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Pullman & Comley’s property tax and valuation practice increasingly includes representation of clients who are denied property tax exemptions upon initial application or whose exemptions are revoked by local assessors after enjoying them for many years.
Two recent cases – neither of which involved the law firm - are worth noting.
Simon’s Rock College in Great Barrington, Massachusetts had been an outpost of Bard College for years. In the spring of 2025, Bard ceased classroom activities at Simon’s Rock due to declining enrollment but continued to operate an athletic center which is used by members of the Great Barrington community.
With the cessation of educational activities, the Great Barrington Select Board voted to revoke the exemption. As a result, tax bills exceeding $250,000 were sent to Bard despite the local community continuing to enjoy the athletic facilities.
Interestingly, the Simons Rock property is currently assessed at $63,000,000 and is listed for sale.
In another high-profile case, emanating from Pennsylvania, the Salvation Army successfully challenged the denials of real estate tax exemptions of over a dozen parcels called the Camp Ladore Retreat and Conference Facility, which consists of a lake and hundreds of acres improved with a lodge, amphitheaters and nature trails. Since the properties in question consisted of several different assessment parcels, the major question here was whether the Salvation Army should be required to prove that each separate tax parcel, viewed in isolation, qualified for the exemption. The court ruled that since the entire property was used in furtherance of the Salvation Army’s charitable purposes, each parcel was entitled to the exemption.
While resolution of this case was based on a Pennsylvania Supreme Court decision, the idea that a charitable organization might have to prove that a holding comprised of multiple assessment parcels was exempt only if evidence could be adduced to establish that each parcel was so used could be daunting and time-consuming.
In similar circumstances, there may be a good reason for a tax-exempt organization with several parcels to combine them into one large holding which could make it less vulnerable to this sort of challenge.
Salvation Army v. Wayne County Commissioners, Commonwealth Court of Pennsylvania, July 28, 2026.
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About Our Property Tax and Valuation Law Blog
Alerts, commentary, and insights from the attorneys of Pullman & Comley’s Property Tax and Valuation practice with timely information for businesses, nonprofits and individuals in commercial property tax appeals and eminent domain matters.