
    State Board Tax Appeals.
    CITY OF JERSEY CITY, PETITIONER, v. BETH-EL BAPTIST CHURCH, RESPONDENT.
    Decided April 2, 1940.
    For the petitioner, James A. Hamill (by Frank P. McCarthy).
    
    For the respondent, David Silver.
    
   Quinn, President.

Respondent is a religious corporation of this state and is the owner of a two-family frame structure in the petitioner taxing district, which duly assessed the land and building for taxes- for the year 1938. On appeal, the Hudson County Board of Taxation canceled the assessment, and petitioner herewith appeals from that determination.

Tlie proof before us is clear to the effect that the first floor of this property is exclusively devoted to the uses of a house of worship by the church, and that the second story is employed as a dwelling for its minister.

The statute exempts from taxation buildings exclusively devoted to religious worship and those actually occupied as a parsonage by the officiating clergyman of a religious corporation of the state. Pamph. L. 1918, ch. 236, § 203 (R. S. 54:4-3.6). It does not appear to us that any principle of statutory construction should operate to deprive the respondent of the Lax exemption obviously intended by the legislature in such a situation, by mere reason of the fact that one building houses both its church and its parsonage.

The judgment of the Hudson County Board cancelling the assessment in question, should be affirmed.  