SAN DIEGO, Calif.—LiMandri & Jonna LLP is pleased to announce the resolution of an administrative appeal regarding whether the Free Sacred Trinity Church, a local Christian church, can obtain a California property tax exemption for its San Diego campus.
Free Sacred Trinity Church is the “Mother Church” of a Christian denomination, founded in 1976, and presently consisting of two subsidiary “Mission” facilities based in San Diego, California and Austin, Texas. All nonprofits, including churches, are generally exempt from federal taxation under 26 U.S.C. § 501(c)(3). But whether nonprofits and churches have to pay local property taxes is a matter of state law.
In 2004, the California Department of Tax and Fee Administration initially determined that the Church did not qualify for property tax exemption because it did not fully understand the Church’s practices. In 2018, the Church applied for property tax exemption again, and again the California Department of Tax and Fee Administration denied the exemption.
LiMandri & Jonna LLP was retained to handle the administrative appeal to the California Board of Equalization due to the firm’s First Amendment practice. After consulting with the Church’s tax lawyers, in March 2021, LiMandri & Jonna filed the opening brief in the administrative appeal.
In June 2021, the Department of Tax and Fee Administration threw in the towel. Instead of litigating the appeal, California issued the property tax exemption. LiMandri & Jonna is very pleased to have obtained this quick and full win for the Free Sacred Trinity Church.