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Book Agents of Methodist Episcopal Church, South v. State Bd. of Equalization, 513 S.W.2d 514

Facts

The case arose from petitions for writs of certiorari filed by taxing authorities and corporate property owners, including the Book Agents of the Methodist Episcopal Church and the Baptist Sunday School Board, challenging property tax assessments. The properties in question included real estate and personal property used for publishing and printing activities. The State Board of Equalization determined that properties used for non-religious purposes were taxable, leading to appeals from both the property owners and the taxing authorities.

The corporation, ‘Book Agents,’ is the record owner of certain real estate located on Demonbreum Street which was assessed for taxation at a value of $1,593,700.00.

Issue

Whether the properties owned by the Methodist and Baptist petitioners qualify for tax exemption under Article II, Section 28 of the Tennessee Constitution and T.C.A. § 67-502(2).

The dominant issue here is whether the Methodist and Baptist petitioners own, occupy and use the subject property so as to exempt that property under Article II, Section 28 of the Constitution of the State of Tennessee and T.C.A. § 67-502(2).

Rule

Property is exempt from taxation if it is owned and used exclusively for religious, charitable, scientific, literary, or educational purposes, as specified in the Tennessee Constitution and relevant statutes.

The property herein enumerated shall be exempt from taxation: (2) The real estate owned by any religious, charitable, scientific or educational institution occupied by such institution or its officers exclusively for carrying out thereupon one (1) or more of the purposes for which said institution was created or exists.

Analysis

The court analyzed the activities of the Methodist and Baptist institutions, determining that while they engaged in publishing religious literature, they also published secular materials. The court concluded that only the portions of the properties used exclusively for religious purposes could be exempt from taxation, while those used for secular purposes were taxable.

The State Board of Equalization, the chancellor, and the Court of Appeals determined that the property owners publish denominational, non-denominational religious, and secular literature.

Conclusion

The Supreme Court affirmed the lower court's decision, holding that the properties were taxable to the extent they were used for non-religious purposes.

Affirmed.

Who won?

The Metropolitan Board of Equalization prevailed as the court upheld the tax assessments against the religious institutions, determining that not all activities conducted by the institutions qualified for tax exemption.

The Metropolitan Board of Equalization will be referred to as the ‘Metropolitan Board.’

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Morrison-Knudsen Co. v. State Tax Commission, 242 Iowa 33, 44 N.W.2d 449, 41 A.L.R.2d 523

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