Surtees v. Carlton Cove, Inc.

G. Thomas Surtees, in his official capacity as commissioner of revenue for the State of Alabama, and Fran Hamilton, in her official capacity as tax assessor of Madison County (referred to hereinafter collectively as the "taxing authorities"), appeal from a summary judgment entered by the Montgomery Circuit Court in favor of Carlton Cove, Inc. ("Carlton"), and Redstone Military Retirement Residence Association ("Redstone"). Carlton and Redstone are nonprofit charitable organizations exempt from federal income taxation under I.R.C § 501(c)(3), and each of them owns and operates a residential…