IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax
PROSPECT COMMUNITY CLUB, ) ) Plaintiff, ) TC-MD 160267R ) v. ) ) JACKSON COUNTY ASSESSOR, ) ) Defendant. ) FINAL DECISION1
Plaintiff appeals the denial of a property tax exemption for property identified as Account
10513560 (subject property) for the 2016-17 tax year. A trial was held in the Oregon Tax Court
on December 9, 2016. Jennifer E. Nicholls, attorney, represented Plaintiff. Susan Kiefer
(Kiefer) testified as a witness on behalf of Plaintiff. Judy Hanratty (Hanratty), exemption
specialist for the Jackson County Assessor’s Office, appeared and testified on behalf of
Defendant. Plaintiff’s Exhibits 1 through 11 were received without objection. Defendant’s
Exhibits B through E were received without objection. Defendant’s Exhibit A was received in
part after objection.
I. STATEMENT OF FACTS
Plaintiff is a community club in the unincorporated community of Prospect, Oregon,
which has a population of less than 1,000 people and is located in Jackson County. (Ptf’s Ex 11
at 3.) Plaintiff has been incorporated in Oregon since 1947, and the Internal Revenue Service
has recognized it as a 501(c)(3) organization, exempt from Federal income tax, since 2004.
(Ptf’s Ex 1 at 3; Ex 4 at 1.) Plaintiff’s 2004 amended Articles of Incorporation state that the 1 The court granted Plaintiff’s appeal in its Decision, entered May 23, 2017. That Decision is incorporated in this Final Decision. Plaintiff filed its Statement for Costs and Disbursements (Statement) on June 2, 2017, requesting an award of costs and disbursements totaling $334.85. Defendant did file a response to Plaintiff’s Statement. Upon consideration, the court grants Plaintiff’s request for costs and disbursements. See Tax Court Rule-Magistrate Division (TCR-MD) 16.
FINAL DECISION TC-MD 160267R 1 corporation “is organized exclusively for charitable, religious, educational, and scientific
purposes.”2 (Ptf’s Ex 2 at 1.) Plaintiff’s 2013 amended bylaws state that the corporation’s
purpose is to provide “a venue for the community to organize and develop educational and
recreational activities for adults and children.” (Ptf’s Ex 3 at 1.)
Plaintiff’s bylaws state that “membership in the corporation shall consist of all persons
eighteen (18) years of age or over residing or employed in the area serviced by the Prospect Post
Office.” (Ptf’s Ex. 3 at 4.) The bylaws require annual membership dues from each member. Id.
Kiefer testified that the dues are $5 per member. However, she testified that the club does not
actively collect dues and that the dues are not considered a significant source of revenue for the
club. Kiefer also stated that neither membership nor payment of membership dues is a
requirement to participate in Plaintiff’s activities or to use the subject property, a community hall
(“the Hall”). The benefit for members who pay dues is discounted rental rates, she stated. Of
the distinction between club members and members of the community at large, Kiefer testified
that “[s]ince everyone who’s a resident is technically a member of the club, it’s not entirely clear
to me how things work.”
Volunteers built the Hall in the 1950s to serve as a gathering place for community events.
(Ptf’s Ex. 8.) Kiefer testified that she is a member of Plaintiff’s organization and a volunteer at
the Hall. Kiefer testified that an old Prospect family donated the property for the Hall for the
2 Prospect’s articles of incorporation were amended in 2004, the same year that the corporation applied for and received its 501(c)(3) classification for federal tax exemption. Its original 1947 articles of incorporation, valid until 2004, stated that Prospect’s purpose was, in part, as follows:
“To become the official sponsor of, to sanction and promote educational pursuits of all kinds and to pursue charitable pursuits of any and all kinds and community recreation; to conduct social bazars, dances, entertainments of all kinds for the purpose of raising funds to be used in the said educational and charitable pursuits; to cultivate social intercourse among its members and to [illegible] the principles of charity, brotherly love, and fidelity, and to promote the welfare and enhance the welfare of its members. To promote the welfare of the community surrounding the town of Prospect, Oregon, and to promote all civic purposes which may be beneficial to the City of Prospect * * *.” (Ptf’s Ex 1 at 1.)
FINAL DECISION TC-MD 160267R 2 express purpose of becoming a community gathering place. Kiefer testified that the ownership
and operation of the Hall is Plaintiff’s primary activity, though the organization also hosts an
annual fundraising Prospect Jamboree and Timber Carnival off-site. Kiefer said that the Hall is
equipped with a recently renovated commercial kitchen, two restrooms, and storerooms, but that
it is otherwise much like a barn. She also testified that the building has a metal roof and no
insulation, and is in need of renovations.
