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3303 John F Donnelly Drive LLC v Holland Charter Twp 2025 Petition.pdf

3303 John F Donnelly Drive LLC, Petitioner Vs. Township Of Holland, Respondent · 25-002057-TT

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Page 1

May 30, 2025 

 

VIA E-File 

 

Clerk 

Michigan Tax Tribunal 

P. O. Box 30232 

Lansing, MI 48909 

 

RE: 3303 John F Donnelly Drive LLC V Holland Charter Twp 

 

PARCEL NO. 70-16-17-300-067 

 

Dear Clerk: 

 

 

Enclosed for filing are the following: 

 

1. A Case Information Sheet. 

2. An Entire Tribunal Property Tax Petition. 

3. A filing fee of $600 to the State of Michigan. 

Thank you for your prompt attention to this matter. 

 

Respectfully, 

 

Cardinal Tax Advisors 

Paul Bach 

 (Electronic Signature) 

By: Paul Bach 

REPRESENTATIVE FOR PETITIONER 

 

 

Enclosures

Page 2

Michigan Tax Tribunal 

Entire Tribunal Case Information Sheet 

1. Petitioner, Address and Phone No.: 

3303 John F Donnelly Drive LLC 

135 Elberdene St 

Holland, MI 49424 

2. Respondent, Address and Phone No.: 

Holland Charter Twp 

353 N 120th Ave 

Holland, MI 49424 

616-396-2345 

3. Agent Name, Address and Phone No.: 

Cardinal Tax Advisors 

Paul Bach, Agent 

PO Box 80361 

248-856-8676 

Rochester, MI 48308 

 

4. Agent Name and Address, if known: 

 

 

5. Filing Fee Paid: $600 

 

6. Is a proof of service attached? 

 

Column below for Property Tax appeal only 

Column below for Non-Property Tax appeal 

only 

A. Amount of State Equalized Value in 

Contention:* $ 671,500 

* For parcel with highest SEV in contention 

 

A. Amount in Contention: 

Tax: $_________________ 

Penalty: $_________________ 

Interest: $_________________ 

 

B. Issue (designate one): 

X Valuation 

 Special Assessment 

 Equalization 

C. Reason for appeal: 

X True cash value (TCV) & taxable value (TV) 

 TV only 

 Uncapping: Tax Year(s) at issue: ________ 

 Tax Bill: Tax Year(s) at issue: ________ 

 STC Order: Tax Year(s) at issue: ________ 

 Other (please state): _________________ 

D. Type of Property: _X__ Real ___ Personal 

 

E. Classification of Property: Commercial 

 

B. Tax Type (designate one): 

Aircraft Fuel Privilege 

Airport Parking Tax 

Estate Tax 

Individual Income 

Motor Carrier 

Motor Fuel 

Sales, Use, Withholding 

Severance Tax 

Single Business 

Stadia or Convention Facility Financing 

State Convention Facility Dev 

State Real Estate Transfer Tax 

Tobacco Products 

Other (please state): _________________ 

F. Tax 

Year(s) 

 

 

G. Parcel ID No. (for parcel listed in 

“A” above) 

 

C. Assessment No(s). 

(attach an additional 

sheet, if necessary) 

D. Date of Issuance 

2025 

70-16-17-300-067 

 

 

 

 

 

 

H. Are you appealing more than one parcel? If yes, 

how many? ___ NO _X_

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULARTORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

3303 JOHN F DONNELLY DRIVE LLC, 

 

 

 

 

 Petitioner 

 

 

v. 

MTT Docket No. _____________ 

Parcel No. __70-16-17-300-067 _ 

 

 

 

HOLLAND CHARTER TWP, 

 

Respondent 

 

 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

Petitioner, 3303 John F Donnelly Drive LLC, through its representative, Cardinal 

Tax Advisors, petitions this Tribunal as follows: 

 

 

1. 

Property Parcel No. 70-16-17-300-067 

 

2. 

The property identified above is Real property. 

 

3. 

If more than one parcel is under appeal, are the properties contiguous? 

___Yes ___ No _X_ N/A 

 

4. 

If more than one parcel of personal property is under appeal, are there also 

parcels of real property under appeal? ___Yes ___ No _X_ N/A If yes, are all 

of the parcels of personal property located on a parcel of real property under 

appeal? ___ Yes ___ No _X_ N/A

Page 4

5. 

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

property statements filed by parcel number: Date ____ or _X__ N/A 

 

6. 

The property is identified above is classified Commercial and is presently used 

for Commercial purposes. Petitioner believes that Petitioner’s property was 

originally designed to be used for Commercial purposes. 

 

7. 

If P.A. 174 of 2006 requires a Board of Review protest for Petitioner’s Property, 

a Board of Review protest was filed in March 2025. 

 

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: N/A 

 

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, list the separate 

and specific acts upon which Petitioner relies to invoke the Tribunal’s authority 

over the assessment or assessments at issue: N/A 

 

10. The property is located in Allegan County. The property address is: 23 James 

St, Holland, MI 49424 

 

11. The assessment(s) at issue were established by: Holland Charter Twp 

 

12. Petitioner’s legal residence or principal office address is: 135 Elberdene St 

Holland, MI 49424. Petitioner is a party in interest with respect to property 

tax parcels included in this petition. 

 

13. This appeal involves issues relating to: 

_X_ the property or properties true cash and taxable values 

___ the property or properties taxable value only 

___ If the property’s taxable value is at issue, is there a dispute as to the value 

of an addition or loss? ___ Yes ___ No 

_X_ uniformity of the property or properties assessment 

__ the property or properties exemption from ad valorem taxation under 

MCL 

___ the classification of the property or properties 

 

 

14. The tax year at issue is 2025.

Page 5

15. If more than the current tax year is being appealed, list the separate and specific 

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

prior tax year of years: N/A 

 

 

16. The values for the property identified above as established by the Respondent’s 

Board of Review are: 

 

 

 

 

17. Petitioner contends that the values for the property identified above are: 

 

 

18. The values in dispute for the property identified above are: 

 

 

 

 

 

 

19. Petitioner requests the following relief: 

 

1. Take jurisdiction to review the 2025 assessed, state equalized and taxable 

values placed against the property covered by this Petition. 

 

2. Determine that the 2025 assessed, state equalized and taxable values for the 

property covered by this Petition should be no higher than $1,350,000. 

 

3. Order that Respondent pay to Petitioner the refund attributable to the 

reduction in value, plus interest and costs. 

 

4. Order such other and further relief as this Honorable Tribunal deems just 

and/or equitable. 

 

 

Tax Year 

True Cash Value 

State 

Equalized 

Value 

Taxable 

Value 

2025 

$4,043,000 

$2,021,500 

$1,875,929 

Tax Year 

True Cash Value 

State 

Equalized 

Value 

Taxable 

Value 

2025 

$2,700,000 

$1,350,000 

$1,350,000 

Tax Year 

True Cash Value 

State 

Equalized 

Value 

Taxable 

Value 

2025 

$1,343,000 

$ 671,500 

$ 525,929

Page 6

20. List the separate and specific facts upon which Petitioner relies to support the 

relief requested: 

 

1. The equalized assessment of the property is more than fifty percent (50%) of 

its true cash value in violation of applicable statutory and constitutional 

limitations; 

 

2. The assessment on the property is unlawful and is based upon the application 

of the wrong principles and thereby operates as a fraud upon the taxpayer; 

 

3. The property is assessed in a discriminatory manner in that the assessment is 

at a higher level of true cash value than the average level of assessment within 

the assessment district. 

 

21. Petitioner requests future correspondence be accepted electronically. 

 

 

Respectfully submitted, 

 

 

 

 

________________________ 

By: Paul Bach 

Cardinal Tax Advisors 

PO Box 80361 

Rochester, MI 48308 

Phone (248) 856-8676 

Paul.bach@cardinaltaxadvisors.com 

 

Dated this 30th day of May, 2025

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