D & M Plumbing Specialists Inc, Petitioner Vs. Township Of Waterford, 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

D & M Plumbing Specialists Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002183

Township Of Waterford,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: September 16, 2026

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

D & M Plumbing Specialists Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002183

Township Of Waterford,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has considered the file in this case and finds that the parties have filed a 

Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By: /s/ Patricia L. Halm

Entered: September 16, 2026

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

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Page 1

PROPERTY TAX REDUCTION SERVICES, LLC 

Mel R. Partovich 

37887 West Twelve Mile Road, Suite B 

 

Jay A. Schwartz 

Farmington Hills, Michigan 48331 

(248) 672-1922 

https://propertytaxreductionservices.org 

 

 

September 16, 2026 

 

 

 

ELECTRONIC FILING 

 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, Michigan 48909 

 

 

Re: 

D & M Plumbing Specialists, Inc. 

 

 

v Township of Waterford 

 

 

MTT Docket No. 25-002183-TT 

 

Dear Madame/Sir: 

 

 

Petitioner is hereby withdrawing its Petition, and Respondent concurs in the withdrawal as 

indicated below. 

 

 

Please close the above-referenced file. Thank you. 

 

Very truly yours, 

 

 

 

 

 

 

 

 

PROPERTY TAX REDUCTION SERVICES, LLC 

 

/s/ Jay A. Schwartz 

 

JAS/lz 

 

CONSENT TO WITHDRAWAL: 

 

/s/ Laura M. Hallahan (w/Written Permission 9-14-2026) 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Hallahan & Associates, P.C. 

Attorneys for Respondent 

1750 South Telegraph Road, Suite 202 

Bloomfield Hills, Michigan 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 25-002183

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Joint

Files

Document Type: Motion to Withdraw Appeal

Attachment File Name: Letter Withdrawing Appeal (D&M v Waterford 25-002183) 9-16-26

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

MICHIGAN TAX TRIBUNAL 

DOCKET # 25-002183 

D & M Plumbing Specialists 

6695 Highland Road 

Waterford, Michigan 48327 

Parcel No. 13-20-126-002

Page 2

September 8, 2026 

Michigan Tax Tribunal 

P. O. Box 30232 

Lansing, Michigan 48909 

Gentlemen/Ladies: 

Pursuant to Michigan Tax Tribunal Docket #25-002183 herewith is our valuation 

of the 

True Cash Value 

of 

real 

property 

located 

at 6695 

Highland 

Road, 

Waterford, Michigan 48327, Tax |.D. # 13-20-126-002. 

In 

our opinion 

the True 

Cash Value 

of the 

property 

is $1,200,000, 

as 

of 

December 31, 2025. 

One Million Two Hundred Thousand Dollars 

Respectfully 

Sgb

Page 3

XII. 

TABLE OF CONTENTS 

Statement of the Problem 

Summary of Salient Facts and Conclusions 

Map of Subject 

Township Data 

Neighborhood Map 

Neighborhood Analysis 

Site Data 

Subject Data 

Income Approach 

Sales Comparison Approach 

Conclusion 

Appendix

Page 4

1

PROPERTY RIGHTS APPRAISED: 

This valuation disclosure is made with the 

understanding that the present ownership of subject property includes all of the 

STATEMENT OF THE PROBLEM 

rights that may be lawfully owned and is therefore titled "fee simple". 

PURPOSE OF THE VALUATION: 

This valuation 

is made for the purpose of 

estimating the true cash value 

of the subject property 

in 

its current condition. 

True cash value 

is defined as "the usual selling price at the place where the 

property to which the term 

is applied shall be at the time of assessment, being 

the price which could be obtained therefore at a private sale"". 

held to be synonymous with true cash value. Market value is defined as 

"The most probable price, as of a specific date, 

in cash or in terms 

equivalent to cash, or in other precisely revealed terms, for which 

the specified property rights should sell after reasonable exposure 

in 

a competitive market under all conditions requisite to fair sale, 

with the buyer and seller each acting prudently, knowledgeably, 

and for self-interest, and assuming that neither 

is under undue 

duress. 

