Department of Revenue v. New Life Fellowship of Montana, Inc.

New Life Fellowship of Montana, Inc. (New Life) appeals the December 21, 1984, order of the Sixteenth Judicial District Court denying its motion to assess attorney’s fees and costs against the Department of Revenue and awarding actual costs in the amount of $28.00 to New Life. We affirm.

New Life is a non-profit Montana organization. It operates a religious and educational facility near Ekalaka, Montana, called Trails End Ranch. The Ranch consists of approximately 80 acres, plus improvements. It is used as a camp for groups of all ages.

On July 24, 1981, New Life applied to the Department of…