Canterbury Health Care, Inc v. Department of Treasury

In this tax case, petitioners appeal by right the order of the Tax Tribunal denying the contractor petitioner an exemption from the sales and use tax on materials purchased for and used to construct a nonprofit nursing care and retirement facility. We affirm.

1. underlying facts and procedural history

Petitioner Canterbury Health Care, Inc., is a nonprofit subsidiary corporation of St. Luke’s Episcopal Church Home, which has traditionally served the aged and to which the Internal Revenue Service granted charitable tax status. Canterbury hired petitioner Granger Construction Company to build…