3303 John F Donnelly Drive LLC, Petitioner Vs. Township Of Holland, 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

3303 John F Donnelly Drive LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002057

Township Of Holland,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ 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:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: February 2, 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

3303 John F Donnelly Drive LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002057

Township Of Holland,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ 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:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: February 2, 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, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

3303 John F Donnelly Drive LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002057

Township Of Holland,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ 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:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: February 2, 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

STATE OF MICHIGAN

DEPARTMENT OF LiCENSING AND REGULATORY AFFAIRS

MICHIGAN ADMINISTRATIVE HEARINGS SECTION

MICHIGAN TAX TRIBUNAL

3303 John F Donnelly Drive LLC,

Petitioner/

V.

Township of Holland

Respondent.

MTT Docket No. 25-002057

Parcel NO: 70-16-17-300-067

CARDINAL TAX ADVISORS

PAUL BACH

Representative for Petitioner

PO Box 80361

Rochester/Ml 48308

248-856-8676

Paui.bach@cardinaltaxadvisors.com

SCHOLTEN FANT

BRADLEYJ FISHER (P64608)

Attorneys for Respondent

100 N Third St/PO Box 454

Grand Haven, Ml 49417-0454

616-842-3030

bfisher@schoitenfant.cQm

STIPULATED MOTION TO WITHDRAW APPEAL

The parties hereto, by their respective r(.

Docket No. 25-002057 for 2025, with prejudice a

Agent for Petitioner:

Paul Bach

to a withdrawal of MTT

Dated:January 29, 2026

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

3303 JOHN 

F DONNELLY DRIVE LLC, 

Docket No. 25-002057 

Petitioner, 

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

Vv. 

PROOF OF SERVICE 

 

HOLLAND CHARTER TOWNSHIP, 

 

Respondent. 

Paul Bach 

Bradley J. Fisher (P64608) 

CARDINAL TAX ADVISORS 

SCHOLTEN FANT 

P.O. Box 80361 

Attorneys for Respondent 

Rochester, MI 48308 

100 N. Third St., PO Box 454 

Phone: (248) 856-8676 

Grand Haven, MI 49417-0454 

Paul.bach@cardinaltaxadvisors.com 

Phone: (616) 842-3030 

 

bfisher@scholtenfant.com 

 

 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OTTAWA 

) 

Kimberly Tapp, deposes and says that she is employed with the law firm of Scholten Fant, 

and 

that she served 

the Respondent’s 

First Interrogatories and Requests 

for Production 

of 

Documents to Petitioner on: 

Paul Bach 

Paul.bach@cardinaltaxadvisors.com 

by depositing the documents in the United States mail at Grand Haven, Michigan, fully prepaid 

and addressed as shown above, on the 19" day of January, 2026. 

 

 

 

imerly Tapp

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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 DECEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

3303 John F Donnelly Drive LLC,

Petitioner,

v

 

 

Township Of Holland,

Respondent.

 MTT Docket No. 25-002057

Please be advised that 25-002057 has been placed on a two-week Prehearing General 

Call commencing December 16, 2026. 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.

Page 2

MTT Docket No. 25-002057

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 disclosures 

by August 19, 2026. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by August 19, 2026. Witnesses, with the exception of rebuttal witnesses, 

will not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

August 19, 2026, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

December 16, 2026, which means all discovery has been requested, all Motions to 

Compel have been filed, and all requested or ordered discovery has been exchanged 

by that date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s 

valuation disclosure, the opposing party’s valuation expert, and the witnesses identified 

on the opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: January 16, 2026

Page 3

MTT Docket No. 25-002057

Page 3 of 3

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their

Page 4

STA

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

3303 JOHN F DONNELLY DRIVE LLC, 

Docket No. 25-002057 

Petitioner, 

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

Vv. 

HOLLAND CHARTER TOWNSHIP, 

Respondent. 

