The Phillipsburg RiverviewOrganization, Inc. (“PRO”), a qualified non-profit corporation dedicated to the protection of natural resources and inappropriate land use, was denied a
property tax exemption by the New Jersey Tax Court.  The case is a reminder to local tax assessors that tax exempt property must be actually and exclusively devoted to the
purpose of the non-profit corporation.

The Tax Court ruled that only 100 square feet of PRO’s building qualified for tax
exemption because the balance of the 5500 square foot building was leased to
for-profit entities that pay rent to PRO. Upholding a line of New Jersey
tax exemption cases regarding non-profits, the PRO case teaches that ownership
alone is not a proper basis for a tax exemption.