The applicant church sought a declaration that its single-building complex, which housed both a place of worship and a religious school, was exempt from property taxation under the Assessment Act.
The respondent assessment corporation argued that the school portions were taxable because the school was operated by a separately incorporated entity.
The court found that the church and the school formed a single patrimony, with the church controlling and dominating the school's operations.
The court held that the exemptions for a place of worship and a non-profit educational seminary applied to the school-use areas, granting the application.