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
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
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