Appeal of Emissaries of Divine Light

The taxpayer, the Emissaries of Divine Light, appeals an order of the New Hampshire Board of Tax and Land Appeals (board) awarding it a partial exemption from property taxes for the 1990 and 1991 tax years. The taxpayer argues that it is entitled to full tax exemption and that apportionment is inappropriate in religious exemption cases. It also argues that the board violated its first amendment rights under the Federal Constitution. We affirm.

The taxpayer is a religious organization located in Epping. The taxpayer owns a number of parcels of real estate, referred to collectively as Green…