In Re the Appeal of the Mental Health Ass'n

The opinion of the court was delivered by

Rosen, J.:

The Mental Health Association of the Heartland (MHAH) is a tax-exempt organization that qualifies for federal income tax exemption under Internal Revenue Code § 501(c)(3), see 26 U.S.C. § 501(c) (2006). It is incorporated as a public-benefit, nonprofit corporation in Missouri. In October 2006, MHAH sought an exemption from ad valorem taxation beginning in the year 2002 on real property that it owns and operates as an apartment building (the Marion Home) for chronically homeless, low-income people who suffer from severe mental handicaps and…