Highland Park Owners, Inc. v. Tracy

R.C. 5709.12(B) states:

“ * * * Real and tangible personal property belonging to institutions that is used exclusively for charitable purposes shall be exempt from taxation. * * * ”

The commissioner argues that, to qualify for exemption, the property must be owned by a charitable institution, and that since Highland Park is not a charitable institution, the property is not exempt. He also argues that the property is not used exclusively for charitable purposes. We disagree on both counts.

*406Section 2, Article XII of the Ohio Constitution permits the General Assembly to exempt from taxation…