Tax Court Digest

Property Tax

Church Property

Petitioners challenged county’s denial of a property-tax exemption, arguing that the property qualified as exempt church property because it was owned by a Catholic church and intended for future supportive housing consistent with the church’s mission. The Tax Court held that the property did not qualify for the church-property exemption because the law requires concurrence of exempt ownership and exempt use, and, as of the January 2, 2024 assessment date, the property was being operated by a nonprofit affordable housing developer’s wholly owned subsidiary rather than by the church itself. The court explained that, even treating the subsidiary as its nonprofit parent for exemption purposes, the lack of concurrence between the church’s ownership and the nonprofit’s use precluded the claimed exemption. The court nevertheless concluded that the property might qualify for an exemption as an institution of purely public charity and therefore declined to dismiss that alternative claim. Finally, the court denied, without prejudice, petitioners’ request to allocate 100% of the land value to the property’s undisputed tax-exempt portion because factual disputes regarding apportionment precluded summary judgment. Partial summary judgment granted in part and denied in part; church-property exemption denied, with charitable-exemption claim remaining pending.

27-CV-25-5108 St. Olaf Catholic Church of Minneapolis, MN v. County of Hennepin