Skyline Preservation Foundation v. County of Polk

OPINION

LANCASTER, Justice.

Relator Skyline Preservation Foundation, Inc. (Skyline) appeals from a Minnesota Tax Court summary judgment holding that Skyline is not an institution of purely public charity, which would exempt it from taxation under Article X of the Minnesota Constitution 1 and Minn.Stat. § 272.02, subd. 1(6) (Supp.1997). 2 Under Minn.Stat. § 278.01 (2000), Skyline petitioned the tax court to review respondent Polk County’s 1997 classification of Skyline’s real property as nonexempt. The tax court applied the guidelines outlined by this court in North Star Research Institute v.…