Ocean Grove Camp Meeting Ass'n of the United Methodist Church v. Township of Neptune

CourtNew Jersey Tax Court
DecidedMarch 5, 2021
Docket005650-2018
StatusUnpublished

This text of Ocean Grove Camp Meeting Ass'n of the United Methodist Church v. Township of Neptune (Ocean Grove Camp Meeting Ass'n of the United Methodist Church v. Township of Neptune) is published on Counsel Stack Legal Research, covering New Jersey Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ocean Grove Camp Meeting Ass'n of the United Methodist Church v. Township of Neptune, (N.J. Super. Ct. 2021).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

TAX COURT OF NEW JERSEY

MALA SUNDAR Richard J. Hughes Justice Complex JUDGE P.O. Box 975 Trenton, New Jersey 08625-0975 609 815-2922, Ext. 54630 Fax 609 376-3018

March 4, 2021 James M. McGovern, Jr., Esq. Davison, Eastman, Munoz, Paone, P.A. Attorneys for Plaintiff

Gene J. Anthony, Esq. Attorneys for Defendant

Re: Ocean Grove Camp Meeting Ass’n of the United Methodist Church v. Township of Neptune Block 148, Lot 1 (54 Pitman Avenue) Docket No. 005650-2018 Dear Counsel:

This letter is the court’s opinion deciding the parties’ respective summary judgment

motions filed in the above captioned matter. Defendant’s summary judgment motion seeks

affirmance of its denial of local property tax exemption for tax year 2018 on the above captioned

property, an administrative office building (Office) owned by plaintiff and located in defendant

taxing district (Township). The Township argues that plaintiff is not affiliated with any

organized religious order or organization, and further uses the Office to process revenues (the

largest being rents and proceeds from summer entertainment). Therefore, per the Township, the

Office is being used in furtherance of plaintiff’s for-profit activities and should be taxed. The

motion was supported by depositions of several of plaintiff’s employees (past and present) or

other representatives, and certain documents as to plaintiff’s incorporation and activities.

Plaintiff’s cross-motion for summary judgment seeks restoration of the Office’s tax

exemption for both tax years 2017 and 2018 (both years being included in plaintiff’s complaint

for tax year 2018). Plaintiff argues that the Office is its administrative building where, in addition to property management, several other activities which are directly in furtherance of its

non-profit, charitable/religious purposes are also being administratively performed. Its motion

was supported by certifications of two of plaintiff’s representatives, with attached documents.

For the reasons stated below, the court finds that it cannot decide the merits of the

exemption denial for tax year 2017 since plaintiff did not timely challenge the same. The court

reverses the tax exemption denial for the Office for tax year 2018 thus grants plaintiff’s cross-

motion for summary judgment as to this tax year.

PROCEDURAL HISTORY

Plaintiff is a federally income tax-exempt entity under I.R.C. §501(c)(3). Until tax year

2016, the Office was granted local property tax exemption by the Township.

By letter dated November 21, 2016, the Township’s assessor denied tax exemption to the

Office for tax year 2017. The reason was:

The property’s use as of October 1 of the pretax year. The use must be a qualifying exempt use. Property’s use must be an integral part of the exempt organization’s operations, not just a convenience, and reasonably necessary for the proper and efficient fulfillment of the organization’s exempt purposes. Property must be actually used for a permitted or qualifying use pursuant to the statute under which exemption is sought.

There was no timely appeal from this tax exemption denial.

On March 27, 2018, plaintiff filed a direct complaint challenging the 2018 local property

tax assessment of $1,057,300 (allocated $515,600 to land and $541,700 to improvements)

imposed on the Office on grounds the assessment was in excess of the Office’s true value.

Plaintiff also alleged that the Office was improperly denied a tax exemption for tax years 2017

and 2018. The Township filed a counterclaim alleging that the Office is not entitled to a tax

exemption and that it was under-assessed.

2 FACTS

The following facts are taken from deposition testimony and certifications of plaintiff’s

employees or other representatives, and undisputed documents as to plaintiff’s incorporation,

activities, and operations.

Plaintiff’s Statutory Incorporation

Plaintiff’s history culminating into its incorporation is detailed in Schaad v. Ocean Grove

Camp Meeting Ass’n of the United Methodist Church, 72 N.J. 237, 254-58 (1977) and State v.

Celmer, 80 N.J. 405, 410-13 (1979). Methodist clergymen bought 260 acres of land near the

ocean in Ocean Grove to establish camp meeting grounds in 1869. Schaad, 72 N.J. 254. The

organizers incorporated under L. 1870, c. 157 as the Ocean Grove Camp Meeting Association

of the Methodist Episcopal Church 1 which retained “title to all the lands . . .” and “sold leaseholds

for 99 years, renewable in perpetuity, at a fixed sum down and a stated annual ground rental” to

the residents due “[t]o maintain the special character of the place.” Schaad, 72 N.J. 254.

When incorporated, plaintiff’s purpose was “that of providing and maintaining for the

members and friends of the Methodist Episcopal Church a proper, convenient and desirable

permanent camp meeting ground and [C]hristian seaside resort.” L. 1870, c. 157 §1. Article II

of plaintiff’s By-Laws reiterate the “object” of plaintiff is “to provide and maintain for members

and friends of the United Methodist Church a proper, convenient, and desirable permanent camp-

meeting ground and Christian seaside resort as provided in the Statute of Incorporation.”

1 The name was changed to “The Ocean Grove Camp Meeting Association of The United Methodist Church.” Celmer, 80 N.J. at 410. Another “Methodist camp meeting association[] . . . was incorporated as the Camp Meeting Association of the Newark Conference of the Methodist Episcopal Church” in the 1800s, “and maintains a community called Mount Tabor in Morris County.” Schaad, 72 N.J. at 255. 3 Plaintiff’s Mission Statement is “providing opportunities for spiritual birth, growth and renewal

through worship, education, cultural activities and recreation in a Christian seaside setting.”

Twenty-six trustees manage plaintiff’s affairs. Id. §4. They must be members of the

Methodist church. L. 1870, c. 157, §4; Celmer, 80 N.J. at 411 (trustees had to “be and remain

members of The United Methodist Church in good and regular standing”). Associate trustees

should be members of a Christian Church “in good and regular standing.” By-Laws, Art. III, §4.

Honorary trustees can be anyone who is “Christian Clergy or lay person, by reason of his or her

contribution to Christianity, and interest and support of” plaintiff. Id., Art. III, §10.

The Trustees manage the daily operations by serving on the “Board’s executive, program

and development committees.” Celmer, 80 N.J. at 412. “The executive committee serves as the

administrative arm of the Board, and represents the Board in all official matters,” while the

“program committee” is responsible for “organizing religious services and meetings” for

residents, and the “development committee is charged with the duty of initiating and

implementing financial programs necessary to provide and maintain [Ocean Grove] . . . as a

proper, convenient and desirable permanent Camp Meeting Ground and Christian Seaside

Resort.” Ibid. (internal quotation marks omitted).

Currently, plaintiff is not a church within the conference of Methodist churches, nor

under the control of a Bishop of the United Methodist Church. There is no “agreement” between

the United Methodist Church and plaintiff, and plaintiff is not considered as a congregation of

the United Methodist Church.

Plaintiff’s incorporating statute authorized it to purchase, hold, and/or sell real property,

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Ocean Grove Camp Meeting Ass'n of the United Methodist Church v. Township of Neptune, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ocean-grove-camp-meeting-assn-of-the-united-methodist-church-v-township-njtaxct-2021.