Opinion No.

Honorable Charles R. Holcomb County Attorney Cherokee County Courthouse Rusk, Texas

Re: Whether a foundation which owns a clinic and leases it to a physicians' association is exempt from ad valorem taxes.

Dear Mr. Holcomb:

You have requested our opinion concerning the exemption from ad valorem taxation of the property of the Travis Clinic Foundation. You have informed us that the Foundation is a nonprofit corporation which owns the Travis Clinic. The Foundation leases the Clinic to the Travis Clinic Association; the Association pays rentals sufficient to pay the indebtedness of the Foundation as…