In Re Appeal of Order of St. Paul First Hermit

CONCURRING AND DISSENTING OPINION BY

Judge FRIEDMAN.

I respectfully concur and dissent. I disagree only with the majority’s holding that the Order of St. Paul the First Hermit (Appellant) failed to establish that the forty overnight rooms in the Retreat House at The National Shrine of Our Lady of Czestochowa (Shrine) are exempt from taxation under section 204(a)(1) of The General County Assessment Law (Assessment Law).1

Section 204(a)(1) of the Assessment Law provides that all “churches, meetinghouses, or other actual places of regularly stated religious worship, with the ground thereto annexed…