It seems they want to move into the farm. But the NY goverment is tired of having the WT dodge taxes:
As to the second question, section 420-a of the RPTL provides an exemption from taxation and certain special ad valorem levies and special assessments to real property owned by a nonprofit organization organized or conducted for one or more of the statutorily specified purposes (e.g., religious, educational) which property is used exclusively for exempt purposes. In certain circumstances, farm property owned and used by such a nonprofit organization has been determined to be entitled to such exemption (e.g., People ex rel. Watchtower Bible & Tract Society, Inc. v. Haring, 8 N.Y.2d 350, 170 N.E.2d 677, 207 N.Y.S.2d 673 (1960); Rudolf Steiner Educational and Farming Association, Inc. v. Brennan, 65 A.D.2d 868, 410 N.Y.S.2d 404 (3d Dept., 1978), app. den., 46 N.Y.2d 709, 387 N.E.2d 624, 414 N.Y.S.2d 1027 (1979)). For purposes of this opinion, we assume that the nonprofit organization is entitled to exempt status on its farm property. The answer to the second question, then, depends on the organization's use of its new property. If it continues to farm the property for at least the balance of the statutory period following the conveyance, there will be no conversion and no conversion payment. Presumably, the organization's now larger farm will continue to be eligible for a nonprofit organizations exemption. As noted above, alternatively, the nonprofit organization could make no use of the property and avoid the payment, but then it might not qualify for a nonprofit organizations exemption due to lack of use (RPTL, §420-a(1)(a); but see §420-a(3) regarding exemption for unused land where exempt use is contemplated in good faith). If, however, the organization were to convert its new parcel to non-farm purposes, albeit nonprofit purposes which might qualify for exemption from taxation pursuant to section 420-a, in our opinion, the conversion payment would still be due.
(I lost the link to this document but I may findd it later if needed.)