Nuci Phillips Memorial Foundation, Inc. v. Athens-Clarke County Board of Tax Assessors

Because the majority incorrectly analyzes the recent amendments to OCGA § 48-5-41 (d) and fails to rely upon the plain language of the current statute in reaching its result, I must respectfully dissent.

1. OCGA § 48-5-41 (a) (4) provides that “[a]ll institutions of purely public charity” are exempt from ad valorem property taxes in Georgia. This Court has held that

[i]n determining whether property qualifies as an institution of “purely public charity” as set forth in OCGA § 48-5-41 (a) (4), three factors must be considered and must coexist. First, the owner must be an institution devoted…