Paul Bach 

Bradley J. Fisher (P64608) 

CARDINAL TAX ADVISORS 

SCHOLTEN FANT 

P.O. Box 80361 

Attorneys for Respondent 

Rochester, MI 48308 

100 N. Third St., PO Box 454 

Phone: (248) 856-8676 

Grand Haven, MI 49417-0454 

Paul.bach@cardinaltaxadvisors.com 

Phone: (616) 842-3030 

bfisher@scholtenfant.com 

RESPONDENT’S ANSWER 

TO PROPERTY TAX PETITION 

NOW COMES RESPONDENT, HOLLAND CHARTER TOWNSHIP, 

by 

and 

through its attorneys, Scholten Fant, and for its Answer to Petitioner’s Property Tax Petition, states 

as follows: 

1. 

Admitted. 

2. 

Admitted. 

3. 

Not applicable. 

4. 

Not applicable. 

5. 

Not applicable. 

6. 

Admitted. 

7. 

Not applicable.

Page 2

8. 

Not applicable. 

9. 

Not applicable. 

10. 

Denied as untrue. 

The Property is located in Holland Charter Township, Ottawa 

11. 

Admitted that Holland Charter Township is responsible for the subject assessments. 

12. 

Neither admitted nor denied for lack of sufficient knowledge or information as to 

form a belief and, therefore, leaves Petitioner to its proofs. 

13. 

Admitted upon information and belief. 

14. 

Admitted. 

15. 

Not applicable. 

16. 

Admitted 

17. 

Neither admitted nor denied for lack of sufficient knowledge or information as to 

form a belief and, therefore, leaves Petitioner to its proofs. 

18. 

Denied as untrue. 

19. 

Respondent requests that the Tribunal deny Petitioner’s request for relief, affirm 

the existing assessments, and award such further relief as 

it deems appropriate under the 

circumstances. 

20. 

Respondent requests that the Tribunal deny Petitioner’s request for relief, affirm 

the existing assessments, and award such further relief as 

it deems appropriate under the 

circumstances. 

21. 

Respondent consents to electronic communications. 

WHEREFORE, Respondent Holland Charter Township respectfully requests that the 

Tribunal deny Petitioner its requested relief, affirm Respondent’s assessment of the subject 

property, award Respondent its costs and attorney’s fees in responding to this action and award

Page 3

such further relief as it deems appropriate under the circumstances. 

Respectfully submitted, 

Dated: September 23, 2025 

Bradley J. Fisher 

(P64608) 

Attorneys for Respondent 

Holland Charter Township

Page 4

AFFIRMATIVE DEFENSES TO PETITIONER’S PROPERTY TAX PETITION 

NOW COMES HOLLAND CHARTER TOWNSHIP, by and through its attorneys, 

Scholten Fant, and hereby offers the following Affirmative Defenses to the Petitioner’s Property 

Tax Petition: 

I. 

The appropriate methods of assessing the Subject Property were used and those 

methods conform to the methods used to assess similarly situated property in the State. 

2. 

Petitioner has failed to state a claim upon which relief can be granted. 

3. 

Petitioner may not be a proper party-in-interest. 

4. 

Petitioner may not have standing to appeal. 

3: 

The Tribunal may lack subject matter jurisdiction over this appeal. 

6. 

Petitioner may have failed to comply with state property tax law by, inter alia, 

failing to report or failing to report completely its assessable property such that its property taxes 

were delinquent or underpaid, such that Petitioner is precluded from appealing its property values, 

and, such that Respondent should be awarded damages. 

7. 

Respondent reserves the right to add additional affirmative defenses as they become 

known to it through discovery in this matter. 

WHEREFORE, Respondent requests that the Tribunal affirm the 2024 assessed and 

taxable values as determined by Respondent, dismiss the Petition, and award Respondent its costs, 

attorney fees and any other relief that the Tribunal determines is fair, just and equitable. 

