Quaker Apartments of Wilmington, Inc. v. Kosydar

The sole question presented in this case is whether the sale of building materials to appellant for incorporation into its apartment building falls under the tax exception granted by R. 0. 5739.02(B) (12) for sales made to organizations operated exclusively for charitable purposes. The Board of Tax Appeals concluded that it did not. We find the decision of the board to be reasonable and lawful, and affirm.

R. 0. 5739.02(B) (12), in relevant part, excepts from taxation:

“Sales of tangible personal property to churches and to organizations not for profit operated exclusively for charitable…