Gourmet Dining operated a “high-end” restaurant out of a building on the campus of Kean University. When Union Township issued tax assessments to the restaurant, Gourmet Dining appealed to the Tax Court. Gourmet argued that it was exempt. The Appellate Division ruled that the tax exemption provisions in issue were not intended to exempt the for-profit operator of a high-end restaurant situated on a college campus when the overriding purpose of the commercial endeavor was focused on profitmaking.