Untitled Texas Attorney General Opinion

NEY GENERAL 0F TEXAS September 9, 1966 Honorable Harold Vlttitoe Opinion No. C-75% County Attorney Brooks County Courthouse Re: Exemption from Falfurrias, Texas ad valorem taxes of properties belonging to The Dear Mr. Vlttitoe: Ed Rachal Foundation We have been furnished with several letters and briefs in connection with your request on the above captioned matter. We quote the following excerpt from one of these briefs. "The properties of the Foundation passed under the Last Will and Testament of Ed Rachal, Deceased, which has been duly probated In the County Court of Brooks County, Texas. The Foundation was chartered under the Won-Profit Corp- oration Act for the State of Texas on July 29, 1965. There have been no past charitable activities of th F a ti0n %I view of Its newness, howkeytte lsnned future activities of the Founda- public library area of public charity, and although present plans of the Founda- tion are indefinite, they will be within The limits of its purposes as set forth In its Articles of Incorporation. A copy of its Articles of Incorporation is enclosed for your use, As indicated in the letter to the various taxing author- ities The Ed Rachal Foundation has been held to be exempt from Federal Income Taxes under the provisions of Section 501 a as a corporation described in Section 501 11 c (3) of the Internal Revenue Code inasmuch as the corporation is organized and operated exclusively for charitable purposes. For the same reason the Office of the Comptroller of Public Accounts for the State of Texas has ruled The Ed Rachal Foundation exempt from Franchise Taxes as a p'urelypublic charity." (Emphasis Supplied.) -3645- Honorable Harold Vittltoe, Page 2 (c-758), At the outset, the fact that The Foundation has been held to be exempt from federal income taxes and has been ac- corded an exemption from franchise taxes by the Comptroller, is not determinative of exemption from ad valorem taxes. Section 2 of Article VIII of the Constitution of the State of Texas empowers the Legislature to exempt;from taxation certain enumerated properties, among which are e .institutions of purely public charity." Section 7 of Article 7150, Vernon's Civil Staututes, which was enacted in pursuance to the fore- going Constitutional authorization, reads as follows: "Public charities. - All buildings be- longing to institutions of purely public charity, together with the lands belonging to and occupied by such institutions not leased or otherwise used with a view to profit, unless such rents and profits and all moneys and credits are appropriated by such institutions solely to sustain such institu- tions and for the benefit of the sick and disabled members and their families and the burial of the s&me, or for the maintenance of persons when unable to provide for them- selves, whether such persons are members of such institutions or not. An institution of purely public charity under this article is one which dispenses Its aid to its members and others in sickness or distress, or at death, without regard to poverty or riches of the recipient, also when the funds, prop- erty and assets of such institutions are placed and bound by its laws to relieve, aid and administer in any way to the relief of its members when in want, sickness and dis- tress, and provide homes for its helpless and dependent members and to educate and maintain the orphans of its deceased members or other persons." We have been furnished with considerable information about properties, both real and personal, located in Brooks, Cameron, and Webb Counties, Texas, as well as with certain arguments that the use to which said properties are presently being put justifies the allowance of charitable exemptions. Since we do not agree, we do not deem it necessary to take up the uses of said properties at this time, since, as stated in the above quoted portion from one of the briefs, there have been no charitable activities by the Foundation in view of its newness and, at the moment, there are only planned -3646- . Honorable Harold Vittitoe, Page 3 (c-758) future charitable activities, the precise nature of which have not been determined. Numerous decisions of our courts clearly establish the rule that in order to gain the exemption granted by Sec- tion 7 the charitable institution must not only own the pro- perty for which exemption is sought, but must, in addition, make an actual, direct and exclusive use of said property for charitable purposes. Santa Rosa Infirmary v. City of San Antonio, 259 S.W. 926 (T 24). enevolent and Protec&ve Order of Elksec: CT?y oPfPiiouston: oPfPiouston:84 S.W. 26 (T CL A 1931 error ref )* City of Longview v. Markh~~cRe~'Me%ial &pital, 137 Gex. 178 152 S W 26 1112 (1941)' Markham Hospital v. City of LongGiew,~l$l'S.W. 26 695 (Tex: mv. App. 1945, error ref.