Appeal from the Order of the Court of Common Pleas of Monroe County in case of Scripture Union, a Pennsylvania Non-Profit Corporation v. John R. Deitch, Martin A. Holmes, Catherine D. Granger, and Board of Assessment Appeals of Delaware County, No. 84-16184.
Benjamin S. Ohrenstein, for appellant.
Joseph R. Young, Beatty, Young, Clouse & Lincke, for appellee, Upper Darby School District.
A. Leo Sereni, for appellee, Delaware County Board of Assessment Appeals.
Alvin S. Ackerman, Fronefield & DeFuria, for appellee, Township of Upper Darby.
Judges MacPhail and Barry, and Senior Judge Blatt, sitting as a panel of three. Opinion by Judge MacPhail.
[ 109 Pa. Commw. Page 274]
Scripture Union has appealed from an order of the Court of Common Pleas of Delaware County which denied Scripture Union's request for tax exempt status for an office building which it owns in the Township of Upper Darby, Delaware County. We affirm.
Scripture Union is a non-profit corporation which distributes bi-monthly publications which include a daily guided reading program and commentary on the scriptures. The organization also counsels interested Christian churches in the operation of their youth programs and supports other Scripture Union ministries in foreign countries. Its main publications are distributed to approximately ten to twelve thousand individual members and 700 churches across the country. Scripture Union is not associated with any organized religion and does not regard itself as a religious organization.
The threshold issue in this case is whether Scripture Union qualifies as a "purely public charity" so as to satisfy the initial requirement in establishing its entitlement to a real estate tax exemption under Section 204(a)(3) of The General County Assessment Law (Law)*fn1 which provides, in pertinent part, as follows:
[ 109 Pa. Commw. Page 275]
The following property shall be exempt from all county, city, borough, town, township, road, poor and school tax, to wit:
(3) All hospitals, universities, colleges, seminaries, academies, associations and institutions of learning, benevolence or charity . . . founded, endowed, and ...