Crusade for Christ, Inc. v. Town of New Lebanon

Simons, J. (dissenting).

I do not agree with the majority’s decision that educational or social institutions must be certified before a tax exemption may be granted. Neither the Real Property Tax Law nor the cases contain that requirement. Unless we intend to make local assessors enforcement officers for the myriad regulatory statutes, ordinances and codes which govern modern life, we should not read this new condition into the law.

The Referee was justified in denying the full relief requested because the appellant failed to establish that the uses of this real property were exclusively those…