Rosenthal argues his $16 million, 15-acre property is exempt from paying an estimated $300,000 to $500,000 in annual property taxes because the real estate houses Zion's Hope Inc., a not-for-profit ministry.

The judge is giving Rosenthal 20 days to amend the suit. The tax year in dispute is for 2001 but the judge's final ruling will affect Holy Land Experience's taxes for future years. The attraction opened in February 2001.

Rosenthal is suing the county and Donegan because the property appraiser ruled last fall that only the 8.57-acre portion of the ministry's church sanctuary is exempt from taxes. But the remaining 6.43 acres, which displays the ministry's museum and exhibits, is assessed at $1.2 million and must pay taxes. The 6.43 acres has a market value of $186,625 per acre or about $4.28 per sf.

Tied in with the suit and the land's evaluation will be 10 acres adjoining Holy Land Experience purchased in May 2001 by the park's biggest financial angel, Scott R. Pierre, president, Van Kampen Foundation and the Grace Foundation of Wheaton, IL. Pierre paid $5.4 million ($540,000 per acre; $12.40 per sf), Orange County real estate records show.

Rosenthal will argue the 10 acres doesn't belong to Zion's Hope Inc., lawyers following the case tell GlobeSt.com on condition of anonymity. But the property appraiser will contend the 10 acres are being planned for surface parking at Holy Land Experience and should be counted as part of the park's realty inventory.

Thomas Drage, a former state legislator, is Donegan's lawyer. David Cortman represents Zion's Hope. Both lawyers are from Orlando.

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