Cleveland Branch of the Guild v. Board of Tax Appeals

By the Court.

Counsel for appellants state the-“basic and controlling question is whether the ownership and operation by a charitable organization not for profit of a small-suite apartment house not for profit as a home for nurses in the circumstances presented by the evidence * * * is a charitable purpose and' activity and is use of the premises by an institution exclusively for charitable purposes.”

That statement invites an examination of the record on which the Board of Tax Appeals based its conclusion that “the controlling fact is the use made of' the property as to which exemption from…