Georgia Congress of Parents & Teachers, Inc. v. Boynton

Bowles, Justice.

This is an appeal from an order granting appellees’ motion for summary judgment. The sole issue for determination is whether the institution involved here is one of purely public charity and, therefore, exempt from ad valorem taxation under Code Ann. § 92-201.

Appellant owns real property in Atlanta, Georgia, against which appellees caused fi. fas. to issue for 1972, 1973 and 1974 unpaid taxes. Appellant filed its complaint below seeking to enjoin execution of the fi. fas. on the theory that it is an institution of purely public charity, and, therefore, exempt from taxation by…