New York Botanical Garden v. Assessors of the Town of Washington

OPINION OF THE COURT

Lazer, J. P.

These appeals involve both the meaning and breadth of interpretation to be given subdivision 1 of section 421 of the Real Property Tax Law under which real property owned by nonprofit entities organized or conducted primarily for certain specifically enumerated purposes and primarily used for those purposes is absolutely or qualifiedly exempt from local taxation. The instant owner and appellant is New York Botanical Garden (Botanical Garden), a corporation organized by a special act of the Legislature a century ago (see L 1891, ch 285). The corporation…