Plaintiff regularly rents the Hall to individuals for private events such as weddings, baby
showers, birthday parties, club meetings, and other social gatherings. Plaintiff charges rental
fees ranging from $15 to $180, depending on the renter’s needs and historical precedents. (Ptf’s
Ex. 5.) Kiefer testified that there is no comparable facility in or near Prospect that is similarly
equipped and available for hosting events. Kiefer testified that about a year ago, she investigated
rental charges for halls in the area, and the nearest venue in Shady Grove charges $300 for a full
day rental. Kiefer testified that Plaintiff charges $75 for 12 hours for non-members and $50 for
members.
The Hall is frequently used at no cost for certain events, including funerals, memorial
services, and on one occasion, a fundraiser to benefit the family of a child diagnosed with cancer.
(Ptf’s Ex. 5.) The United States Department of Agriculture has used the Hall to present forest
fire information sessions, and the local library has hosted civic discussions there. (Id.; Ptf’s Ex
11 at ¶ 3.)
Plaintiff’s organization also uses the Hall for occasional meetings of its volunteer board.
(Ptf’s Ex. 5.) In addition, Kiefer testified, Plaintiff organization hosts its own events at the Hall,
including a weekly meal for senior citizens and special holiday dinners for Thanksgiving and
Christmas. Kiefer said volunteers prepare the meals, which are offered to the public for free, but
FINAL DECISION TC-MD 160267R 3 Plaintiff accepts donations from participants. Kiefer testified that Plaintiff never discriminates
based on race, color, or creed. Kiefer testified that advertisements for the meals are displayed at
the local post office and distributed to a voluntary email list, and that no one is turned away from
these meals due to an inability to donate. Kiefer testified that Plaintiff also offers monthly
dinners for families, and charges $7 or $8 per adult for those meals. Kiefer testified that any
receipts from meal fees or lunch donations are used to cover the costs of preparing the meals and
heating the poorly insulated building.
Kiefer testified that most of the money Plaintiff receives through rental fees, meal
donations, and fundraising efforts are used for operational expenses like utilities and
maintenance of the aging building, and that Plaintiff only raises funds “in order to continue to
exist.” Kiefer testified that Plaintiff receives some donations throughout the year, but that these
donations are not enough to cover the costs of operating the facility. Plaintiff’s fundraising
efforts include an annual Carnival and Jamboree, at which it sponsors the children’s games.
(Def’s Ex. E at 6). Kiefer said these fundraising activities do not occur at the Hall. Kiefer
testified that the Carnival features food vendors and a beer garden, and that receipts from the
entry fee of $5 are used to pay for carnival prizes. Kiefer said Plaintiff sponsors an annual $500
scholarship with proceeds from the Carnival and uses any additional funds to maintain the Hall.
Kiefer testified that several years ago, Plaintiff hosted bingo at the Hall, but that Plaintiff no
longer hosts the games and does not intend to do so in the future.
Plaintiff has historically enjoyed a charitable exemption from property taxes. In May
2016, Defendant denied Plaintiff’s renewal application for exemption, stating that:
“Charity is not the primary, if not sole, objective of the Prospect Community Club. Fund raising activities are not charitable use of the property. The courts define these activities as ‘destination of income’ and conclude that raising money to do charity is not a charitable use of property.”
FINAL DECISION TC-MD 160267R 4 (Ptf’s Ex. 11 at 1.) Hanratty testified that Defendant made its determination based on old
Facebook posts made by Plaintiff indicating the nature of some of Plaintiff’s regular activities at
the time, including hosting bingo. Hanratty testified that the outdated posts were “all
[Defendant] found” on which to base a judgment. Hanratty testified that Defendant also relied
on the language of Plaintiff’s 1947 Articles of Incorporation and its amended 2004 Articles of
Incorporation, finding neither of the statements to “isolate the charitable purpose.” Although
Hanratty conceded that Plaintiff organization “do[es] wonderful things for their community,” she
testified that Defendant could not conclude that Plaintiff’s work was primarily charitable.
II. ANALYSIS
The issue presented in this appeal is whether Plaintiff is entitled to property tax
exemption under ORS 370.130(2) as a “charitable institution.”3
All real property in Oregon is taxable unless it is specifically exempted. ORS 307.030.
