Ocean Grove Camp Meeting Offices Tax Exempt

by: Joseph Grather
10 Mar 2021

I don’t often venture over to the tax appeal side of things here at McKirdy Riskin, but I have always been fascinated by the Ocean Grove Camp Meeting Ass’n that is the subject of a recent tax court opinion authored by Judge Sundar (March 4, 2021 opinion is available here).  I would suggest a full read of the opinion if only to learn about the history of the Methodist Church’s founding of the “Christian seaside resort” back in 1869.

Photo credit – JWG 11/15/2016.

The Great Auditorium pictured above was built in 1894, seats 7,000 and is a “national landmark.”  Clustered around the Great Auditorium are permanent “tents and cottages”.  What is truly amazing is that most tenters only pay $10.50 per year based on a 99-year ground lease.  $10.50 a year one block off the Atlantic Ocean!  (There must be a waiting list).

Returning to the case, the Township terminated the Association’s tax-exempt status in 2016 and the Association appealed in the Tax Court to challenge that determination for the tax years 2017 and 2018.  The contentions of the parties were aptly summarized by Judge Sundar:

“The Township argues that plaintiff is not a religious institution or a church but an independent affiliate, which exists and operates without any control by or direction from the
United Methodist Church or any other Higher Order. Therefore, the Township contends, it is not organized for any specific tax-exempt purpose. Plaintiff counters that the special legislation,
its mission statement, charter, and By-Laws, are sufficient evidence that its incorporation fits into either the Religious/Charitable Clause or the MMI Clause.” Slip op. at 12.

The court agreed with the Association in a thoughtful and well-reasoned opinion.  Again, the full opinion is worthy of a read.