SCHOLTEN FANT 

Dated: September 23, 2025 

Bradley J. Nisher (P4608) 

Attorneys for Respondent 

Holland Charter Township

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

3303 JOHN F DONNELLY DRIVE LLC, 

Docket No. 25-002057 

Petitioner, 

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

v. 

HOLLAND CHARTER TOWNSHIP, 

Respondent. 

Paul Bach 

Bradley J. Fisher (P64608) 

CARDINAL TAX ADVISORS 

SCHOLTEN FANT 

P.O. Box 80361 

Attorneys for Respondent 

Rochester, MI 48308 

100 N. Third St., PO Box 454 

Phone: (248) 856-8676 

Grand Haven, MI 49417-0454 

paul.bach@cardinaltaxadvisors.com 

Phone: (616) 842-3030 

bfisher@scholtenfant.com 

PROOF OF SERVICE 

The undersigned certifies that a copy of the Respondent's Answer to Property Tax Petition 

and Affirmative Defenses to Petitioner's Property Tax Petition was e-filed with the Michigan Tax 

Tribunal and served upon all parties and/or attorneys of record to this action to their addresses as 

disclosed by the pleadings, on September 23, 2024, via U.S. Mail First Class, from Grand Haven, 

Michigan, with postage thereon fully prepaid. 

Dated: September 23, 2025 

Legal Assistant to Bradley J. Fisher

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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. 25-002057

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Holland (OTTAWA)

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

Bradley

M.I.

J.

Last Name

Fisher

Firm Name (if any)

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

100 N. Third Street

P. O. Box 454

City or Town

Grand Haven

State

Michigan

ZIP Code

49417

Telephone Number

616-842-3030

Fax Number

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

bfisher@scholtenfant.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Bradley J. Fisher

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

3303 John F Donnelly Drive LLC, 

Petitioner 

Vv. 

MTT Docket No. 25-002057 

Holland Charter Twp, 

Respondent 

PROOF OF SERVICE 

Paul Bach, being duly sworn, deposes and says that on September 15, 2025, he 

served a copy of the Entire Tribunal Property Tax Petition relative to the above- 

captioned matter upon: 

1. Assessor, Holland Charter Twp, 353 N 120th Ave 

, Holland, MI 49424 

2. Clerk, Holland Charter Twp, 8650 Ottawa Beach Rd, Holland 

, MI 49423 

via certified mail, return receipt requested, with proper postage affixed thereto. 

3. School Secretary, West Ottawa Public, 1138 136th Ave , Holland, MI 49424 

4. Equalization Director, Allegan County, 113 Chestnut St 

, Allegan, MI 49010 

5. Clerk, Allegan County, 113 Chestnut St, Allegan, MI 49010 

6. 

State of Michigan, State Treasurer, 430 W. Allegan Lansing, MI 48922 

via first class mail, with proper postage affixed thereto. 

Paul Bach

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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

Page 6

20.

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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

3303 John F Donnelly Drive LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002057

Township Of Holland, 

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 8, 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

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

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

Page 6

20.

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

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

3303 John F Donnelly Drive LLC

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

PO Box 80361

City or Town

Rochester

State

Michigan

ZIP Code

48308

Telephone Number

248-856-8676

Fax Number

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

paul.bach@cardinaltaxadvisors.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Paul

M.I.

Last Name

Bach

Firm Name (if any)

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

PO Box 80361

City or Town

Rochester

State

Michigan

ZIP Code

48308

Telephone Number

248-856-8676

Fax Number

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

paul.bach@cardinaltaxadvisors.com

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]

Michigan

Taxing Authority (City or Township)

Township Of Holland (OTTAWA)

County

Ottawa

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:

70-16-17-300-067

Classification of Property: Real 

Commercial

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

2021500

Current Taxable Value as established by the Board of Review:

1875929

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

2700000

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

1350000

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 MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest 

State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Paul Bach

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.