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Corporation of Presiding Bishop of Church of Jesus Christ of Latter-Day Saints v. Ada County, 123 Idaho 410, 849 P.2d 83

Facts

The Corporation of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints owned a home in Boise used as the residence for the president of the Idaho Boise Mission. The mission president, an unpaid ordained minister, served full-time and was responsible for the spiritual and physical needs of 157 lay missionaries. The property had been tax-exempt since its purchase in 1979 until the county denied the exemption in 1987, leading to the appeal. The president's role did not involve a localized congregation, as the missionaries were spread across a wide area and attended services at their local meetinghouses.

The CPB owns a parcel of land in Boise improved with a two-story, five-bedroom home used as the residence of the president of the Idaho Boise Mission and his wife.

Issue

Whether the Mission President's home qualifies for an ad valorem tax exemption as a 'parsonage' under Idaho Code § 63–105B and as property used exclusively for charitable purposes under Idaho Code § 63–105C.

Whether the Mission President's home is a “parsonage” such that it qualifies for an ad valorem tax exemption under I.C. § 63–105B.

Rule

For a property to qualify as a parsonage under Idaho law, it must be owned by a religious organization and occupied as a residence by a designated minister who serves a specific localized congregation that gathers to worship at frequent and regular intervals.

for purposes of property tax exemption for religious corporations or societies, “parsonage” is building owned by religious organization occupied as residence by designated minister who ministers to specific localized congregation that gathers to worship at frequent and regular intervals.

Analysis

The court analyzed the definition of 'parsonage' and determined that the mission president's home did not meet the criteria, as the president did not serve a specific localized congregation. The court emphasized that the mission president's role was not equivalent to that of a traditional pastor, as he did not have a congregation that gathered regularly in one location. The court also noted that the property was not used exclusively for charitable purposes as defined by the law.

Applying the foregoing premises to the case at bar, it is clear that the Mission Home does not qualify for exemption as a “parsonage belonging to [any religious corporation or society] and occupied as such” within the strict parameters of I.C. § 63–105B.

Conclusion

The Supreme Court reversed the district court's decision, concluding that the Mission President's home did not qualify for a property tax exemption as a parsonage or as charitable use property.

Reversed.

Who won?

Ada County prevailed in the case because the Supreme Court found that the mission president's home did not meet the legal requirements for a tax exemption under Idaho law.

The County has no written guidelines or standards for determining when an ecclesiastical residence qualifies for tax exemption as a parsonage.

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