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Westfield Organization Fights Tax Exemption Denial

A sign outside Journey Inn Ministries T.A.J.E is pictured.

A Westfield non-profit is fighting the town’s decision to deny a property tax exemption.

Journey’s Inn Inc., also known as Journey Inn Ministries T.A.J.E (Journey Inn), filed an Article 78 petition in late July after the town of Westfield’s assessor denied a tax exemption for four parcels in Westfield that include a large dwelling, known as the Yellow House, and several barns and outbuildings. Journey Inn Ministries officials said the entire parcel will directly support its ministry to help people live healthier lives and walk in Godly principles.

The organization had been seeking a 420-a tax exemption, which provides real property tax exemption to nonprofit organizations whose property is used exclusively for religious, charitable, educational, hospital, or mental/moral improvement purposes. To qualify, the organization must be a nonprofit entity, and the property must be solely dedicated to these exempt purposes; any portion used for other purposes or profit is taxable.

Ministry officials say the entire property supports Journey Inn Ministries’ work, while town officials have denied the application saying the use of the property through late February was insufficient to satisfy the requirement of exclusive use needed to approve the tax exemption, said the property was supporting for-profit enterprises that included cat breeding and graphic arts – an allegation the ministry denies.

“Similarly here, the town’s denial of Journey Inn’s application lacks a rational basis and should be annulled,” attorney Christine Bacon argued on the ministry’s behalf in a July 31 memorandum. “The stated reason for the denial is that the property’s current actual use is insufficient to satisfy the statutory requirement of exclusive use. Yet the town has offered no rational basis for this conclusion, which lacks evidentiary support. By contrast Journey Inn produced voluminous documentation to justify exemption, as discussed above.”

Formerly known as the Gold Brook Farm, the property operated as a bed and breakfast before Journey Inn Ministries purchased it. The non-profit honored pre-existing reservations for the April 8, 2024, solar eclipse and said the use as a bed and breakfast was a one-time event. Town officials say otherwise. Joel Seachrist, the attorney representing the town, said former assessor Bonnie Strickland and assessor trainee Ken Shearer found instances on the Journey Inn/Gold Brook Farm website and Facebook pages that indicated future bookings were being accepted after April 24; a May 3, 2024, post showing a cat in a “Roan Room” under renovation with inquiries accepted for “pricing and rates” and active promotion of Balinese cat breeding through Moon Acre Manor Cattery including pricing and availability details. Strickland also filed an affidavit saying the Journey Inn/Gold Brook Farm website remained active after the June 14, 2025, Board of Assessment Review meeting, though the reservation function was removed after the meeting, according to Strickland. The assessors repeatedly denied the tax exemption because the property’s main use wasn’t for tax-exempt purposes, serving primarily, the assessors said, as a private residence or potential bed and breakfast.

“While the respondents do not dispute the petitioner’s 501(c)(3) status or minor renovations, the exemption requires actual use of the property for exempt purposes at the time of the application,” Seachrist wrote in his memorandum. “Petitioner’s application fails to meet this burden. Petitioner’s applications primarily describe prospective, future programs, such as combining Bible studies with equine activities, organic farming and various classes, with timelines indicating programs would begin in 6 to 12 months and full operations within two years. Current activities are minimal: three Bible study groups in 2024, produce donations and one poetry class in 2025. These do not constitute primary use of the entire 78-acre property, including dwellings, barns and land, for exempt purposes.”

Journey Inn Ministries officials replied in their own memorandum of law that the cattery was related to Arizona properties and had never been a use of the Westfield property, while the bookings for bed and breakfast rooms hadn’t been used despite availability on the Gold Brook Farms website while the two organizations were merging websites. An attempt to book a room would have been unsuccessful despite the booking availability on the organization’s website, Bacon wrote.

Journey Inn Ministries officials are asking state Supreme Court Justice Grace Hanlon to annul the town’s denial of the Section 420-a tax exemption, declare the property is entitled to full exemptions, direct Westfield to reflect the exemption in town records and the town’s 2025 assessment role, award Journey Inn Ministries costs, disbursements and attorneys fees as well as any further relief the court finds proper.

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