Fundamental assumptions and conditions presumed in this definition are 

1. 

2. 

3. 

4. 

Buyer and seller are motivated by self-interest. 

Buyer and seller are well informed and are acting prudently. 

The property is exposed for a reasonable time on the open 

market. 

Payment 

is made 

in cash, 

its equivalent, 

or 

in specified 

financing terms. 

Specified financing, 

if any, may be the financing actually in 

place or on terms generally available for the property type in 

its locale on the effective appraisal date. 

The effect, 

if any, on the amount of market value of atypical 

financing, services, 

or fees shall 

be clearly and precisely 

revealed in the valuation disclosure. 

Market value is

Page 5

2

SUMMARY OF SALIENT FACTS AND CONCLUSIONS 

Subject Property: 

Owner: 

Tax I.D. No.: 

Legal Description: 

2026 Assessed Value: 

2025 Capped Value: 

2025 Taxable Value: 

School Districts: 

Taxes Paid: 

Site Size: 

Zoning: 

Improvements: 

Size: 

Year Built: 

Class Quality: 

Highest & Best Use: 

Estimate of Value: 

6695 Highland Road 

Waterford, Michigan 48327 

Zuehlke, Crake and Liles, a registered Co-Partnership 

13-20-126-002 

T3N, ROE, SEC 20 E

Page 6

3

Page 7

4

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Page 1

MICHIGAN TAX TRIBUNAL 

 

 

DOCKET # 25-002183 

 

 

 

 

 

 

 

 

D & M Plumbing Specialists 

6695 Highland Road 

Waterford, Michigan 48327 

 

 

 

 

Parcel No. 13-20-126-002 

 

 

 

 

 

 

 

 

 

 

 

For Year 

 

2025

Page 2

September 3, 2026 

Michigan Tax Tribunal 

P. O. Box 30232 

Lansing, Michigan 48909 

Gentlemen/Ladies: 

Pursuant to Michigan Tax Tribunal Docket #25-002183 herewith is our valuation 

of the True Cash Value 

of 

real 

property 

located 

at 6695 

Highland 

Road, 

Waterford, Michigan 48327, Tax I.D. # 13-20-126-002. 

In 

our opinion 

the True Cash Value 

of the 

property 

is $1,200,000, 

as 

of 

December 31, 2024. 

One Million Two Hundred thousand dollars 

\ 

Respectfully 

ubmitted,

Page 3

XI. 

TABLE OF CONTENTS 

Statement of the Problem 

Summary of Salient Facts and Conclusions 

Map of Subject 

Township Data 

Neighborhood Map 

Neighborhood Analysis 

Site Data 

Subject Data 

Income Approach 

Sales Comparison Approach 

Conclusion 

Appendix

Page 4

1

PROPERTY RIGHTS APPRAISED: 

This valuation disclosure is made with the 

understanding that the present ownership of subject property includes all of the 

STATEMENT OF THE PROBLEM 

rights that may be lawfully owned and is therefore titled "fee simple". 

PURPOSE OF THE VALUATION: 

This valuation 

is made for the purpose of 

estimating the true cash value of the subject property 

in 

its current condition. 

True cash value 

is defined as "the usual selling price at the place where the 

property to which the term 

is applied shall be at the time of assessment, being 

the price which could be obtained therefore at a private sale"!. 

held to be synonymous with true cash value. 

Market value is defined as 

"The most probable price, as of a specific date, 

in cash or in terms 

equivalent to cash, or in other precisely revealed terms, for which 

the specified property rights should sell after reasonable exposure 

in 

a competitive market under all conditions requisite to fair sale, 

with the buyer and seller each acting prudently, knowledgeably, 

and for self-interest, and assuming that neither 

is under undue 

duress. 

Fundamental assumptions and conditions presumed in this definition are 

1. 

2. 

3. 

4. 

Buyer and seller are motivated by self-interest. 

