Skip universal navigation

New York State Universal header

Skip to main content

Volume 10 - Opinions of Counsel SBRPS No. 115

Opinions of Counsel index

Nonprofit organizations exemption (youth sportsmanship) (general) - Real Property Tax Law, § 420-b:

Property owned by corporations or associations organized exclusively for the development of good sportsmanship for persons under the age of eighteen years (e.g., Little League) is tax exempt pursuant to section 420-b of the RPTL, provided the municipality has not opted to tax such organizations and provided further that the other statutory requirements (e.g., property use) are satisfied. [4 Op.Counsel SBEA No. 90 and 6 Op.Counsel SBEA No. 17 superseded]

We have been asked whether the property of an incorporated youth athletic association may qualify for a real property tax exemption pursuant to section 420-b of the Real Property Tax Law. The requestor cites two of our Opinions of Counsel (i.e., 4 Op.Counsel SBEA No. 90 and 6 Op.Counsel SBEA No. 17), in which we opined that Little Leagues could not qualify for exemption pursuant to then section 420 of the RPTL, and asks if they are still accurate. Because of statutory changes, they are not.

That is, the two cited opinions were written in 1975 and 1977, respectively. In 1980, chapter 904 added a new section 476 to the RPTL, specifically authorizing an exemption for property owned by corporations or associations organized or conducted exclusively for “the development of good sportsmanship for persons under the age of eighteen years.” The following year, the quoted phrase was included in the newly denominated section 420-b of the RPTL (L.1981, c.919, §6) and the no longer necessary section 476 was repealed (id., §7). {1}

Accordingly, unless a municipality which uses the assessment roll for its tax purposes has adopted a local law, ordinance or resolution to withdraw the exemption now otherwise available to this type of organization (e.g., Little League), the youth athletic association may receive exemption pursuant to section 420-b of the RPTL, provided it satisfies the various statutory criteria for that exemption (e.g., organizational purpose, property use).

October 30, 2000


{1}  Chapter 414 of the Laws of 1971 split the statutory list of categories of nonprofit organizations entitled to tax exemption into two: a mandatorily exempt group and a second group also entitled to exemption unless some or all of such group were made taxable by a municipality. Chapter 919 of the Laws of 1981 further distinguished the two groups by separating them into two sections of the RPTL: section 420-a (mandatory class) and section 420-b (permissive class).

Updated: