STRATFORD, NJ – A New Jersey Tax Court has ruled in favor of the Greater New Jersey Annual Conference of the United Methodist Church, overturning a Camden County tax board decision that upheld an omitted property assessment for 2022.
In a decision dated August 22, Judge Mala Sundar granted the church’s motion for partial summary judgment, finding that the Borough of Stratford improperly revoked the religious exemption on the property and imposed the added assessment.
The ruling follows months of procedural back-and-forth between the borough and the conference, which had been recognized as tax-exempt for years before the assessor reversed course.
Key Points
- The Tax Court found Stratford’s 2022 omitted assessment against the United Methodist Church invalid.
- The borough claimed the church failed to return a required “Further Statement” form and was not using the property for religious purposes.
- Judge Sundar cited a prior court precedent and ruled that discovery delays did not justify withholding summary judgment.
Longstanding exemption challenged
The Greater New Jersey Annual Conference of the United Methodist Church, a federally recognized nonprofit organized for religious purposes, owns the Stratford property identified as Block 39, Lot 1. The parcel, improved with a church building, had long been classified as exempt under code 15D for “Church and Charitable Property.”
According to court records, the borough’s assessor had approved the property’s exemption for 2022. However, nearly a year after the October 2021 assessment date, the assessor sent a letter to the church requesting completion of a “Further Statement” to maintain the exemption. The letter warned that failure to respond could result in loss of the benefit.
Omitted assessment issued after no response
The church’s receipt of the letter was acknowledged by a pastor, but no form was returned. In June 2023, the assessor issued an omitted assessment for the 2022 tax year and an added assessment for 2023, claiming the property was not being “occupied for the intended use.”
The borough’s correspondence stated that conditions under N.J.S.A. 54:4-4.4 were not met, effectively revoking the exemption. The church appealed to the Camden County Board of Taxation, arguing that the $632,000 assessment and loss of exempt status were improper. The board upheld the assessor’s action.
Court finds exemption properly maintained
In her opinion, Judge Sundar ruled that the borough’s imposition of the omitted assessment was inconsistent with established law, referencing Borough of Red Bank v. RMC-Meridian Health, a 2018 Tax Court decision. She found the church’s property remained qualified for exemption and that the borough’s argument for additional discovery did not outweigh the clear record of prior exemption.
The court held that the borough had not demonstrated evidence of non-religious use sufficient to justify the omitted assessment. The decision grants partial summary judgment to the church, reversing the county board’s ruling.
Case narrows focus on procedural compliance
While the ruling resolves the 2022 omitted assessment dispute, the court noted that other issues, including a related added assessment for 2023, remain under separate consideration. The opinion underscores the narrow interpretation of procedural lapses in exemption maintenance and reaffirms protections for long-recognized religious properties in New Jersey.