Buyer and seller are well informed and are acting prudently. 

The property is exposed for a reasonable time on the open 

market. 

Payment 

is made 

in cash, 

its equivalent, 

or 

in specified 

financing terms. 

Specified financing, 

if any, may be the financing actually in 

place or on terms generally available for the property type in 

its locale on the effective appraisal date. 

The effect, 

if any, on the amount of market value of atypical 

financing, 

services, 

or fees 

shall 

be clearly and 

precisely 

Market value is

Page 5

SUMMARY OF SALIENT FACTS AND CONCLUSIONS 

Subject Property: 

Owner: 

Tax 1.0. No.: 

Legal Description: 

2025 Assessed Value: 

2025 Capped Value: 

2025 Taxable Value: 

School Districts: 

Taxes Paid: 

Site Size: 

Zoning: 

Improvements: 

Size: 

Year Built: 

Class Quality: 

Highest & Best Use: 

Estimate of Value: 

6695 Highland Road 

Waterford, Michigan 48327 

Zuehlke, Crake and Liles, a registered Co-Partnership

Page 6

1

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

Petitioner: D & M Plumbing Specialists, Inc. 

v 

Respondent: Charter Township of Waterford 

 

 

MTT Docket No. 25-002183 

 

 

 

Petitioner’s Prehearing Statement 

 

RESPONDENT’S PREHEARING STATEMENT 

 

Petitioner’s representative: 

Jay A. Schwartz 

Property Tax Reduction Services, LLC 

37887 West 12 Mile Road, Suite B 

Farmington Hills, MI 48331 

(248) 672-1922 

 

Respondent’s representative: 

Laura M. Hallahan (P42101) 

 

Seth A. O’Loughlin (P80257) 

 

Kelsea M. Melcher (P85821) 

 

Hallahan & Associates, P.C. 

 

1750 S. Telegraph Road, Suite 202 

 

Bloomfield Hills, Michigan 48302 

 

(248) 731-3089 

 

I. 

VALUATION INFORMATION: 

A. The true cash value (TCV), assessed value (AV), and taxable value (TV) for each 

parcel and tax year at issue as established by the Board of Review: 

Parcel Number 

Year 

TCV 

AV 

TV 

W-13-20-126-002 

2025 

$1,175,900 

$587,950 

$509,130 

W-13-20-126-002 

2026 

$1,198,080 

$599,040 

$522,870 

 

B. Respondent’s contentions of TCV, state equalized value (SEV), and TV for each 

parcel and tax year at issue: 

Parcel Number 

Year 

TCV 

SEV 

TV 

W-13-24-451-015 

2025 

$1,200,000 

$600,000 

$509,130 

W-13-24-451-015 

2026 

$1,200,000 

$600,000 

$522,870

Page 2

MTT Docket No. 25-002183 

Respondent’s Prehearing Statement, Page 2 of 5 

 

 

C. Petitioner’s contentions of TCV, state equalized value (SEV), and TV for each 

parcel and tax year at issue (per Petitioner’s Petition and Motions to Amend, if 

applicable): 

Parcel Number 

Year 

TCV 

SEV 

TV 

W-13-20-126-002 

2025 

$800,000 

$400,000 

$400,000 

W-13-20-126-002 

2026 

$850,000 

$425,000 

$425,000 

 

D. Amounts in dispute for the tax year(s) at issue: 

Parcel Number 

Year 

TCV 

SEV 

TV 

W-13-20-126-002 

2025 

$400,000 

$200,000 

$109,130 

W-13-20-126-002 

2026 

$350,000 

$175,000 

$97,870 

 

I. 

TAX INFORMATION: 

A. Have taxes been paid for each property for each tax year at issue? 

☐ Yes 

☒ No 

III. 

FACTUAL STATEMENT OF CLAIMS: 

A. Describe any additions or losses for each property for each tax year at issue (by 

parcel number and tax year): 

Respondent is unaware of any additions or losses to the subject property. 

