In People ex rel. Society of Free Church of St. Mary the Virgin v. Feitner (168 NY 494 [1901]), a religious corporation challenged the assessment of real estate taxes upon its property in New York City. At issue was whether the buildings upon the corporation's real property qualified for the exemption by being "used exclusively for carrying out thereupon" the corporation's religious purpose. (Id. at 496.) The property consisted of a church building, a mission house, a clergy house and a rectory. All parties conceded that the church building was exempt. The Court in Feitner held that the mission house was also exempt from taxation. The court described the use and occupancy of the mission house as follows: Upon the first floor of this house is a chapel, where there is an altar used daily for religious services. This building is in charge of three sisters, who have a general reception room upon the first floor, where all persons desiring to consult them are received. The second floor is also occupied by a chapel and the third floor by the women's guild, the rooms being used regularly three times each week, one for the mothers' meeting, one for the guild girls and one for younger girls and children. The fourth floor is used as the living rooms of the sisters, and the fifth is their kitchen. The Court held that the mission house was exempt from taxation stating that "the daily use of the chapel for religious services, the constant reception of women and children for counsel and advice, the distribution of charity, with the meeting of the guilds day and night, would seem to make the residence of the sisters in the building necessary and an incident to the work carried on there, and not an appropriation of the building for other purposes than that for which the relator was incorporated." Id. at 497 . With respect to the clergy house, the Court in Feitner held that it was also exempt from taxation because the sleeping and living rooms occupied by the curates who cared for the building and the building engineer were incidental to the work carried on by the corporation. (Id. at 498.) However, the Feitner Court held that rectory did not qualify for exemption under the statute. The Court stated that "the building is used as [the rector's] dwelling house, and is not otherwise devoted to the purposes for which the [religious corporation] was incorporated." (Id. at 499.) The Court found that the Legislature by separate statute (Tax Law of 1896, ch. 908, 4, subd. 9) had expressly provided that rectories and buildings used by officiating clergy would only be exempted from taxation up to the amount of two thousand dollars and that therefore the Legislature must have intended that such residences not be completely exempted from taxation. (Id.)