The Oregon Revised Statutes provide a property tax exemption for certain charitable
organizations on “such real or personal property, or proportion thereof, as is actually and
exclusively occupied or used in the literary, benevolent, charitable or scientific work carried on
by such institutions.” ORS 307.130(2)(a). The court is guided by the principle that “[t]axation is
the rule and exemption from taxation is the exception.” Dove Lewis Mem’l Emergency
Veterinary Clinic, Inc. v. Dept. of Rev. (Dove Lewis), 301 Or 423, 426-27, 723 P2d 320 (1986).
Property tax exemption statutes are to be strictly but reasonably construed, meaning that the
court should give “due consideration to the ordinary meaning of the words of the statute and the
legislative intent,” and should construe ambiguities in favor of the state. North Harbour Corp. v.
Dept. of Rev., 16 OTR 91, 94-95 (2002). The burden of establishing entitlement to an exemption
3 The court’s references to the Oregon Revised Statutes (ORS) are to the 2015 version.
FINAL DECISION TC-MD 160267R 5 is on the taxpayer claiming the exemption, and the entitlement must be established by a
preponderance of the evidence. ORS 305.427.
To qualify for the exemption, an organization must meet three requirements: (1) the
organization must have charity as its primary, if not sole, object; (2) the organization must be
performing in a manner that furthers its charitable object; and (3) the organization’s performance
must involve a gift or giving. SW Oregon Pub. Def. Services v. Dept. of Rev. (SW Oregon), 312
Or 82, 89 (1991); See also OAR 150-307-0120-(A)(4)(a)-(d)4 (incorporating these factors). This
test is applied to the overall activities of the organization, and not any specific part or operation
thereof. Mercy Med. Ctr., Inc. v. Dept. of Rev. (Mercy Med.), 12 Or Tax 305, 307, 1992 WL
310208, *2 (1992). An organization must meet all three elements to qualify as charitable.
Mazamas v. Dept. of Rev., 12 OTR 414, 415 (1993).
A. The Organization
1. Charitable purpose
At the outset, an organization seeking a charitable exemption under ORS 307.130 must
prove that it is charitable by having “charity as its primary, if not sole, object.” SW Oregon, 312
Or at 89. This inquiry looks to the character of the organization. Dove Lewis, 301 Or at 427.
The Department of Revenue (the department) has promulgated regulations that offer a
framework for, among other things, determining whether an organization qualifies as a charitable
organization. In order to qualify, an organization must: be incorporated and organized as a
nonprofit corporation; separately account for funds and donations committed to charitable use;
not operate for the profit or private advantage of the organization’s founders and officials; and
///
4 The court’s references to the Oregon Administrative Rules are to the 2016 version, which was renumbered as of September 1, 2016.
FINAL DECISION TC-MD 160267R 6 require that its assets be used for charitable purposes when the organization dissolves. OAR
150-307-0120-(A)(2)(a)-(e).
Although not dispositive, an organization’s articles of incorporation and bylaws can serve
as prima facie evidence of the character of the organization. Dove Lewis, 301 Or at 427; Found.
of Human Understanding v. Dept. of Rev., 301 Or 254, 258, 722 P2d 1, (1986) (articles); Benton
County v. Allen, 170 Or 481, 485, 133 P2d 991 (1943) (articles); Hamilton v. Corvallis Gen.
Hosp. Ass’n., 146 Or 168, 171-72, 30 P2d 9 (1934) (articles and bylaws).
Plaintiff’s amended Articles of Incorporation state that Plaintiff is “organized exclusively
for charitable, religious, educational, and scientific purposes” and that “[n]o part of the net
earnings of the corporation shall inure to the benefit of * * * members, trustees, officers, or other
private person[s] * * *.” The articles also provide for a charitable distribution upon Plaintiff’s
dissolution. Plaintiff’s bylaws state that its purpose is to provide “a venue for the community to
organize and develop educational and recreational activities for adults and children.” (Ptf’s Ex. 3
at 1.) Because Plaintiff is a nonprofit organization and its articles of incorporation and bylaws
sufficiently show that charity is its primary object, Plaintiff satisfies the first prong of the SW
Oregon test.
Plaintiff’s stated purpose weighs in its favor, but is not enough to establish a right to
exemption under ORS 307.130. Cascade Raptor Ctr. v. Lane County Assessor, TC-MD
101269B, WL 4021408 at *4 (Or Tax M Div Sept 12, 2011) (explaining that charities in this
state enjoy no inherent right to exemption from taxation (citing Samaritan Vill., Inc. v. Benton
County Assessor (Samaritan Vill.), TC-MD 001064C,WL 25846514 at *8 (Or Tax M Div Jan 23,
2003) (internal quotation marks omitted)).
