## Facts

- A religious organization sought a real property tax exemption for certain property under New York’s statutory exemptions for religious (and possibly charitable) uses.
- A taxing authority denied the exemption in whole or in part on the ground that the property was not used “exclusively” (commonly applied as “primarily”) for qualifying religious purposes.
- The organization challenged the denial through judicial review proceedings, contesting the taxing authority’s legal standard and/or application of the statutory “use” requirement.
- The dispute centered on how the property was actually used and whether the organization’s activities on the property qualified as religious use for exemption purposes.

## Issues

1. Whether the property qualified for a religious real property tax exemption under New York law based on its actual use.
2. Whether “used exclusively” for religious purposes should be applied as a “primarily used” standard permitting incidental non-qualifying uses.
3. Whether the taxing authority applied an erroneous legal standard or made a determination that could not be sustained on the administrative record.

## Decision

- The New York Court of Appeals issued a decision resolving the exemption dispute under New York’s real property tax exemption framework for religious uses.
- The court treated the controlling inquiry as the nature and extent of the property’s actual use, rather than the popularity or orthodoxy of the claimant’s religion.
- The court applied New York’s approach to “exclusive use” exemptions by evaluating whether qualifying religious use was the property’s primary use, while considering the effect of incidental non-qualifying uses.

## Legal Principles

- Eligibility for a religious property-tax exemption turns on the property’s actual use, not on theological judgments about the claimant’s religious beliefs.
- Statutory “used exclusively” requirements in New York are applied in practice as a primary-use test; incidental non-exempt use does not automatically defeat exemption.
- Taxing authorities may examine objective evidence of use to classify activities as qualifying or non-qualifying, but must avoid evaluating religious truth claims.
- Judicial review may set aside an exemption denial if the authority applied an incorrect legal standard or if the determination cannot be sustained on the record under the governing review standard.

## Conclusion

The case applied New York’s religious property-tax exemption doctrine by focusing on whether the property’s primary use was religious, permitting scrutiny of objective property use while rejecting decisions based on religious orthodoxy.


Holy Spirit Ass'n for the Unification of World Christianity v. Tax Comm'n, 435 N.E.2d 662 (N.Y. 1982)