Woods Schools Tax Exemption Case

Opinion by

Me. Justice Eagen,

This is a real estate tax assessment case. Total exemption from all real estate taxation is sought by the appellant, the Woods Schools, on the ground that it is a “purely public charity.”

Woods Schools is a nonprofit corporation which maintains and operates a private institution in Bucks County, Pennsylvania, for the education, treatment and care of children and adults, who are physically, mentally, socially or emotionally handicapped. Its real estate holdings presently include over 326 acres of land improved with approximately 80 buildings.

The institution seeks the…