FINAL DECISION TC-MD 160267R 7 2. Performance in furtherance of the charitable purpose
The second prong of the SW Oregon test requires an organization seeking exemption to
“be performing in a manner that furthers its charitable object.” SW Oregon, 312 Or 82, 89
(1991); See also OAR 150-307-0120-(A)(4)(a)-(d). In other words, the court must determine
whether Plaintiff is actually charitable by its conduct. Dove Lewis, 301 Or at 428; see also OAR
150-307-0120-(A)(2)(b) (providing that “whether a corporation is a charity is to be determined
not only from its charter, but also from the manner in which it conducts its activities”).
While no particular definition of “charity” has been adopted in this context, courts have
interpreted this requirement to mean that the organization’s activities must be “for the direct
good or benefit of the public or community at large.” OAR 150-307-0120-(A)(4)(b). A
charitable institution’s “dominant purpose must be doing good to others rather than being
organized for the convenience of those who use its services.” U.S. Atheists v. Multnomah
County Tax Assessor, TC-MD 001108E, WL 34148929 at *3 (June 18, 2001) (citation omitted;
internal quotation marks omitted). The department clarifies this point as follows:
“Public benefits must be the primary purpose rather than a by-product. An organization that is established primarily for the benefit of its members is not a qualifying charity. For example, a rifle club formed primarily for the pleasure of its members also provides safety information and instruction. Since the club’s primary purpose is not to provide a direct benefit to the public, its property is not exempt.”
OAR 150-307-0120-(A)(4)(b); see also, Tivnu: Bldg. Justice v. Multnomah County Assessor,
TC-MD 150486R, WL 6752345 at *5 (Nov. 15, 2016). This rubric allows courts to accept a
generous definition of what qualifies as charity. Lebanon Cmty. Found., Inc. v. Linn County
Assessor, TC-MD 011005A, WL 1591920 at *2 (July 18, 2002) (finding that charity was not
limited to relieving pain, alleviating disease, or removing constraints).
FINAL DECISION TC-MD 160267R 8 To determine whether Plaintiff’s activities further its charitable purpose, the court must
ask whether the organization conducts itself in a way that offers a direct good to the community
at large, or whether its activities serve only a select membership. In this case, Plaintiff draws a
distinction between “members” and dues-paying members. Plaintiff’s bylaws illustrate this
distinction, defining its “members” as “all persons * * * residing or employed in” Prospect
(regardless, it seems, of any payment to or participation in Plaintiff organization). (Ptf’s Ex. 3 at
4.) However, as Kiefer testified, only the members who pay annual dues to Plaintiff enjoy the
added benefit of a discount on rental fees for hosting private events at the community Hall.
In the rifle club example previously mentioned, the organization presumably hosts
private, members-only events as well as safety trainings that are open to and benefit the public.
The events for the public benefit are mere “by-products” of the organization’s primary purpose
of operating a private rifle club. In the present case, the fact that paying dues to Plaintiff
organization is not a requirement to use the Hall or to participate in any activities Plaintiff
conducts at the Hall distinguishes Plaintiff from the aforementioned rifle club. In addition,
Plaintiff admittedly makes no real effort to collect dues from its members or keep records of dues
paid, and, as Kiefer testified, Plaintiff tends to use the term “members” to refer to all Prospect
residents, even those who have not paid dues to Plaintiff.
The distinction between dues-paying members and community members could, in some
cases, defeat the taxpayer’s charitable purpose; however, here it appears to be quite negligible.
Kiefer testified that Plaintiff advertises its weekly lunch events by posting fliers or menus at the
local post office, indicating that Plaintiff intends to encourage any member of the public, not just
for its dues-paying members, to attend its events at the Hall. In addition, Plaintiff allows anyone
to use the Hall at no charge for funerals and memorial services, and does not discriminate on the
FINAL DECISION TC-MD 160267R 9 basis of dues paid for the opportunity to rent the Hall for other events. Defendant concedes that
Plaintiff “do[es] wonderful things for the community,” not just its members. Based on this
evidence, the court finds Plaintiff’s activities are conducted for the benefit of the community at
large, and thus Plaintiff satisfies the second prong.
