Corporation That Offered Meditation and Healing Skills Not Entitled to Exemption
In Self Realization Meditation Healing Centre v. Charter Township of Bath, Michigan Court of Appeals, No. 297475, June 21, 2011, the property of a nonprofit corporation that was a part of a network of centers that offered training for those wishing to take healing and counselling skills into their lives or professions was not entitled to a local Michigan charitable institution property tax exemption because the overall nature of the corporation was not charitable.
Although charity was one of several stated purposes for which the corporation was incorporated, it was but one of a group of purposes distinguishable from one another. The other purposes were religious, scientific, literary, and educational. However, there was insufficient evidence that religion, charity, and education were the chief components of the corporation's purposes because the corporation was organized for the all-encompassing purpose to help people with life in general. Specifically, the corporation was organized for the stated purpose to assist those who sought inner knowledge and personal growth in the pursuit of peace, health, and happiness through meditation, yoga, and spiritual living.
The court noted that if the corporation's stated purposes constituted charity, this would expand the definition of charity nearly beyond all bounds, in such a way that helping people with almost any mental activity would qualify for charity. There was no indication that the Legislature intended to expand the charitable exemption quite so broadly as the corporation proposed. Overall, the corporation was just as much a bed and breakfast, a yoga center, a place to walk in the woods, and a center for learning meditation as it was a charity.
The corporation was also denied a religious exemption because its articles of incorporation did not confirm that its overall nature was religious. The court concluded that the corporation's principles and teaching were as much philosophy as religion. Although the corporation did engage in teaching of some beliefs, it was at least equally engaged in teaching practices such as yoga and meditation.