6787 Steelworkers Hall, Inc. v. Jon M. Snyder, Assessor of Porter County
71 N.E.3d 97
| Ind. T.C. | 2017Background
- 6787 Steelworkers Hall, Inc. (Local 6787) is a 501(c)(5) labor union representing ~3,400 ArcelorMittal Burns Harbor employees; it owned a Union Hall and a Meeting Hall on 20 acres in Porter County during 2008 and 2010.
- Local 6787 sought property-tax exemptions for those years under Indiana’s charitable and educational-purpose exemptions; PTABOA denied the applications and the Indiana Board of Tax Review affirmed denial after a two-day hearing.
- Local 6787 presented evidence of union activities: collective bargaining agreements (BLAs) with employment/economic security provisions, safety and civil-rights initiatives, an Employee Assistance Program, job and leadership training via an Institute for Career Development, community wellness events, and occasional free use of its Meeting Hall by charities.
- Local 6787 argued the property was used exclusively (Union Hall) or predominantly (Meeting Hall) for charitable/educational purposes, and relied on precedent allowing member‑focused charities to qualify for exemption.
- The Assessor conceded the facts but argued the union activities primarily benefited members and any public benefit was incidental or collateral, so the uses were not charitable/educational under the statute.
- The Indiana Board found only limited charitable/public uses (charities allowed to use the hall, public wellness events, donations); it concluded most union activities were member‑oriented fringe benefits and not exempt. Local 6787 appealed to the Tax Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Local 6787’s property was used for charitable purposes under I.C. § 6-1.1-10-16 | Union activities and bylaws are charitable; member‑limited charities can be exempt (relying on Grand Master) | Activities primarily benefit members; public benefit is incidental/collateral and insufficient for exemption | Court affirmed Board: most union activities are member‑benefits, not charitable uses under the statute |
| Whether property was used predominantly for exempt purposes when mixed uses occurred | Meeting Hall was used >50% for exempt activities in 2008 and 2010; no profit from nonexempt uses | Even if some exempt uses occurred, overall predominant use was for member benefits and nonexempt events | Court affirmed Board: Local 6787 failed to show predominant exempt use |
| Whether Grand Master (1865) controls and requires exemption for member‑centric organizations | Grand Master permits member‑limited charities and thus supports exemption | Grand Master involved a different statute and benevolent corporations; it is not binding under current exemption statute | Court: Grand Master not controlling; statutory language differs and case is distinguishable |
| Whether Board’s findings were supported by substantial evidence | Local 6787: submitted unrebutted, probative evidence; Board accepted facts but erred legally | Board: applied law to facts and reasonably found public benefits incidental | Court: deferred to Board’s factual findings as supported by substantial evidence; no reweighing of evidence |
Key Cases Cited
- Hubler Realty Co. v. Hendricks Cnty. Assessor, 938 N.E.2d 311 (Ind. Tax Ct.) (burden on party challenging Board and standard for overturning Board determination)
- Freudenberg-NOK Gen. P’ship v. State Bd. of Tax Comm’rs, 715 N.E.2d 1026 (Ind. Tax Ct.) (court will not reweigh evidence or reassess witness credibility on review)
- Cedar Lake Conference Ass’n v. Lake Cnty. Prop. Tax Assessment Bd. Appeals, 887 N.E.2d 205 (Ind. Tax Ct.) (deference to Board’s factual findings; de novo review of legal questions)
- DeKalb Cnty. Assessor v. Chavez, 48 N.E.3d 928 (Ind. Tax Ct.) (definition of substantial evidence in tax-board review)
- Tannins of Indianapolis, LLC v. Indiana Dep’t of State Revenue, 6 N.E.3d 511 (Ind. Tax Ct.) (tax exemptions construed strictly against taxpayer; burden of proof on claimant)
- Fraternal Order of Eagles No. 3988, Inc. v. Morgan Cnty. Prop. Tax Assessment Bd. of Appeals, 5 N.E.3d 1195 (Ind. Tax Ct.) (distinguishing fraternal beneficiary exemption from charitable/educational exemptions)
- City of Indianapolis v. Grand Master, etc., of Grand Lodge of Indiana, 25 Ind. 518 (Ind.) (1865) (historical rule that charity need not be universal; discussed and distinguished by the court)