Toledo Business & Professional Women's Retirement Living, Inc. v. Board of Tax Appeals

The taxpayer, a nonprofit corporation, owns and operates “low-rent retirement living apartments with attendant facilities for aged occupants.” The annual income maximum for occupancy is $5,250 for couples and $4,300 for individuals.

The “attendant facilities” include central, as well as individual kitchens, safety devices in the building, recreational activities designed for mental and physical therapy and advancement. Medical and nursing care are claimed to he available, but the record is thin as to the terms and conditions upon which it is furnished.

The argument for exemption is two-pronged.…