This is an appeal by Kootenai County from a district court judgment granting a tax exemption to property owned by the respondent, a religious corporation, and used primarily as a summer church camp for training children in handicraft, water skiing, boating and water safety.
The pertinent facts of those stipulated by the parties are. as follows: The Upper Columbia Mission Society of Seventh Day Adventists, plaintiff-respondent herein, is a Washington corporation, incorporated in the State of Washington on February 24, 1898, and authorized to do business in the State of Idaho since 1949. The articles of incorporation provide that:
“The objects of said corporation shall be the organization, establishment and maintenance of mission and church societies to teach, spread and promulgate the Christian religion and morality in accordance with the teachings of the Seventh-Day Adventists: and to erect and assist in erecting church edifices for such societies when established: and to build and assist in building structures for educational, charitable and benevolent purposes throughout eastern Oregon,
Washington, Idaho and British Columbia and to said end to own, hold, mortgage, sell and convey property of every kind and description, and to do all other things incidental to the accomplishments of the aforesaid purposes.”
The respondent corporation owns two lots of real property located at Hayden Lake in Kootenai County. Situated on the property are 18 to 20 buildings consisting of sleeping quarters, dining facilities and other buildings. The property is primarily used as a summer encampment for children who receive training in handicraft, water skiing, boating and water safety, through formal classes. They also receive religious training. During the hours when classes are not held, the facilities are available for swimming and boating. A registration fee of $19.00 is charged for each of the campers attending the camp, and the program is available not only to members of the Seventh Day Adventists religion, but also to any other children who desire to register for the camp. However, all campers are required to attend the religion classes. The camp has never been operated at a profit and in 1963 the net loss for the encampment was $7,795.58. During the days in the summer when the camp does not have organized operations, the facilities are open to ministers and church teachers who meet for educational classes and to take advantage of the camp’s recreational facilities.
In 1963 the Kootenai County Assessor placed the two lots on the tax rolls and sent respondent a statement for 1963 real property taxes in the amount of $890.74. Two open air chapels and the acre of ground upon which they were situated were exempted from the rolls for taxation purposes. The respondent paid the taxes under protest and appealed the assessor’s action. The County Commissioners of Kootenai County, sitting as a Board of Equalization, denied the protest and appeal. Respondent then appealed to the State Tax Commission which, after hearing on the case, affirmed the Board’s holding. From that decision, respondent appealed to the district court.
The district court held that the property in question was tax exempt under I.C. § 63-105B as being property owned by a religious corporation used for religious purposes; that the property was tax exempt under I.C. § 63-105L as being owned and used for educational purposes from which no profit is derived; and that the property was tax exempt under I.C. § 63-105C as being property owned by a charitable corporation used exclusively for the purposes for which such corporation was organized. The court further held that the fact that the property is exempt from taxation pursuant to two or more provisions of the Idaho Code, does not require the legal conclusion that such property loses its exempt status, despite the use of the word *882“exclusive” by the legislature in enacting each of the separate statutory sections.
This court is of the opinion the trial court’s ruling is incorrect and the judgment entered therein must be reversed.
In granting the tax exemption, the trial court determined that respondent’s property was exempt under each of three separate statutory exemptions, I.C. §§ 63-105B, 63-105C and 63-105L. To determine the correctness of the court’s action in granting the exemptions, we must examine the facts and apply to them the requirements contained in each section of the exemption statute. It is well established that where the cause is heard in the trial court on stipulated facts and documentary 'evidence and no oral testimony is taken, so that the Supreme Court has before it all the showing that was considered by the trial court that heard and passed upon the question, then the Supreme Court is in as favorable a position to consider the matter as was the trial court and will examine and be governed by the facts disclosed, and exercise its own discretion as if the case were being presented to this court for determination in the first instance. Crumley v. Minden, 80 Idaho 391, 331 P.2d 275 (1958) ; Johnson v. Noland, 78 Idaho 642, 308 P.2d 588 (1957); Pharris v. State, 91 Idaho 456, 424 P.2d 390 (1967).
The use of the property for which an exemption is sought is clearly set out in the stipulation of facts signed by both parties. The stipulation states: “The property is primarily used as a summer encampment for children and the children are trained in handicraft, water skiing, boating, water safety, through formal classes. During the hours when formal classes are not conducted, facilities are available for swimming and boating. Classes are also conducted in religious training.”
As so used, the property does not qualify for a tax exemption under I.C. § 63-105B.1 The property is used primarily as a recreational summer camp for children, and as such, does not constitute “property * * * used exclusively for and in connection with public worship.” (emphasis added) Statutes granting tax exemptions exist only as a matter of legislative grace, and by statutory mandate must be strictly construed. I.C. § 63-101; Sunset Memorial Gardens v. Idaho State Tax Commission, 80 Idaho 206, 327 P.2d 776 (1958). As this court stated in Malad Second Ward of the Church v. State Tax Commission, 75 Idaho 162, 269 P.2d 1077 (1954).:
“Churches and other religious institutions, fraternal, benevolent or charitable corporations or societies enjoy no inherent right to exemption from taxation; and their property is taxable except insofar as it is specifically exempt by constitutional provision or statutory enactment. There is no presumption or implied exemption from taxation in their favor; and all property within the State is liable to taxation unless expressly exempt. Where an exemption is claimed, the property to be exempt must be clearly defined and founded upon plain language, without doubt or ambiguity, and must come within the plain wording of the statute.
