Columbus Colony Housing, Inc. v. Limbach

The taxpayer is a nonprofit corporation, exempt from federal taxation under Section 501(c)(3) of the Internal Revenue Code. Further, the taxpayer and the volunteers who participate in the programs at the taxpayer’s apartment complex are engaged in a praiseworthy endeavor. However, our task is one of statutory interpretation. The statute which controls our decision is R.C. 5739.02(B)(12).

R.C. 5739.02(B)(12) exempted the following from sales tax:

“Sales of tangible personal property [or services] to churches and to nonprofit organizations operated exclusively for charitable purposes in this…