} The case of Hedgecroft v. City of Houston, 150 Tex. 654, 244 S.W. 26 632 (1952) demonstrates what facts are suf- ficient to constitute 'actual use.' The court was there con- cerned with the following facts. The Hedgecroft Corporation had acquired title to the propert in question through gift and conveyance on December 30, 19$ 8. Before that time the corporation had agreed with a construction company to make the necessary alterations and repairs of the property to fit it for the operation of a hospital, clinic and training school; and beginning with the week ending July 7, 1948, and continuing until December 29, 1948, the construction company had been pre aring plans for repairs and alterations. From August 1, 19ft8, through December 27, 1948, a blue print company had furnished numerous blue prints concerning the ccntemplated repairs. Prior to the corporation's acquisition of the prop- erty in question and immediately thereafter including January 1, 1949, the corporation was engaged in planning and making the necessary repairs. The remodeling was completed on May 13, 1949, to an extent which allowed the clinic to move on to the premises; and the clinic had since been continuously in op- eration there. The City of Houston and the Houston Indepen- dent School District instituted a suit for taxes for the yerr 1949. In holding that the property in question was exempt, the court reviewed decisions in other States in which exemp- tion had bean accorded on the basis that if the subsequent use of the premises created a tax exempt situation then a use which was confined to readying them for such purpose esta- blished a right to exemption. At page 636 the court said: -3647- Honorable Harold Vittltoe, Page 4 (C-758) I, The work proceeded until it was com- pieied on May 13, 1949, and since that time the hospital and clinic have been operated as a public charity. The facts alleged show, In our opinion, an actual and direct use of the property on and prior to January 1, 1949 . __9 for the charitable purpose." (Emphasis suppliZE)- The most recent case involving the exemption of prop- erties belonging to a charitable foundation is David Graham Hall Foundation v. Highland Park, et al. 371 S.W. 2d '(62 (T Ci A 1963 f I The court was' co~~erne~'wi~~'the f~lE~:~~g'~a~~s",~'~;,Ced at page 765 of the opinion: "The David Graham Hall Foundation was established in 1940. Its corporate charter recites that it was created for the 'support of any benevolent, charitable, educational or missionary undertaking.' Over the years it has engaged In many laudable activities, among them the study, prevention and cure of communicable diseases, the establishment of blood banks, etc. "The Foundation is sole owner of the property in question, Lot 16 of Block 87, Highland Park 4th Installment. The dimen- sions of the lot are 250' by 250'. On it four buildings are located: a main build- ing and three residences. "The main building houses the Founda- tion's administrative offices and labora- tories. This building also houses the ad- ministrative offices of the David Graham Hall Trust, a related but separate organi- zation. The Trust owns many properties the revenue from which is devoted to the support of the Foundation. . . . "Of the three residences on the property, two of.them are rent houses, the revenues from which are devoted to the Foundation's acti- irities. The third residence Is known as the caretaker's house. This house has also been rented form indet,ermina+eperiod for the sum of $50.00 per month. During World War -3648- Honorable Harold Vittltoe, Page 5 (C-758) II these houses were occupied ~j.npart at least at a nominal rental by war refugees who performed services for the Foundation.” The court held that the property of the charitable organization was not exempt from the payment of ad valorem taxae since the particular property in question had not been used exclmeively for charitable purpoeee. At page 764, the court stated: - “As was pointed out by our Supreme Court recently it will not suffice for one to show that he cornea within the statutory proviaiona for tax exemption if the facts do not bring his caea with- in the requirements for tax exemption aa laid down in Art, VIII, Sac. 2 of our State Constitution. River Oak8 Garden Club v. City of Houston, Tex. 370 S.U. 26 851. . . . . . . n The aonrtitutional requirement is two-f&r the property must be owned by the organization alaiming the examp- tion; and it muat be exclurmively used by the organization, ae distinguished from a partial uaa by it and a partial use by others whether the others pay rent or not. A th itiee, omitted -7 . . . (J&ha6is”th%e) It is our opinion that under the decisions above cited none of the properties belonging to the Foundation are now exempt from ad valorem taxes, because said properties are not presently being devoted to the actual, direct and ex- clusive charitable use requisite to exemption. SUMMARY The properties belonging to The Ed Rachal Foundation are not now exempt from ad valorem taxes be- cause said properties are not presently being devoted to the -3649- Honorable Harold Vittitoe, Page 6 (C-758) actual, direct and exclusive charitable use requisite to ex- emption. Yours very turly, WAGGONRRCARR Attorney General of Texas MMcGP:lr APmOVED: OPINION COMMITTEE W. V. Geppert, Chairman Arthur Sandlin Jack Goodman John Pettit Pat Bailey APPROVED FOR THE ATTORNEX GENERAL BY: T. B. Wright -3650-