3. Gift or giving
The third and final prong of the SW Oregon test requires the organization seeking an
exemption to show that its “performance * * * involve[s] a gift or giving.” SW Oregon, 312 Or at
89. This determination is crucial to the analysis because the element of gift or giving “is what
distinguishes charity from nonprofit.” Samaritan Vill., 2003 WL 25846514 at *5 (relying on SW
Oregon, 312 Or at 89); Dove Lewis, 301 Or at 428 (finding that, in analyzing the eligibility of
charitable organizations for tax exemption, “the crucial consideration is the element of a gift or
giving”). Serenity Lane makes the test quite simple, stating, “[t]he question is whether
individuals other than those who own or operate the institution receive a benefit without any
expectation of reciprocity from the recipient.” Serenity Lane, Inc. v. Lane County Assessor
(Serenity Lane), 21 Or Tax 229, 242 (2013) (citing SW Oregon, 312 Or at 91).
In determining whether the conduct of an organization involves an element of “gift or
giving,” courts consider a list of probative factors, none of which is dispositive in isolation.
Serenity Lane, 21 Or Tax at 236; Methodist Homes, Inc. v. Tax Comm’n, 226 Or 298, 310 360
P2d 293 (1961). These factors include:
“(1) Whether the receipts are applied to the upkeep, maintenance and equipment of the institution or are otherwise employed;
“(2) Whether patients or patrons receive the same treatment irrespective of their ability to pay;
“(3) Whether the doors are open to rich and poor alike and without discrimination as to race, color or creed; and
FINAL DECISION TC-MD 160267R 10 “(4) Whether charges are made to all and, if made, are lesser charges made to the poor or are any charges made to the indigent.”
Serenity Lane, 21 OTR at 236 (citing SW Oregon, 312 Or at 87); OAR 150-307.0120-
(A)(4)(d)(C). In addition to the factors above, the department recognizes that the “gift or giving”
requirement may be met by providing products or services at below-market rates to those in
need. OAR 150–307–0120-(A)(4)(d).
Plaintiff argues that its operations involve several types of gift or giving. First, many of
its events welcome the public at no cost, including free weekly lunches and holiday meals that
are offered in exchange for a suggested donation amount and from which no one is turned away
due to an inability to pay. Other nonprofit organizations, like the local school and library, are
allowed to use the Hall at no cost. In addition, Plaintiff’s activities are staffed by volunteers and
supported by significant contributions from community members. In Samaritan Vill., the court
noted that donations made to the plaintiff “suggest a public determination that [the plaintiff] is
charitable.” Samaritan Vill., 2003 WL 25846514 at *7.
Although many of Plaintiff’s frequent sponsored activities are open to the whole
community at little or no cost, no event rental discount or waiver is offered to those residents
unable to pay to rent the Hall for outside events. However, the fact that Plaintiff collects fees for
rental of the Hall is not fatal to its “gift or giving” argument. Samaritan Vill., 2003 WL
25846514 at *6 (citing OAR 150-307-0120 (A)(4)(C)(iv)). Plaintiff offers its Hall for rent at
rates substantially below market value. Fees collected from paid rentals of the Hall are applied
to upkeep and maintenance of the facilities, while receipts from monthly family dinners are
primarily used to cover the cost of providing the meals. Kiefer testified that any profits made
from these activities are also reinvested in the facilities or in other activities organized by
Plaintiff. In Hazelden Found. v. Yamhill County Assessor, the court held that such receipts can
FINAL DECISION TC-MD 160267R 11 be “used to subsidize other activities of the institution, at least as long as those activities
contribute to the charitable goal of the institution and are not undertaken for private profit.” 21
OTR 245, 252 (2013).
In Oregon Country Fair v. Dept. of Rev., the court analyzed whether a community fair
was exempt from taxation under ORS 307.130. The organization hosted an outdoor festival to
“promote the arts and crafts, the exchange of ideas, the establishment of a community feeling of
unity and enhance an earth-life harmony philosophy.” Oregon Country Fair v. Dept. of Rev., 10
Or Tax 200, 205 (1986). The court found that, while the fair’s activities were “unquestionably
worthwhile and beneficial,” they were not charitable under ORS 307.130 because, in part, the
fair failed to admit individuals regardless of their ability to pay, and because there were no
adjustments made in the charges for the poor or indigent. Id. This case is distinguishable from
Oregon Country Fair, not only because the court over time has expanded its definition of
charity, but because Plaintiff has shown sufficient evidence that it opens its Hall and delivers its
programming for a price below the market value, and frequently for no cost at all. OAR 150–
307–0120(4)(d); see also Samaritan Vill., 2003 WL 25846514 at *7 (finding that the plaintiff’s
performance involved gift or giving based on the facts that the plaintiff charged rents below
market value and “outside groups routinely use[d] the facility free of charge”). Plaintiff is
generous even to the point of its own detriment, as it barely has the income to maintain its
facility. Plaintiff has thus satisfied the third and final prong of the SW Oregon test and has
established that it is a charitable institution under ORS 307.130(2).
