Tax Exemption for a House Used for Retreats
In Benedictine Sisters of Pittsburgh v. Fayette County Bd. of Assessment Appeals, 844 A.2d 86 (Pa. Cmwlth. 2004), the Court ruled that a three bedroom, ranch style house with a swimming pool and detached garage used for retreats was exempt from taxes as an "actual place of regularly stated religious worship," as provided by the Pennsylvania Constitution, Article VIII, Section 2(a)(i).
The Court reasoned that "the fact that some education may be taking place at the property does not mean that education is the primary use of the property" and that "the concept of worship is not limited to a formal service." 844 A.2d at 90 (citing Mount Zion New Life Center v. Bd. of Assessment and Revision of Taxes and Appeals, 94 Pa. Commw. 439, 503 A.2d 1065 (Pa. Cmwlth. 1986) and Evangel Baptist Church v. Mifflin County Bd. of Assessment Appeals,815 A.2d 1174 (Pa. Cmwlth. 2003)).
Looking to the stated use of the property for "prayer, spiritual readings and discussions," the Court concluded that the "Benedictine Sisters satisfied their burden of showing that the Property's primary purpose is as a place of regularly stated worship." Benedictine Sisters, 844 A.2d at 90.