Humboldt Field Research Inst. v. Town of Steuben

Humboldt Field Research Institute and Eagle Hill foundation applied for a property tax exemption pursuant to Me. Rev. Stat. 36, 652(1)(A) and (B), which the Town assessors denied. The county commissioners upheld the Town's denial, and the superior court affirmed. Humboldt and Eagle Hill appealed, arguing (1) the Town was required to continue Humboldt's and Eagle Hill's tax exemptions from the prior year, which were based on their status as charitable institutions, absent evidence of an organizational change; and (2) the organizations were exempt as literary and scientific institutions. The Supreme Court affirmed, holding (1) Maine law consistently places the burden on the taxpayer to prove entitlement to a tax exemption, even when an exemption has been granted in prior years, if the assessor challenges the exemption; and (2) the commissioners did not err in determining that Humboldt and Eagle Hill did not meet their burden to prove entitlement to an exemption.