Book Agents of the Methodist Episcopal Church, South v. State Board of Equalization

(concurring in part and dissenting in part.)

I concur in all of the Chief Justice’s-opinion, except the holding therein that the tax on the printing press property shall be prorated on the basis of the ratio of denominational religious earnings to all earnings. While the ratio is reasonable and fair, there is no right or justification given by the statute to adopt any ratio at all.

T.C.A. Section 67-502(2) clearly provides that only the real and personal property “occupied” and “used exclusively” for religious purposes shall be exempt. The statute says nothing at all of ratios or proportions or…