“A statute granting tax exemption to certain institutions under prescribed conditions is to be strictly construed and cannot be extended by judicial construction so as to create an exemption not specifically authorized.
“In Bistline v. Bassett, 47 Idaho 66, 272 P. 696, 697, 62 A.L.R. 323, this Court held:
“ ‘Exemptions are never presumed. The burden is on a claimant to establish *883clearly a right to exemption. An alleged grant of exemption will be strictly construed. It must be in terms so specific and certain as to leave no room for doubt.’
“Other authorities to the same effect are: Salisbury v. Lane, 7 Idaho 370, 63 P. 383; Cheney v. Minidoka County, 26 Idaho 471, 144 P. 343; Kootenai County v. Seven-Seven Co., 32 Idaho 301, 182 P. 529; Andrews v. North Side Canal Co., 52 Idaho 117, 12 P.2d 263; State v. Union Congregational Church, 173 Minn. 40, 216 N.W. 326; Cooley on Taxation, 4th Ed., p. 1403, Sec. 672 ; 61 C.J. 392, Sec. 396; 84 C.J.S., Taxation, § 227; 51 Am.Jur. 526, Sec. 524.” 75 Idaho 165, 166, 169 P.2d 1079.
See Herndon v. West, 87 Idaho 335, 393 P.2d 35 (1964).
Thus, unless we are to overrule or depart from these precedents, I.C. § 63-105B must be construed strictly. The statute provides primarily for the exemption of property “used exclusively for and in connection with public worship.” The assessor fully complied with this provision by exempting the two open air chapels and the acre of ground upon which they were situate. To this primary exemption there have been only two extensions granted by the legislature, i. e., (1) “any parsonage * * * occupied as such” and (2) “any recreational hall belonging to and used in connection with the activities of such corporation or society.” Neither types of buildings are involved herein. Furthermore, had the legislature intended the exemption of summer recreational church-camps, it could have, and still can, so provide just as it did for recreational halls. Such extensions should come, however, from action by the legislature and not by judicial fiat. Malad Second Ward, etc. v. State Tax Comm., supra.
As to I.C. § 63-105L2 and again applying the Idaho rule of strict construction, although we do not think that formal classes in handicraft, water skiing, boating, and water safety nor the daily religious classes satisfy the educational purpose requirement of the statute, we need not and do not decide this issue. It is apparent from the stipulation of facts that the property is not used exclusively for educational purposes as is required by the statute. The property is used for recreational purposes both by children and adults, and therefore, the property in question fails to qualify for a tax exemption under this statute.
Again applying the strict construction rule to I.C. § 63-105C,3 under which the lower court also found the property ex*884empt, there is nothing in the record that indicates that the respondent corporation is a fraternal, benevolent, or charitable corporation, despite the language in respondent’s Articles of Incorporation which reads: “and to build and assist in building structures for educational, charitable and benevolent purposes.” Moreover, even if we assume that the respondent qualifies as such a corporation, there is no evidence in the record that the property is exclusively used for the purposes for which the corporation or society was organized.
The lower court concluded that the recreational aspects of the camp are specifically authorized by the articles of incorporation by the catch-all phrase at the end of the “objects” paragraph, i. e., “to do all other things incidental to the accomplishment of the aforesaid purposes.” Bearing in mind that the primary use of the property, under the stipulation, was “as a summer encampment for children * * * ” where the children would receive training in handicraft, water skiing, boating, and water safety, as well as religious training, the foregoing conclusion is erroneous. Thus, the property also fails to qualify for a tax exemption under I.C. § 63-105C.
This decision makes unnecessary any disposition of appellant’s other assignments of error.
Judgment of the district court reversed, and the cause remanded for the trial court to enter judgment for the 1963 taxes in the amount of $890.74 plus interest. Costs to appellant.
McFADDEN, C. J., and WARD, District Judge, concur.. “63-105B. Property exempt from taxation — Religious corporations or societies. —The following property is exempt from taxation: Property belonging to any religious corporation or society of this state, used exclusively for and in conneetion with public worship, and any parsonage belonging to such corporation or society and occupied as such, and any recreational hall belonging to and used in connection with the activities of such corporation or society.”
. “63-105L. Property exempt from taxation — Property used for school or educational purposes. — The following property is exempt from taxation: All property used exclusively by the owner for (for) school or educational purposes, from which no profit is derived, and all property from which no profit or rental is derived and which is held or used exclusively for endowment, building or maintenance purposes of schools or educational institutions.”
. “63-1050. Property exempt from taxation — Fraternal, "benevolent, or charitable corporation or societies. — The following property is exempt from taxation: Property belonging to any fraternal, benevolent, or charitable corporation or society, the World War veterans organization buildings and memorials of this state, used exclusively for the purposes for which such corporation or society is organized ; provided, that if any building or property belonging to any such corporation or society is leased by such owner or if such corporation or society uses such property for business, purposes from which a revenue is derived, then the same shall be assessed and taxed as any other property, and if any such property is leased in part or used in part by such corporation or society for commercial purposes the assessor shall determine the value- of the entire building and assess such proportionate part of such building including the value of the real estate as is so leased or used for commercial purposes, and shall assess all merchandise kept for sale, and the trade fixtures used in connection with the sale of such merchandise.”