American Sunday School Union v. City of Philadelphia

Citations

• 161 Pa. 307
• 29 A. 26
• 1894 Pa. LEXIS 690

Syllabus

<p>Taxation — Exemption—Charity—American Sunday School Union.</p> <p>A society organized as an institution of purely public charity, and as such exempt from taxation, may, as an aid to the accomplishment of its primary object, carry on business, or use part of its property for a business purpose, which will render such business or such part of its property taxable.</p> <p>The American Sunday School Union was organized for “ the erection and maintenance of Sunday schools, and the publication and circulation of moral and religious publications.” It had no capital stock, and divided no profits. It owned a large building fronting on an important business street, where, in addition to the work of its organization, it conducted a book store for profit. The profits thus made were devoted to the charitable work of the society. Held that the society was not exempt from taxation on the portion of its property used for commercial purposes.</p> <p>Apportionment — Board of Revision — Appeal—Review.</p> <p>On a bill in equity to restrain a city from collecting a tax on property owned by a charitable institution, the court will not determine whether the proportions exempt and taxable have been correctly ascertained. Such a question can only be heard on appeal from the decision of the Board of Revision of Taxes.</p> <p>Mr. Justice Williams filed a dissenting opinion.</p>