Exempt Purpose Tied to Religious Activity
In Camp Retreats Foundation, Inc. v. Township of Marathon, Michigan Court of Appeals, No. 304179, May 15, 2012, a Michigan nonprofit organization's camp retreats facility was entitled to a local charitable institution property tax exemption because the property's primary use focused on bringing people's minds or hearts under the influence of religion, and it offered this charity on a nondiscriminatory basis. The organization bought the property specifically intending to create a camp for use by people of the Muslim faith and created a facility particularly suitable for that use. Despite the organization's articles of incorporation, which placed emphasis on athletic activities for youth, the camp facility's central focus was on providing the Islamic community with religious experience in a camp environment. Participants either had a personal connection to the two directors who were both Muslim or were tied to Muslim groups or activities.
The camp facility's recreational opportunities also furthered religious purposes by inextricably interweaving Islamic worship and observance into the camp's daily programs. In addition, no evidence supported the Tax Tribunal's finding that the general public was prevented from attending programs at the camp facility. To the contrary, the testimony established that the organization welcomed participants of every faith, as well as atheists. The presence of fences on the property and signs warning against trespassing bore no relationship to whether the camp facility offered its charity generally and without restriction.