Appeal, No. 132, March T., 1961, from order of Court of Common Pleas of Allegheny County, April T., 1960, No. 2661, in case of Pittsburgh Bible Institute v. Board of Property Assessment, Appeals and Review. Order, as modified, affirmed.
Philip Baskin, Special Counsel, with him Frank J. Zappala, Jr., Assistant County Solicitor, and Maurice Louik, County Solicitor, for Board of Property Assessment, Appeals and Review, appellant.
H. Stewart Dunn, with him Bechman, Dunn & McGregor, for appellee.
Before Bell, C.j., Musmanno, Jones, Cohen, Eagen, and Alpern, JJ.
OPINION BY MR. JUSTICE EAGEN.
This is an appeal from a decision and order of the Court of Common Pleas of Allegheny County which ruled that the property of the Pittsburgh Bible Institute is totally exempt from real estate assessment and taxation. A tax assessment levied against a portion
of the property for the years 1959, 1960 and 1961 by the Board of Property Assessment, Appeals and Review, was declared by the court to be invalid.
The Pittsburgh Bible Institute is an unincorporated nonprofit association. Its object is "[To] give an opportunity to all who may desire to gain a thorough and practical knowledge of the Word of God and of methods of Christian work; to train those who desire to enter the Ministry; to prepare Missionaries for City, Home, or Foreign Fields; to instruct Bible Teachers and Christian Workers; to enable theological students to devote themselves for a season exclusively to the study of the Bible and to the winning of souls; further, to prepare students to read both the Old and New Testaments in the original languages, and to train in prayer and for all forms of Christian activity."
More than 1500 students have been enrolled in the Institute since its founding. In the years 1958, 1959 and 1960, a total of 12, 8, and 9 students, respectively, enjoyed the facilities provided.
The Institute began to acquire its present property in the year 1912. It consists of approximately 420 acres, including 175 acres of cultivated farm land, and 120 acres of timberland. All of the farm work is performed by students of the Institute and its personnel. The farm products are used principally to provide maintenance for students and others associated in the work of the Institute. A portion is used to supplement the maintenance of the Buelah Home, Bellevue, Pennsylvania, a residence for returned missionaries. Buildings, including men's and women's dormitories, an administration building and a ...