Religious Worship Buildings Tax Exemption
In Mount Zion New Life Ctr. v. Bd. of Assessment and Revision of Taxes and Appeals, 94 Pa. Commw. 439, 503 A.2d 1065 (Pa. Cmwlth. 1986), the Court noted that the term "religious worship" must be construed broadly to include prayer and religious teaching; the Court concluded that certain buildings in a retreat center located on a 104-acre tract which were regularly used for religious worship were entitled to an exemption.
Citing Board of Home Missions and Church Extension of Methodist Episcopal Church v. City of Philadelphia, 266 Pa. 405, 109 A. 664 (1920), the Court adopted the "primary purpose" test in Mt. Zion for determining whether a portion of a building qualifies as an actual place of religious worship.
Under this test, a tax exemption is authorized for "those places in which the primary purpose is worship and other activities are merely incidental." Mt. Zion, 503 A.2d at 1071.
This Court determined in Mt. Zion that certain portions of the buildings used by the retreatants for worship and teaching were exempt because they were primarily used for religious worship.
The other areas, however, that were not primarily used for religious worship were not found to be tax exempt.
Regarding land and non-structural improvements, we noted that "the courts have commonly concluded that one acre for each place of worship is reasonably necessary to provide for ingress and egress." Mt. Zion, 503 A.2d at 1072.