El Paso Central Appraisal District v. Ev. Lutheran Good Samaritan Society, Inc.

OPINION

OSBORN, Chief Justice.

This appeal is from a judgment entered in a bench tried case allowing the Appellee tax exempt status on a retirement and nursing home in El Paso. We reverse.

The Evangelical Lutheran Good Samaritan Society, Inc., is organized as a non-profit corporation under the laws of North Dakota. It operates, in El Paso, a one hundred unit apartment complex for elderly, retired people who do not need immediate medical care and a sixty bed nursing home for those who do need regular medical care. The Society’s application for tax exempt status was denied as to the retirement…