Care Institute, Inc.-Roseville v. County of Ramsey

OPINION

RUSSELL A. ANDERSON, Justice.

Respondent, Care Institute, Inc.-Rose-ville (CIIR), an Indiana nonprofit corporation exempt from federal and state income tax, owns and operates Rosewood Estates of Roseville (RER), an assisted living facility for the elderly. At issue in this case is whether CIIR qualifies as a purely public charity exempt from property taxes for tax years 1996, 1997, and 1998. On CIIR’s motion for summary judgment, the Minnesota Tax Court held that because it ruled in 1996 that CIIR qualified as an exempt purely public charity for tax year 1994, the doctrines of res…