IBEW Local 305 Inc. v. Allen County Assessor

CourtIndiana Tax Court
DecidedMarch 13, 2026
Docket25T-TA-00003
StatusPublished
AuthorJudge McAdam

This text of IBEW Local 305 Inc. v. Allen County Assessor (IBEW Local 305 Inc. v. Allen County Assessor) is published on Counsel Stack Legal Research, covering Indiana Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
IBEW Local 305 Inc. v. Allen County Assessor, (Ind. Super. Ct. 2026).

Opinion

ATTORNEY FOR PETITIONER: ATTORNEYS FOR RESPONDENT: KERA L. PAOFF MARK E. GIAQUINTA PAOFF & ROBINSON, LLC GIAQUINTA LAW OFFICES LLC Toledo, OH Fort Wayne, IN

NICHOLAS M. BRADY LEWIS WAGNER & TRIMBLE Indianapolis, IN

IN THE INDIANA TAX COURT

IBEW LOCAL 305, ) ) FILED Petitioner, ) ) Mar 13 2026, 3:19 pm

v. ) Case No. 25T-TA-00003 CLERK Indiana Supreme Court ) Court of Appeals and Tax Court

ALLEN COUNTY ASSESSOR, ) ) Respondent. )

ON APPEAL FROM A FINAL DETERMINATION OF THE INDIANA BOARD OF TAX REVIEW

FOR PUBLICATION March 13, 2026

MCADAM, J.

This case requires the Court to determine the meaning of the word “school” as it

is used in Indiana Code § 6-1.1-10-36.3. Under the statute, property is totally exempt

from property taxation if it is predominantly occupied or used for an educational purpose

by a “not-for-profit school.” Though the ordinary and usual meaning of the word “school”

is an institution for instruction or teaching, the Indiana Board of Tax Review concluded

that the legislature intended a narrower meaning and limited the word to include only “institutions accredited or regulated by the Indiana Department of Education.” (Cert.

Admin. R. at 1366 ¶ 40.) The Court holds that departure from the plain meaning of the

word “school” is unsupported by the text and rejects the Board’s narrow definition.

Accordingly, the Court reverses the Board’s determination and remands the case for

reconsideration.

FACTS AND PROCEDURAL HISTORY

International Brotherhood of Electrical Workers, Local Union No. 305 (“Local

305”) is an Indiana not-for-profit corporation that owns property in Allen County, Indiana,

consisting of approximately 0.64 acres of land and a building of approximately 7,680

square feet. The property is used and occupied more than fifty percent of the time by

the Fort Wayne Electrical Joint Apprenticeship and Training Committee Trust Fund

(“JATC”) to operate an apprenticeship program.

The JATC is an employee welfare benefit plan operating as a trust fund created

jointly by Local 305 and the Fort Wayne Division, Central Indiana Chapter of the

National Electrical Contractors Association. Local 305 and the Association each appoint

three of the six trustees who manage the JATC. The trust acts as a training fund to

“provide education and training to apprentices in the electrical industry.” (Cert. Admin. R.

at 1355–56 ¶ 9.) To provide this education, the JATC explains that it employs

administrators and staff and operates with dedicated facilities for classrooms,

administration, and storage.

The JATC’s apprenticeship program combines classroom instruction with on-the-

job training in the electrical trade, including at least 900 hours in the classroom and

8,000 hours on the job over five years. Classes are taught by both experienced

2 electricians and Ivy Tech Community College instructors during regularly scheduled

evening hours based on a standard September through June academic year. The

program’s curriculum is reviewed and approved by multiple organizations, including the

United States Department of Labor’s Office of Apprenticeship and Ivy Tech Community

College. Graduates receive both a certificate from the Department of Labor and an

Associate of Applied Science degree from Ivy Tech. According to an affidavit from one of

JATC’s trustees, the program is not restricted to union members; the JATC program is

open to the public and graduates are free to work for whomever and wherever they

want.

Claiming that JATC’s apprenticeship program was a not-for-profit school with an

educational purpose, Local 305 applied for a 100% property tax exemption on the

subject property for the 2020 and 2022 assessment years. The Allen County Property

Tax Assessment Board of Appeals wholly denied the exemption for 2020 and partially

denied the exemption for 2022, both of which were appealed by Local 305 to the

Indiana Board of Tax Review. Instead of a trial before the Indiana Board, the parties

submitted a stipulated record and wrote briefs to present their case to the Indiana

Board. Because the parties agreed that the JATC used the subject property more than

50% of the time for educational purposes during the assessment years, the parties and

the Board agreed that the case “turn[ed] on whether the [JATC] qualifies as a ‘school.’”

(Cert. Admin. R. at 1352–53 ¶ 1; see Cert. Admin. R. at 876 ¶ 10, 1359 ¶ 22.)

The Indiana Board concluded that the JATC did not qualify as a “school” under

Indiana Code § 6-1.1-10-36.3(c)(2) and granted only a partial property tax exemption for

the JATC’s educational purpose. It determined that “the legislature likely intended a

3 narrow, more technical definition” of the term “school” in the predominant-use statute

“limited to institutions accredited or regulated by the Indiana Department of Education.”

(Cert. Admin. R. at 1366 ¶ 40.) Because the JATC was not accredited by the

Department of Education, the Board therefore denied Local 305 a 100% exemption and

instead granted it an exemption proportional to the time the property was used for

educational purposes, which amounted to 62.5%. Local 305 then filed an appeal with

this Court.

STANDARD OF REVIEW

This Court’s review of Indiana Board decisions is governed by Indiana Code

§ 33-26-6-6, which closely mirrors the language governing judicial review of

administrative decisions under Indiana’s Administrative Orders and Procedures Act.

Compare IND. CODE § 33-26-6-6(e) (2026) with IND. CODE § 4-21.5-5-14(d) (2026). The

party seeking to overturn the final determination of the Board bears the burden of

demonstrating its invalidity. IND. CODE § 33-26-6-6(b). Challengers must demonstrate

that they have been prejudiced by a final determination of the Board that is arbitrary,

capricious, an abuse of discretion, or otherwise not in accordance with law; contrary to

constitutional right, power, privilege, or immunity; in excess of or short of statutory

jurisdiction, authority, or limitations; without observance of the procedure required by

law; or unsupported by substantial or reliable evidence. IND. CODE § 33-26-6-6(e). The

Board’s legal conclusions are reviewed de novo, and its factual determinations are

afforded deference when they are supported by substantial and reliable evidence.

Majestic Props., LLC v. Tippecanoe Cnty. Assessor, 241 N.E.3d 642, 644 (Ind. Tax Ct.

4 2024) (citing Indiana Alcohol & Tobacco Comm’n v. Spirited Sales, LLC, 79 N.E.3d 371,

375 (Ind. 2017)).

DISCUSSION

As was the case at the administrative level, the sole issue presented for

consideration on appeal is whether the JATC is a “school” for purposes of Indiana Code

§ 6-1.1-10-36.3 (2020) (the “predominant-use statute”). The parties agree on the case’s

general framework: if the JATC is a “school,” then the property is wholly exempt from

property taxation under the predominant-use statute; if not, the property is only partially

exempt.

The Indiana Board determined that the JATC was not a “school” within the

meaning of the statute because the word “exclude[s] entities, like the [JATC], that offer

post-secondary or higher education and that are not regulated by the Indiana

Department of Education.” (Cert. Admin. R. at 1363 ¶ 33; see Cert. Admin. R. at

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IBEW Local 305 Inc. v. Allen County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ibew-local-305-inc-v-allen-county-assessor-indtc-2026.