Tipton County Health Care Foundation, Inc. v. Tipton County Assessor
2012 Ind. Tax LEXIS 4
| Ind. T.C. | 2012Background
- Autumnwood Village was built in 1998 as an assisted living facility adjacent to the hospital and other long-term care facilities on 1.94 acres.
- Autumnwood features 40 apartments, a central dining room, and amenities directed at elderly residents, with design elements for accessibility and safety.
- In December 2007 the Hospital sold Autumnwood to the Tipton County Health Care Foundation, with Miller's Health Systems providing management services under a prior agreement.
- Starting January 1, 2008 the Foundation leased Autumnwood to Miller's under a five-year triple-net lease, giving Miller's exclusive possession and obligating it to operate Autumnwood as an assisted living facility while the Foundation paid taxes and other expenses.
- The Foundation filed applications for a charitable purposes exemption with the PTABOA for 2008 and 2009, both denied; the Indiana Board also denied the exemption, finding no prima facie case.
- The Court affirms the Indiana Board, holding that the Foundation failed to prove a charitable purpose, and that the absence of a proven private-benefit/private-motive in Miller's arrangement undermines the exemption request.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Foundation established a prima facie charitable exemption | Foundation contends Autumnwood’s elderly-focused care suffices | Board required proof of charitable purpose and no clear private benefit | Yes, Foundation did not prove a prima facie charitable purpose |
Key Cases Cited
- Hamilton Cnty. Prop. Tax Assessment Bd. of Appeals v. Oaken Bucket Partners, LLC, 938 N.E.2d 654 (Ind. 2010) (unity of ownership/occupancy not required; each entity must show its own exempt purpose when lacking)
- Sangralea Boys Fund, Inc. v. State Bd. of Tax Comm'rs, 686 N.E.2d 954 (Ind. Tax Ct.1997) (exemption requires charitable purpose and prevents private benefit)
- College Corner, L.P. v. Dep't of Local Gov't Fin., 840 N.E.2d 905 (Ind. Tax Ct.2006) (burden shifts to rebuttal after prima facie showing)
- St. Mary's Med. Ctr. of Evansville, Inc. v. State Bd. of Tax Comm'rs, 534 N.E.2d 277 (Ind. Tax Ct.1989) (strict construction of exemption statutes; burden on taxpayer)
- Wittenberg Lutheran Vill. Endowment Corp. v. Lake Cnty. Prop. Tax Assessment Bd. of Appeals, 782 N.E.2d 483 (Ind. Tax Ct.2003) (great deference to Board; review for arbitrariness or lack of substantial evidence)
- Raintree Friends Hous., Inc. v. Indiana Dep't of State Revenue, 667 N.E.2d 810 (Ind. Tax Ct.1996) (charitable exemption standards in housing for elderly)
- Knox Cnty. Prop. Tax Assessment Bd. of Appeals v. Grandview Care, Inc., 826 N.E.2d 177 (Ind. Tax Ct.2005) (elderly care exemptions; evidence focused on charitable purpose)