A Michigan court ruled that an undeveloped tract of church-owned property on which a sanctuary was about to be constructed was not exempt from state property taxation under a Michigan statute exempting "houses of public worship … used predominantly for religious services or for teaching of religious truths …."
The court concluded that "actual use of a building, not merely preparation for construction or even initiation of actual construction, is a prerequisite to an exemption from taxation" under the Michigan statute" since "by the statute's own terms, a prerequisite to an exemption is that the house of public worship be used predominantly for religious services or for teaching the religious truths and beliefs."
The court rejected contrary rulings in other states with the observation that such rulings were "based on the particular language of those states' exemption statutes." St. Paul Lutheran Church v. City of Riverview, 418 N.W.2d 412 (Mich. App. 1987)