Jewish Hospital Ass'n v. Board of Tax Appeals

The record herein does not indicate whether the director of nursing, residents, interns or graudate-nurse employees were required to be in or near the hospital so as to be available on a 24-hour basis or whether any of those employees were, outside of duty hours, required to participate in any of the educational, research, teaching or patient-care programs of the hospital.

Except for the director of nursing, there is nothing to indicate whether the use of the facilities was primarily for residence or for temporary sleeping purposes.

As to the use of the one parcel as sleeping facilities for…