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Keywords

statuteappealcorporationnonprofit

corporationnonprofit

Related Cases

New England Forestry Foundation, Inc. v. Board of Assessors of Hawley, 468 Mass. 138, 9 N.E.3d 310

Facts

The New England Forestry Foundation, Inc. (NEFF) is a Massachusetts nonprofit corporation that owns a 120-acre parcel of forest land in Hawley. NEFF applied for a charitable tax exemption under G.L. c. 59, § 5, Third, but the town's board of assessors denied the application, claiming NEFF failed to demonstrate that it occupied the land for charitable purposes. NEFF appealed to the Appellate Tax Board, which upheld the denial. NEFF's mission includes conservation and management of forest lands, and it has engaged in various activities to maintain the Hawley forest, including hiring a licensed forester to develop a management plan.

The taxpayer, NEFF, is a Massachusetts nonprofit corporation organized under G.L. c. 180, and it has received tax-exempt status from the Federal government under 26 U.S.C. § 501(c)(3) (2006). NEFF is dedicated to several activities in furtherance of this mission including '[e]ducating landowners, foresters, forest product industries, and the general public about the benefits of forest stewardship and multi-generational forestland planning.'

Issue

Did the New England Forestry Foundation qualify for a charitable tax exemption under G.L. c. 59, § 5, Third, for its 120-acre parcel of forest land in Hawley?

Rule

Under G.L. c. 59, § 5, Third, real property owned by a charitable organization is exempt from taxation if the land is occupied by the organization for the purposes for which it was organized.

Clause Third provides that the real property of a charitable organization is exempt from taxation if the land is occupied by the charitable organization or its officers for the purposes for which it was organized.

Analysis

The court determined that NEFF's activities in managing the Hawley forest, including sustainable forestry practices and conservation efforts, constituted a charitable purpose. The court found that NEFF's work benefits the public by preserving natural resources and contributing to environmental quality, thus fulfilling the requirements for a charitable organization under the statute. The court also noted that the Appellate Tax Board erred in its interpretation of NEFF's activities as not qualifying as charitable.

Therefore, we conclude that the board erred in denying NEFF a property tax exemption and that NEFF is a charitable organization that, during the relevant tax year, occupied its parcel in Hawley for its charitable purposes within the meaning of G.L. c. 59, § 5, Third.

Conclusion

The Supreme Judicial Court reversed the Appellate Tax Board's decision and granted NEFF the charitable tax exemption for its forest land in Hawley.

We conclude that the board erred in holding that c. 61 precludes NEFF from eligibility for a Clause Third property tax exemption.

Who won?

New England Forestry Foundation, Inc. prevailed in the case because the court found that its activities met the criteria for a charitable organization under the relevant tax exemption statute.

The Supreme Judicial Court, Spina, J., held that taxpayer was entitled to charitable exemption.

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