Ohio Children's Society, Inc. v. Porterfield

In recent years this court has had occasion to review determinations of whether the operations of certain organizations were “exclusively for charitable purposes.” See Vick v. Cleveland Memorial Medical Foundation (1965), 2 Ohio St. 2d 30; Planned Parenthood Assn. v. Tax Commr. (1966), 5 Ohio St. 2d 117; Carmelite Sisters, St. Rita’s Home, v. Bd. of Review (1969), 18 Ohio St. 2d 41. In each of those eases, after construing the relevant statutory provisions strictly against the parties seeking exemption from some legal mandate, a majority of the court found the operations to have been operated…