Cite as: 520 U. S. 564 (1997)
Opinion of the Court
William L. Plouffe argued the cause and filed a brief for respondents.*
Justice Stevens delivered the opinion of the Court.
The question presented is whether an otherwise generally applicable state property tax violates the Commerce Clause of the United States Constitution, Art. I, § 8, cl. 3, because its exemption for property owned by charitable institutions excludes organizations operated principally for the benefit of nonresidents.
I
Petitioner is a Maine nonprofit corporation that operates a summer camp for the benefit of children of the Christian Science faith. The regimen at the camp includes supervised prayer, meditation, and church services designed to help the children grow spiritually and physically in accordance with the tenets of their religion. App. 40-41. About 95 percent of the campers are not residents of Maine. Id., at 44.
The camp is located in the town of Harrison (Town); it occupies 180 acres on the shores of a lake about 40 miles northwest of Portland. Brief for Respondents 4, and n. 6. Petitioner's revenues include camper tuition averaging about $400 per week for each student, contributions from private donors, and income from a "modest endowment." App. 42, 51. In recent years, the camp has had an annual operating deficit of approximately $175,000. Id., at 41. From 1989 to 1991, it paid over $20,000 in real estate and personal property taxes each year.1 Id., at 42-43.
*Briefs of amici curiae urging reversal were filed for the American Council on Education et al. by Sheldon Elliot Steinbach, Carter G. Phillips, Nathan C. Sheers, and Adam Yarmolinsky; and for the Christian Legal Society et al. by James C. Geoly, Kevin R. Gustafson, and Steven T. McFarland.
1 Most of petitioner's tax bill was for real estate taxes. See, e. g., App. 43 (petitioner paid 1991 real estate taxes of $20,770.71 and personal property taxes of $994.70).
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