B. Classification of each property for each tax year at issue (by parcel number): 

W-13-20-126-002 

2025 & 2026 

Commercial 

 

C. Current use of each property for each tax year at issue, if different than above (by 

parcel number): 

Not applicable. 

D. Contention of highest and best use for each property for each tax year at issue, if 

different than property’s current use for each tax year at issue (by parcel number): 

Not applicable. 

E. Your factual statement of claims in support of your contentions, including additions 

and losses, if any (i.e., what facts are you relying on in support of your claim or 

defense?): 

Respondent contends that it lawfully and uniformly assessed the subject property.

Page 3

MTT Docket No. 25-002183 

Respondent’s Prehearing Statement, Page 3 of 5 

 

 

F. 

If non-uniformity of assessment is alleged, what evidence will you rely upon in 

support of your contents? 

Respondent contends that it lawfully and uniformly assessed the subject property. 

G.

Page 4

MTT

Page 5

MTT

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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

MICHIGAN TAX TRIBUNAL

Docket Number: 25-002183

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Respondent

Files

Document Type: Prehearing Statement

Attachment File Name: R's PHS_D&M_FINAL

Document Type: Valuation Disclosure

Attachment File Name: Valuation Disclosure 2025

Document Type: Valuation Disclosure

Attachment File Name: Valuation Disclosure 2026

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

D & M Plumbing Specialists LLC, 

 

 

 

Petitioner, 

 

v 

 

Charter Township of Waterford, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002183 

 

 

_____________________________________________________________________________/ 

 

JAY A. SCHWARTZ 

Property Tax Reduction Services, LLC 

Representative for Petitioner 

37887 West 12 Mile Road, Suite B 

Farmington Hills, MI 48331 

(248) 672-1922 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

RESPONDENT’S SUBSTITUTION OF AUTHORIZED REPRESENTATIVE 

 

Hallahan & Associates, P.C. will substitute in place of Paula Moore of Charter Township 

of Waterford as Representative for Respondent Charter Township of Waterford. 

_/s/ Paula Moore________________ 

Paula Moore 

Assessor 

Charter Township of Waterford 

 

Dated: June 18, 2026 

__/s/ Laura M. Hallahan____________ 

Laura M. Hallahan (P42101) 

Seth O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

 

 

Dated: June 18, 2026

Page 2

MTT Docket No. 25-002183 

 

 

2

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Substitution of 

Authorized Representative to: 

 

Jay A. Schwartz 

jayschwartz@propertytaxreductionservices.org 

 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

/s/ Laura M. Hallahan_______ 

Dated: June 18, 2026 

Laura M. Hallahan

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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

D & M Plumbing Specialists Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

 

MTT Docket No. 25-002183 

Township Of Waterford,

Respondent.

ORDER GRANTING PETITIONER’S MOTION TO AMEND

The Tribunal has considered the file in this case and finds that Petitioner filed a motion 

requesting that the Tribunal permit them to amend the petition to include a subsequent 

tax year. Respondent has not filed a response to the Motion to Amend. The motion is 

timely under MCL 205.737 and 205.735a, however, and Petitioner has shown good 

cause to justify the granting of the motion. Therefore,

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED.

IT IS FURTHER ORDERED that this order only grants the relief indicated above and 

does not find as true any allegations of fact or provide any other relief requested by the 

motion.

By: /s/ Patricia L. Halm

Entered: June 18, 2026

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

D & M Plumbing Specialists Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

 

MTT Docket No. 25-002183 

Township Of Waterford,

Respondent.

ORDER GRANTING PETITIONER’S MOTION TO AMEND

The Tribunal has considered the file in this case and finds that Petitioner filed a motion 

requesting that the Tribunal permit them to amend the petition to include a subsequent 

tax year. Respondent has not filed a response to the Motion to Amend. The motion is 

timely under MCL 205.737 and 205.735a, however, and Petitioner has shown good 

cause to justify the granting of the motion. Therefore,

IT IS ORDERED that Petitioner’s Motion to Amend is GRANTED.

