Holy Spirit Ass'n for the Unification of World Christianity v. Tax Commission

For the reasons set forth in the admirable dissenting memorandum of the Tax Commission’s minority, I would grant the petition and annul respondent’s determination denying the application for exemption of certain of petitioner’s properties from real estate taxes.

I do not agree with the view of the court majority that petitioner was not organized primarily for religious purposes. This conclusion depends upon dubious, unacceptably restrictive assumptions concerning the nature of religion and religious purposes, assumptions that if applied in an even-handed way, as the Constitution mandates that…