Syracuse University v. Murphy

Syracuse University is an educational corporation, chartered by special act of the Legislature, exclusively for educational purposes. It owns and operates a steam plant primarily for the purpose of producing steam to heat its own buildings. However, at least during the period here involved (1940 to 1955), it produced surplus steam which it sold to public or charitable institutions near the campus. It furnished no steam to private or commercial enterprises. The cost of production was charged pro rata in accordance with the quantity used. The university was by far the largest user, using more…