Defendants, relying on City of Mattoon v. Graham, 386 Ill. 180, The Oak Park Club v. Lindheimer, 369 Ill. 462, Turnverein "Lincoln" v. Board of Appeals, 358 Ill. 135, and People ex rel. Baldwin v. Withers Home, 312 Ill. 136, contend that if property is let for a return, it is used for profit and so far as its liability to the burden of taxation is concerned, it is immaterial whether the owner actually makes a profit or sustains a loss. Plaintiffs relying on People ex rel. Goodman v. University of Illinois Foundation, 388 Ill. 363, and People ex rel. Hesterman v. North Central College, 336 Ill. 263, contend that the property must be leased "with a view to profit" and that the "mere fact that a part of the enterprise yields an income — incidental profit — is but of little importance." 388 Ill. at 374.

Given that residence facilities have, on occasion, qualified for exemption from taxation under the school exemption (see People ex rel. Goodman v. University of Illinois Foundation (1944), 388 Ill. 363, 368 (student dormitories on university campus); Monticello Female Seminary v. People (1883), 106 Ill. 398, 400 (house occupied by superintendent of grounds at seminary); People ex rel. Pearsall v. Catholic Bishop (1924), 311 Ill. 11, 13-14 (gardener's residence, archbishop's summer home and a student dormitory at seminary); People ex rel. Hestermanv. North Central College (1929), 336 Ill. 263, 266 (student dormitories at college)), we cannot say that a parsonage could never qualify for exemption as property used exclusively for religious purposes solely because it is also used for residential purposes. (See generally Taxation: Exemption of Parsonage or Residence of Minister, Priest, Rabbi or Other Church Personnel, Annot., 55 A.L.R.3d 356, 378-79 (1974).)

While we have been unable to find a case precisely in point, our view finds support in many other jurisdictions. ( Yale University v. Town of New Haven (1899), 71 Conn. 316 [42 A. 89, 43 L.R.A. 490]; Chicago v. University of Chicago (1907), 228 Ill. 605 [81 N.E. 1138, 10 Ann.Cas. 669]; In re Syracuse University (1925), 124 Misc. 788 [209 N.Y.S. 329], affd. 214 App. Div. 375 [212 N.Y.S. 253]; Hoboken v. Division of Tax Appeals (1946), 134 N.J.L. 594 [ 49 A.2d 587]; Albuquerque Alumnae Assn. v. Tierney (1933), 37 N.M. 156 [ 20 P.2d 267]; People ex rel. Hesterman v. North Central College (1929), 336 Ill. 263 [ 168 N.E. 269]; People ex rel. Goodman v. University of Illinois Foundation (1944), 338 Ill. 363 [ 58 N.E.2d 33].) We therefore conclude that the trial court should have found that all of the properties in dispute here were entitled to the exemption from the taxes levied and collected by the respondents.

Dormitories established by a college for the use of all students may well be and have been exempted in this and other States. ( Matter of Syracuse University, 214 A.D. 375; People ex rel. Trustees v. Mezger, 98 A.D. 237, affd. 181 N.Y. 511; St. Barbara's R.C. Church v. City of New York, 243 A.D. 371; The People v. North Central College, 336 Ill. 263; Harvard College v. Cambridge, 175 Mass. 145; Yale University v. New Haven, 71 Conn. 316.) In these cases, the dormitories were devoted to all students.

Accordingly, we have held student dormitories, dining halls, and recreation facilities tax exempt as properly parts of the educational facilities of particular schools. ( People ex rel. Goodman v. University of Illinois Foundation, 388 Ill. 363; People ex rel. Hesterman v. North Central College, 336 Ill. 263.) On the other hand though, "Statutes exempting property from taxation must be strictly construed and cannot be extended by judicial interpretation.

In numerous other cases property owned by schools, not used for instructional purposes but used for student dormitories and dining rooms exclusively on a fee basis, has been held tax exempt as being used "exclusively for school purposes." School of Domestic Arts and Science v. Carr, 322 Ill. 562, and cases cited; People ex rel. Hesterman v. North Central College, 336 Ill. 263; People ex rel. Goodman v. U. of I. Foundation, 388 Ill. 363. It is our conclusion that the statutes here challenged are definitely within the constitutional power of the legislature and validly exempt property used exclusively for cemetery purposes within the meaning and intention of the makers of the constitution.

Here, as in the cases cited, the residential use is primary; other uses are incidental. Different factual situations were presented in People ex rel. Hesterman v. North Central College, 336 Ill. 263, and People ex rel. Goodman v. University of Illinois Foundation, 388 Ill. 363. In the former, two properties used as college dormitories and dining halls were exempted from taxation.

The distinction between investment and direct use for an exempt purpose has been well stated in Wehrle Foundation v. Evatt, 141 Ohio St. 467, where the court held that property which is used to produce income to be used exclusively for charitable purposes may not be exempted from taxation, the test being, instead, the present use of the property rather than the ultimate use of the proceeds derived from the property. To the same effect are People ex rel. Goodman v. University of Illinois Foundation, 388 Ill. 363, and People ex rel. Hesterman v. North Central College, 336 Ill. 263. In our opinion the evidence clearly supports the trial court finding of the acreage utilized for airport operations and acreage devoted to farming.

The distinction between investment and direct use for an exempt purpose has been well stated in Wehrle Foundation v. Evatt, 141 Ohio St. 467, where the court held that property which is used to produce income to be used exclusively for charitable purposes may not be exempted from taxation, the test being, instead, the present use of the property rather than the ultimate use of the proceeds derived from the property sought to be exempted. To the same effect is People ex rel. Hesterman v. North Central College, 336 Ill. 263, where this court held that the phrase in the applicable statute "with a view to profit" modifies both the word "leased" and the word "used" and, hence, that leasing, alone, does not divest property of its exempt character unless it be with a view to profit. Application of these tests to the case at bar discloses that the present use of each of the four properties is for at least one exempt purpose, namely, public education.

This court has consistently refused to make any distinction between public schools and private schools with reference to taxation of their property. ( People v. North Central College, 336 Ill. 263; People v. University of Illinois, 357 id. 369.) We have heretofore held that the primary use to which property is devoted by a school, whether to a school use or to some use separate and apart from that of the school, is determinative of whether the property is liable for taxation.