Cleveland Bible College v. Board of Tax Appeals

It is true that in the Ohio Constitution of 1851, exemption from taxation was authorized as to “institutions of purely public charity” and that under the 1912 amendment to the Constitution the language was changed to read “institutions used exclusively for charitable purposes.” However, in my judgment, such later language, also used in Section 5353, G-eneral Code, does not benefit the appellant in the instant case.

Under present Section 2, Article XII, of the Constitution, and Section 5353, G-eneral Code, enacted pursuant to the authorization therein contained, it is incumbent upon an…