IT IS FURTHER ORDERED that this order only grants the relief indicated above and 

does not find as true any allegations of fact or provide any other relief requested by the 

motion.

By: /s/ Patricia L. Halm

Entered: June 18, 2026

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,

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

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

Page 2

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

Page 3

3

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Page 1

1 of 1

Docket #: 25-002183

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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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 JANUARY 4 - 15, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

D & M Plumbing Specialists Inc,

Petitioner,

v

 

 

Township Of Waterford,

Respondent.

 MTT Docket No. 25-002183

Please be advised that 25-002183 has been placed on a two-week Prehearing General 

Call commencing January 04, 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.

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MTT Docket No. 25-002183

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

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M

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

D & M Plumbing Specialists. Inc. 

Petitioner 

vs. 

Docket No: 

__25-002183 

Parcels: W-13-20-126-002 

Township of Waterford 

Respondent 

ANSWER TO PETITION 

Now comes the Township of Waterford, a Michigan Municipal 

Corporation, through its’ Assessor, Paula Moore, and answers the Petition heretofore 

filed in this cause. 

1) 

Answering paragraph one of the Petition, Respondent admits the 

allegations therein contained. 

2) 

Answering paragraph two of the Petition, Respondent admits the 

allegations therein contained. 

3) N/A. 

4) N/A. 

5) N/A. 

6) 

Answering paragraph six of the Petition, Respondent admits the 

allegations therein contained. 

7) N/A. 

8) N/A. 

9) N/A. 

10) Answering paragraph ten of the Petition, Respondent admits the 

address correlates to the parcel listed in the petition.

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11) Answering paragraph eleven of the Petition, Respondent admits the 

Township correlates to the parcel listed in the petition. 

12) N/A. 

13) Answering paragraph thirteen of the Petition, Respondent admits the 

allegations therein contained. 

14) Answering paragraph fourteen of the Petition, Respondent admits the 

year correlates to the information in the petition. 

15) N/A. 

16) Answering paragraph sixteen of the Petition, Respondent admits the 

allegations therein contained. 

17) Answering paragraph seventeen of the Petition, Respondent denies the 

allegations therein contained. 

18) Answering paragraph eighteen of the Petition, Respondent denies the 

allegations therein contained. 

19) Answering paragraph nineteen of the Petition, Respondent denies the 

allegations therein contained. 

20) Answering paragraph twenty of the Petition, Respondent denies the 

allegations therein contained. 

Wherefore, Respondent respectfully requests that the Petitioners’ claim be 

denied and that the Tribunal sustains the assessed value of $587,950 and the taxable 

value of $509,130 for Parcel W-13-20-126-002, as confirmed by the local Board of 

Dated: 

7 

OF WATERFORD 

20 eg 

Paila di 

Assessor

Page 3

AFFIRMATIVE DEFENSES 

For its further Answer to Petitioner's Petition and by way of its Affirmative Defenses, 

Respondent states as follows and demands an answer from Petitioner as to each: 

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 the Respondent. 

3. 

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

to conform with the mode and method applied in the case of all of the properties in the 

Respondent's 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 property. 

5. 

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

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

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8.

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WHEREF

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002183

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Waterford (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Paula

M.I.

Last Name

Moore

Firm Name (if any)

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

5200 Civic Center Drive

City or Town

Waterford

State

Michigan

ZIP Code

48329

Telephone Number

248-674-6204

Fax Number

248-674-5455

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

pmoore@waterfordmi.gov

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

Paula Moore

/s/

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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. 

