In In the Matter of Yeshivath Shearith Hapletah v. Assessor of the Town of Fallsburg, 79 N.Y.2d 244 (1992) the petitioner was a religious corporation which owned a 31-acre parcel of property in Sullivan County. The property was used primarily during the summer months to provide religious instruction to approximately 450 students. The Court stated that the property was "comprised of a main building containing a kitchen and communal dining room for all participants, a ritual bath, recreational facilities, classrooms, synagogues and a variety of housing facilities including a multiunit dormitory building, 64 bungalows and 6 trailers. Ten acres of the 31-acre parcel are largely wooded and are used primarily by the students for hiking. The housing units are occupied by the Rabbis, teaching staff, their wives and children, all of whom receive religious instruction." (Id. at 247.) The Court further noted that the record showed that "no fees are paid for use of the facilities; rather, they are made available as housing for teachers and are included as part of the annual tuition for students. Petitioner derives no income from the Woodbourne facility. Charitable contributions are relied upon to help defray operating costs." (Id. at 248.) The respondent Town in Yeshivath argued that the portions of the property used for residential purposes was not exempt from taxation because they were not necessary or fairly incidental to the operation of the religious programs. The Court of Appeals rejected this argument. The Court stated that "the test of entitlement to tax exemption under the 'used exclusively' clause of the statute is whether the particular use is 'reasonably incidental' to the primary or major purpose of the facility. Put differently, the determination of whether the property is used exclusively for the statutory purposes depends upon whether its primary use is in furtherance of the permitted purposes." (Yeshivath, 79 N.Y.2d at 250.) In examining the residential use of the property in Yeshivath, the Court found that "if petitioner was unable to provide residential housing accommodations to its faculty, staff, students and their families, its primary purposes of providing rigorous religious and educational instruction at the yeshivah would be seriously undermined. Thus, these housing facilities are 'necessary and reasonably incidental' to the primary purpose of the Woodbourne facility, and this is so notwithstanding the existence of limited housing facilities nearby." (Id. at 250-251.) The Court further concluded that "the 10-acre wooded parcel of land used for recreational purposes by the students is incidental to the primary religious purpose of the entire 31-acre parcel, and is entitled to exemption as well." (Id. at 252.)