Sarah Dix Hamlin School v. City & County of San Francisco

This is an appeal from a judgment sustaining respondent’s claim to the tax exemption allowed by Revenue and Taxation Code section 214 on property used exclusively for school purposes of less than collegiate grade, and owned and operated by a nonprofit corporation.

The Sarah Dix Hamlin School, hereafter referred to as the respondent, is a nonprofit corporation. Its articles of incorporation state that its purpose is to own, conduct and operate a school for girls of less than collegiate grade; that it does not contemplate pecuniary gain or profit, and that no part of its earnings shall inure to…