_______________________________________/ 

 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

 

 

I, Lyn Zarem, state that on September 11, 2025, I served a copy of the 2025 Property Tax 

Petition (with noted docket number), relative to the above-captioned matter: 

By CERTIFIED MAIL, on: 

 

Township of Waterford 

Assessing Department 

5200 Civic Center Drive 

Waterford, Michigan 48329 

 

Waterford Township Clerk 

5200 Civic Center Drive 

Waterford, Michigan 48329 

 

and FIRST-CLASS MAIL, on: 

 

Oakland County Director of Equalization 

Suite 1000W 

250 Elizabeth Lake Road 

Pontiac, Michigan 48341 

 

Oakland County Clerk 

Building 12E 

1200 North Telegraph Road 

Pontiac, Michigan 48341 

 

Secretary of Local School Board 

Waterford School District 

501 North Cass Lake Road 

Waterford, Michigan 48328

Page 2

2 

 

State Treasurer 

Michigan Department of Treasury 

430 West Allegan 

Lansing, Michigan 48922 

 

I declare under the penalty of perjury that a statement above is true to the best of my 

knowledge, information and belief. 

 

 

 

 

 

 

 

 

 

 

 

/s/ Lyn Zarem 

 

 

 

 

 

 

 

 

 

 

 

Property Tax Reduction Services, LLC 

 

 

 

 

 

 

 

37887 West Twelve Mile Road, Suite B 

 

 

 

 

 

 

 

Farmington Hills, Michigan 48331 

 

 

 

 

 

 

 

(248) 672-1922

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Page 1

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

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 

_____________________________ 

 

 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________ 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

 

2. 

The property identified above is ___real ___personal. 

 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.) 

 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes ___No. (If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

 

 

 

 

 

6. 

The property identified above is classified as _________________________ 

 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent’s ___ March ___ July ___December Board of Review. 

 

 

 

CHARTER TOWNSHIP OF WATERFORD,

D & M PLUMBING SPECIALISTS, INC.

 W-13-20-126-002

 X

Commercial-Improved

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

 

 

 

 

 

9. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

 

 

 

 

 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

 

 

 

 

 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

 

12. 

Petitioner’s legal residence or principal office address is: 

 

 

 

 

 

13. 

This appeal involves issues relating to the (check all that are applicable): 

________the property or properties’ true cash and taxable values 

________the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

________uniformity of the property or properties’ assessment

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MTT

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MTT

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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

D & M Plumbing Specialists Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002183

Township Of Waterford, 

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: August 13, 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

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Page 1

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

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 

_____________________________ 

 

 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________ 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

 

2. 

The property identified above is ___real ___personal. 

 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.) 

 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes ___No. (If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

 

 

 

 

 

6. 

The property identified above is classified as _________________________ 

 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent’s ___ March ___ July ___December Board of Review. 

 

 

 

CHARTER TOWNSHIP OF WATERFORD,

D & M PLUMBING SPECIALISTS, INC.

 W-13-20-126-002

 X

Commercial-Improved

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

 

 

 

 

 

9. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

 

 

 

 

 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

 

 

 

 

 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

 

12. 

Petitioner’s legal residence or principal office address is: 

 

 

 

 

 

13. 

This appeal involves issues relating to the (check all that are applicable): 

________the property or properties’ true cash and taxable values 

________the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

________uniformity of the property or properties’ assessment

Page 3

MTT

Page 4

MTT

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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: Organization

First Name/Company Name

M.I.

Last Name

D & M Plumbing Specialists, Inc.

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

6695 Highland

City or Town

Waterford

State

Michigan

ZIP Code

48327

Telephone Number

2486721922

Fax Number

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

jschwartz@propertytaxreductionservices.org

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jay

M.I.

A.

Last Name

Schwartz

Firm Name (if any)

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

37887 West Twelve Mile Road

Suite B

City or Town

Farmington Hills

State

Michigan

ZIP Code

48331

Telephone Number

248-672-1922

Fax Number

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

jschwartz@propertytaxreductionservices.org

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 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]

6695 Highland

Waterford

Michigan

48327

Taxing Authority (City or Township)

Township Of Waterford (OAKLAND)

County

Oakland

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.)

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)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

W-13-20-126-002

Classification of Property: Real 

Commercial

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

587950

Current Taxable Value as established by the Board of Review:

509130

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

800000

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

400000

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:

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

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

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

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