Hapletah v. Assessor of Town of Fallsburg

In Hapletah v. Assessor of Town of Fallsburg (79 N.Y.2d 244 [1992] the municipality found a partial tax exemption, refusing to exempt portions of the property used to house staff and arguing that the tax exemption statute only provided for property "used exclusively" for religious purposes and should be given a strict interpretation. The Court of Appeals, however, refused to interpret the exemption so narrowly. Instead, the Court ruled that the test for entitlement to an exemption "is whether the particular use is reasonably incidental to the [primary or] major purpose of the facility whether its primary use is in furtherance of the permitted purposes" (Hapletah v. Assessor of Town of Fallsburg at 250.) The Court went on to find that housing provided the staff, who lived on the premises and devoted its time fully to the religious institution, was exempt from the property tax since that housing was clearly incidental to the purpose of the facility.