A Florida state court ruled that a church-owned unimproved lot was exempt from real estate taxes.
The court observed that "while the land was substantially vacant and unimproved and was not used by the church continuously, nevertheless, the land was being actually and presently used by the church for religious purposes sporadically and improvements and greater physical use were planned.
The church's present religious use of the property, while not evidenced by improvements and not continuous, was exclusive of any other use and was not incidental to any nonexempt use." Hausman v. First Baptist Church, 513 So.2d 767 (Fla. App. 1987)