College Preparatory School for Girls v. Evatt

The only question before this court is whether the decision of the Board of Tax Appeals denying the appellant exemption from taxation of the school playground was reasonable and lawful.

The decision of the Board of Tax Appeals is based upon its determination that the applicant is not a charitable institution within the purview and meaning of Section 2, Article XII of the Ohio Constitution and Section 5353, General Code. Hence we must ascertain whether the appellant is an “institution” within the meaning of Section 5353, General Code.

Section 5353, General Code, provides:

“Lands, houses and other…