B. The organization’s use of the subject property
Having determined that Plaintiff is a charitable organization, the court turns to address
whether the subject property is “actually and exclusively occupied or used in the * * * charitable
FINAL DECISION TC-MD 160267R 12 * * * work carried on” by Plaintiff. ORS 307.130(2)(a). The Oregon Supreme Court has
construed the term “exclusively” to mean the primary, rather than the incidental use of the
property. Mercy Med., 12 OTR at 308 (citing Multnomah School of the Bible v. Multnomah
County, 218 Or 19, 29, 343 P2d 893 (1959)). If “the activity undertaken on the property
substantially contributes to the furtherance of the charity’s goals,” the property will be exempted.
Young Men’s Christian Association v. Dept. of Rev., 268 Or 633, 635, 522 P2d 464 (1974). The
Oregon Supreme Court has also held that the use of a property should be reviewed in the specific
context of the organization’s charitable purpose. Habitat for Humanity of the Mid-Willamette
Valley v. Dept. of Rev., 360 Or 257, 266, 381 P3d 809, 814 (2016) (finding that because plaintiff
organization’s charitable purpose was to acquire vacant lots and build housing on those lots for
sale to low-income families at below market prices, plaintiff was actually using the vacant lots to
further its charitable purpose).
Charitable use of the property is distinctly different from charitable use of proceeds
derived from use or from fund-raising activities conducted on the property. As Defendant points
out, Oregon does not recognize the “destination of income” theory for tax exemption purposes.
The department provides an illustrative example: “[U]se of property by a charitable organization
as a bingo parlor to raise money for a charitable activity is not an actual charitable use of the
property, and does not qualify the property for exemption.” OAR 150–307–0120—(A)(4)(a);
see also The Round Up Ass’n v. Umatilla County Assessor, TC-MD 110865N, 2012 WL
6737188, at *10 (Or Tax Dec. 28, 2012). While Plaintiff admittedly has hosted bingo events in
the past, it did not host any bingo events in the tax year in question. It would be unfair to
construe intermittent bingo nights in years past as Plaintiff’s primary use of the subject property.
During the tax year in issue Plaintiff did not, in fact, operate a bingo parlor.
FINAL DECISION TC-MD 160267R 13 Instead, Plaintiff uses the subject property as a community hall, offering meals and
programming for the enrichment of the Prospect community. Plaintiff allows any person to use
the Hall at a rate below the market value for such a facility, giving individuals and organizations
a place and an opportunity to gather to celebrate, learn, grieve, eat, dance, and be together in a
variety of circumstances. The facility is not leased by or used for any commercial purpose, and
the incidental profits, if any, are used for the maintenance of the facility and furtherance of the
organization’s goals. In other words, Plaintiff’s primary use of the subject property is sharing it
with the community in furtherance of its stated purpose to provide a “venue for the community.”
III. CONCLUSION
After consideration of the evidence and testimony, the court concludes that Plaintiff
meets all of the requirements necessary to qualify as a charitable institution within the meaning
of ORS 307.130. Accordingly, Plaintiff is entitled to property tax exemption under
ORS 307. 130 for the 2016-2017 tax year. Now, therefore,
IT IS THE DECISION OF THIS COURT that Plaintiff’s appeal is granted.
IT IS FURTHER DECIDED that Plaintiff’s request for costs and disbursements is
granted. Plaintiff is awarded costs and disbursements in the amount of $334.85.
Dated this day of June 2017.
RICHARD DAVIS MAGISTRATE If you want to appeal this Final Decision, file a complaint in the Regular Division of the Oregon Tax Court, by mailing to: 1163 State Street, Salem, OR 97301-2563; or by hand delivery to: Fourth Floor, 1241 State Street, Salem, OR.
Your complaint must be submitted within 60 days after the date of the Final Decision or this Final Decision cannot be changed. TCR-MD 19 B.
This document was filed and entered on June 21, 2017.
FINAL DECISION TC-MD 160267R 14