• Key point. Undeveloped land owned by a church for future use may not be exempt from property tax under a statute exempting property used exclusively for religious purposes.

A Connecticut court ruled that an undeveloped tract of land owned by a church was not entitled to exemption from property taxation since it was not used exclusively for religious purposes. The church property was an unimproved, wooded lot that contained no structures or buildings other than a volleyball court. The court noted that the state property tax law exempts property belonging to a religious organization that is not in actual use for religious purposes because of “the absence of suitable buildings and improvements thereon, if the construction of such buildings or improvements is in progress.” Despite the church’s assertion that the property was used for religious purposes in that “prayer walks” were occasionally conducted on the property, the court ruled that the property was not exempt because it “contains neither any building or other improvement used for charitable purposes, nor such improvements in the process of being constructed.” Grace n’ Vessels of Christ Ministries, Inc. v. City of Danbury, 733 A.2d 283 (Conn. App. 1999).

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