Opinion No.

The Honorable John Paul Capps State Senator 914 James Street Searcy, AR 72143-3927

Dear Senator Capps:

I am writing in response to your request for my opinion concerning the taxable status of a hospital facility. As background for your question, you state:

A not-for-profit (501(c)(3)) hospital in my district has acquired another hospital in the same city from a publicly owned for-profit corporation. Title to the real and personal property is now vested in the not-for-profit hospital. The not-for-profit hospital will continue to operate the acquired facility exclusively as a sub-acute hospital.

You…