The ruling is bound to be one of the most controversial in recent commercial real estate annals in Central Florida, brokers and tax specialists familiar with other tourist ventures tell GlobeSt.com.

"Right now, there is nothing with which to compare this project in the entire United States and that is bound to make the property appraiser's decision a precedent-setting action," an area real estate lawyer tells GlobeSt.com on condition of anonymity.

"However he rules, the decision is sure to be appealed" to an Orange Circuit Court panel of judges, the lawyer says.

Holy Land Experience is a $16 million, 15-acre enterprise being developed by the Zion's Hope ministry. The organization is directed by Marvin Rosenthal, a former Philadelphia-born Jew converted to the Baptist faith as a teenager and ordained as a minister at 33. He is in his 60s today. Rosenthal moved Zion's Hope to Orlando from Philadelphia in 1989. His son David assists him.

The one-month-old Holy Land Experience is at Interstate 4 and Vineland Road, five miles east of Universal Orlando and 15 miles from Walt Disney World and other name attractions. The Rosenthals, however, classify their project as a museum, not as an attraction.

As a museum, valued by Orange County at $3.7 million, the Rosenthals would pay an annual property tax of $81,400. That number is based on the county's current assessment formula of $22,000 per $1 million of taxable value.

At the $16 million development cost, however, the project would be hit with an annual tax of $352,000. About $14 million in member donations helped the enterprise get off the ground, leaving a first mortgage of $2 million on the property, according to previously published numbers confirmed by the Rosenthals. They could not be reached for comment at GlobeSt.com's publication time.

But Tom Drage, a former state legislator and the property appraiser's lawyer, is on record opposing the Rosenthal's position because it is a commercial money-making enterprise. The fact that Holy Land is exempt from federal and state sales taxes doesn't automatically qualify it for a county property tax exemption, Drage will argue in court if the Rosenthals challenge an unfavorable decision by the property appraiser.

The admission at Holy Land Experience is $17 for adults; $12 for children. That compares with $50 at both Universal Orlando and Disney. The park has an annual advertising budget of $350,000. A gift shop within the park sells religious-oriented publications, baubles, gifts and food--all exempt from the county's 6% sales tax because of Holy Land Experience's religious status.

The entire show and lecture take 20 minutes. The park has played to capacity, 1,000 guests, every day since it opened Feb. 5, according to the Rosenthals.

They estimated, prior to the venture's opening, they would only need about 200,000 visitors a year to break even. Disney, by comparison, pulls 15 million visitors annually at its 30,000-acre enclave in nearby Lake Buena Vista.

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