Christian Fellowship and Renewal Ctr. v. Town of Limington

CourtSuperior Court of Maine
DecidedOctober 25, 2004
DocketYORap-04-06
StatusUnpublished

This text of Christian Fellowship and Renewal Ctr. v. Town of Limington (Christian Fellowship and Renewal Ctr. v. Town of Limington) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christian Fellowship and Renewal Ctr. v. Town of Limington, (Me. Super. Ct. 2004).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION YORK, ss. DOCKET NO. AP-04-06, AE Lp 7 DAS P / F , / CHRISTIAN FELLOWSHIP AND RENEWAL CENTER, Plaintiff ORDER ce te oes - Vv. AND pepe: DECISION NOV 3 he

TOWN OF LIMINGTON, et als.,

Defendants

The plaintiff has appealed from a January 7, 2004 decision of the York County Commissioners which denied its request for a property tax abatement for the 1996 tax year. The procedural history of this case is jengthy and can be found, in part, in Christian Fellowship and Renewal Center v. Town of Limington, 2001 ME 16, 769 A.2d 834. Following a number of additional orders and proceedings the Commissioners made their decision and after further orders and stipulations this appeal, following the submission of briefs and oral argument, is ready for a resolution. The parties have provided this court with a detailed Stipulation of Fact which vastly aided judicial review of this dispute.

The Christian Fellowship and Renewal Center (CFRC) has been a Maine non- profit corporation since December of 1987 and has owned real estate in Limington since April of 1989. In 1996 Limington did not tax the main building of CFRC or an adjoining 3 acres but did tax a farmhouse, the caretaker’s house and the remaining land which consists of 72 acres, but was found to be comprised of 88 acres. The CFRC sought tax-

exempt status for the farmhouse, caretaker’s house and remaining 72 acres.

soe atu

The CFRC is exempt from federal income taxation pursuant to 26 USC §501(c)(3), has directors who must be Christians, and is organized to provide religious, charitable and educational services particularly by assisting fundamentalist, bible-believing churches and individuals both physically and spiritually. It did so by providing food to the needy and by making its facilities available to churches and their members at reduced rates. The facilities are primarily available to individuals and entities that hold fundamental bible-based religious views. The main building was used both for food distribution for the poor and to rent to churches and religious groups. The rental fees were modest and were waived for individuals who could not afford them. The stipulated facts indicate that the revenues of CPRC were modest and that the expenses slightly exceeded the revenues in 1996.

The CFRC also allowed individuals who were using the main building to use the remainder of the property for recreation. The farmhouse was used by a minister and his family and for overflow lodging if there was a group that was too large to be housed entirely in the main building. The caretaker’s house was used, as its name suggests, by the caretakers of the property. The caretakers received no compensation for their services, but were not charged any rent. Lastly the property is available for rent for a variety of activities such as conventions, family reunions, bridal and baby showers, conferences, seminars and anniversary parties, but was not actually rented for any of those purposes. _

The Commissioners determined that the taxed property was not also entitled to tax exempt status as the CFRC was “primarily organized and conducted for religious purposes to benefit certain religious groups and individuals ... and the Center’s primary use of its property is as rental property for the benefit of stich religious groups

and individuals.” ‘he Commissioners found that CFRC had ”... failed to demonstrate

no that it provides any significant benefit to the general public or the local community or that it provides a service or benefit that the government would otherwise provide.” The Commissioners did find that food distribution to the needy constituted a charitable and benevolent purpose, that only a small portion of the “retreat center”, presumably the main building, was used for this purpose and that the CFRC had not established its entitlement to an exemption.

We have both statutes and a substantial body of Maine Supreme Judicial Court (Law Court) decisions to add in deciding this case.

As early as 1928 the Law Court stated, “It is a fundamental rule of the law of taxation that ‘taxation is the rule and exemptions the exception.’ And all doubts and uncertainties as to the meaning of a statute are to be weighed against exemption.” Ferry Beach Park Association v. City of Saco, 127 Me. 136, 138 (Me. 1928). That rule has been clarified in Holbrook Island Sanctuary ». Town of Brooksville, 161 Me. 476, 483, 214 A.2d 660, 64 (ME. 1965) to require the organization to come “tinmistakably within the spirit and intent of the act creating the exemption.” and tempered in State Young Men’s Christian Association of Maine v. Town of Winthrop, 295 A.2d 440, 442 (Me. 1972) with the finding that, “This rule, however, does not require that the narrowest possible meaning must be given to words descriptive of exemption. The strict construction must still be a reasonable construction.”

While taxation is the rule and exemptions are the exception the Legislature has created a number of exemptions found at 36 M.RS.A. §652, which exempts from taxation certain property of institutions and organizations. An exemption that does not directly affect this case is the exemption for “Houses of religious worship, including vestries” and “property owned and used by a religious society as a parsonage to the

value of $20,000, and personal property not exceeding $6,000 in value, but so much of any parsonage as is rented is liable to taxation. For purposes of the tax exemption provided by this paragraph, a parsonage shall mean the principal residence provided by a religious society for its clergyman whether or not located within the same municipality or place as the house of religious worship where the clergyman regularly conducts religious services.” See 36 MRS.A. g652(1)(G). This sub-section is the religion-based exemption that is directly provided to assist churches. The house of religious worship is exempt from taxation while a portion of the value of a parsonage or rectory is also exempt.

There is a second exemption that is available to both religious and non-sectarian institutions and organizations. That exemption is found at 36 M.R.S.A. §652(1)(A) and is available to “benevolent and charitable institutions.” The questions become whether the farmhouse, caretaker’s house and the remaining acres are “owned and occupied or used solely for their own purposes by benevolent and charitable institutions”, 36 M.R.S.A. §652(1)(A) and whether the CFRC is “organized and conducted exclusively for benevolent and charitable purposes.” 36 M.R.S.A. §652(1)(C)(1).

The word “benevolent” is to be construed as synonymous with the word “charitable”. Maine AFL-CIO Housing Development Corporation v. Town of Madawaska, 523 A.2d 581, 4 (Me. 1987). In the case of Episcopal Cantp Foundation, Inc. v. Town of Hope, 666 A.2d 108 (Me. 1995) the Law Court was faced with the issue of whether providing children with the opportunity to attend a summer camp below cost was a charitable _ and benevolent purpose. It described a charity, at 110, by quoting from Johnson v. South Blue Hill Cemetery Association, 221 A.2d 280, 7 (Me. 1966), to be “for the benefit of an indefinite number of persons, either by bringing their minds or hearts under the

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Bluebook (online)
Christian Fellowship and Renewal Ctr. v. Town of Limington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christian-fellowship-and-renewal-ctr-v-town-of-limington-mesuperct-2004.