Salvation Army v. Department of Taxation of Ohio

The question to be decided is whether the words “purposes only of public charity” as used in Section 5334, General Code (Section 5731.0.9, Revised Code), include religious purposes. The Department of Taxation, appellee herein, contends that they do not and that, since The Salvation Army is an institution not only for what appellee concedes are purposes of public charity but also for religious purposes, it is not an “institution for purposes only of public charity” within the meaning of that statute and therefore it is not entitled to the tax exemption sought.

In our opinion, previous decisions…