34 N.Y.2d 143 (1974)
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An organization’s activities must be primarily charitable or educational, not merely incidentally beneficial to the public, to qualify for real property tax exemption under New York law.
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Summary
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The Association of the Bar of the City of New York and the Explorers Club challenged the City of New York’s decision to revoke their real property tax exemptions. The Court of Appeals held that neither organization qualified for the exemption because their primary purposes were not charitable or educational. The Bar Association primarily served its members’ professional interests, and the Explorers Club primarily promoted scientific exploration. The court also upheld the constitutionality of the state law allowing local governments to terminate exemptions for certain non-profit organizations.
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Facts
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The Association of the Bar of the City of New York, incorporated in 1871, aimed to cultivate jurisprudence, reform law, facilitate justice, and elevate the legal profession’s standards. Its activities included maintaining a law library, evaluating judicial candidates, addressing lawyer misconduct, reviewing legislation, and offering legal education programs. The Explorers Club, founded in 1905, focused on furthering exploration knowledge and maintaining a related library and map collection. It supported geographic exploration and research, provided education and counseling, and funded conservation projects. Both organizations had previously enjoyed real property tax exemptions.r
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Procedural History
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The City of New York, acting under state law (Real Property Tax Law § 421), revoked the real property tax exemptions for the Bar Association and the Explorers Club. Both organizations challenged this decision. The Appellate Division initially sustained the organizations’ entitlement to the exemption. This appeal followed, with the Court of Appeals reversing the lower court’s decision and upholding the city’s action.r
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Issue(s)
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1. Whether the properties of the Association of the Bar of the City of New York and the Explorers Club qualify for real property tax exemptions as charitable or educational organizations.r
2. If not, whether the state legislation permitting the revocation of these exemptions violates due process or equal protection.r
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Holding
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1. No, because neither organization is primarily organized and conducted for charitable or educational purposes; their activities, while beneficial, are incidental to their primary purposes.r
2. No, because the state has broad discretion in taxation, and the classification is rationally related to the legitimate state interest in preventing erosion of municipal tax bases.r
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Court’s Reasoning
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The Court reasoned that to qualify for a property tax exemption, an organization must be organized and operated exclusively for religious, charitable, hospital, educational, or cemetery purposes. While the term