of wrong principles; and d. The assessment, including state equalized values and/or taxable values, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection, and due process of law. WHEREFORE, Petitioner moves that this Motion be granted, and Petitioner requests that the Tribunal enter an Order reducing the 2026 assessed values, reducing the 2026 taxable values, and requiring the Respondent pay to Petitioner the refunds attributable to such reductions, plus interest and costs. PROPERTY TAX REDUCTION SERVICES, LLC By: /s/ Jay A. Schwartz Jay A. Schwartz Representative for Petitioner 37887 West Twelve Mile Road, Suite B Farmington Hills, Michigan 48331 (248) 672-1922 Dated: May 21, 2026 jschwartz@propertytaxreductionservices.org
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3 PROOF OF SERVICE On May 21, 2026, the undersigned certifies that a copy of Petitioner’s Motion to Amend to Contest 2026 Assessed and Taxable Values, and Proof of Service were served, by first class mail, upon: Paula Moore, Assessor Charter Township of Waterford 5200 Civic Center Drive Waterford, Michigan 48329 I declare under the penalty of perjury that the statement above is true to the best of my knowledge, information and belief. /s/ Lyn Zarem Lyn Zarem Property Tax Reduction Services, LLC 37887 West Twelve Mile Road, Suite B Farmington Hills, Michigan 48331