Untitled Texas Attorney General Opinion

E ATT-S NEY GENERAL CD EXAS Mr. Joe Resweber Opinion No. C- 697 County Attorney Harris County Re: Whether Clareivood House, Houston, Texas an elderly persons’ retirement home, is exempt from ad valorem taxes as an institution of purely Dear Mr. Resweber: public charity. In connection with your request for an opinion on the above captioned matter, we have been advised of the follow- ing facts. Clarewood ~House, hereinafter referred to as the Home, is owned by the Sharpstown Tower Corporation, which is incorporated under the Texas Non-Profit Corporation Act for the oharitable or benevolent purposes of providing elderly persons with housing facilities and were specially designed to meet the physical, social, and psychological needs of the aged and contribute to their health, security, happiness, and usefulness in longer living. The corporation Is 100s financed as an F.H.A Loan Project. The Commlssloner of Internal Revenue has heretofore granted this corporation a tax exemption as having been organized~and operated exclus%vely for charitable purposes and no part of the earnings of which inures to the benefit of any private shareholder or lndivldual. See Sec. 501(c ( the Internal Revenue Code of 1954, 26 U.S.C. Sec. 501 I c 31 35); also annotations In 69 A.L R.2d 871, 878. The corporation’s property consists of 8.388 acres. of: land loaated In a metropolitan area of Houston, adjacent to the large Sharpstown Shopping Center. The Home was located to avoid isolation from the community and designed to meet the needs of elder1 citizens for adequate housing In that community, costing x 4,700,OOO.OO. It has eleven stories, containing two hundred eighty-eight apartment residence units, each having Its own private bath with tub or tub-shower combi- nation. There are no’:ateps in the Home; only elevators and inolines which have handrails are provided,- with some units having side door ovens and baths for wheel-chair residents. A specially designed nursing aare unit is connected to the -3&a- Mr. Joe Resweber, Page 2 (C-697) Home by covered passageways and ramps. Included in the unit are rooms for occupational therapeutic activity of several kinds and rooms for residents requiring nursing care by resident nurses. A twenty-four nursing unit is provided at rates which the residents can afford to pay and at a rate well-below the prevailing rates in 'hiouston. A furnished chapel and various recreational areas' are available to all without cost, Much, of the cost of operating the Home is to be paid for by contributions or donations, which now exceed $450,000.00. No founder's or finder's or admission fee is charged, but those residents who are financially able to pay for their care are charged a fee on a basis determined by the Board of Directors. Admission.,in each case is determined on its own merits and as a matter of mutual agreement. Hotel-type room and bath, with 288 square feet normally bring a fee of $80.00 monthly; efficiency units of 354 square feet for $100.00 monthly; the one-bedroom, living dining combination, with kitchen, electric range, and more elaborate facilities for $150.00 monthly; two- bedroom, two-bath apartments extensive facilities and con- taining 780 square feet for $190.00 monthly, ten of which are specially designed for wheel-chair tenants. Additional elaborate facilities include a library, game room, beauty shop, restaurant, hobby rooms, auditorium for lectures and cultural events, telephone and message service, coin-operated laundry, and sun decks. All apartments are air-conditioned with a picture-window view.. and have,,tile flooring. When it becomes debt-free, the land and buildings are required to be deeded to the First Methodist Church. Fifteen units In the Home have so far been set aside for use by retired persons unable to pay for such facilities, three of which are oocupied by tenants paying no rental and six of which are occu led by tenants paying only partial rental. Thus nine of the 28 2; apartment units havebeen occupied by tenants who are unable to pay the normal rental charges, and at this time, an additional six patrons unable to pay are being added as tenants. The Board of Directors assert they are increasing the number of full and partial charity tenants just as fast as resources permit! Revenues have not been sufficient to pay the debt charges and all operating expenses and over $450,000.00 In deficits have had to be raised by donations. Although It was a group of Individuals who organized the Home, It Is non-sec- tarian, with most denominations represented by tenants. The average age of the 275 residents Is 77. Sixty per cent of them receive Social Security benefits,~ sixty-five per cent being under 72; and one-third of the residents would face serious -3353- Mr. Joe Fiesieber, page 3~ (C- 697) difficulty without the social security. All are unemployed but five. The Board of Directors have avoided requiring infor- mation smacking of a “pauper’s oath” or disclosure of their amount of income; but in all cases it asrrertains that the aged persons are “needy” and it Is satisfied that no recipient of charity Is a property owner. Our rough calculation Indicates that an average apartment unit costs approximately $~~,OOO.OO to ereat. Cn the basis of the information furnished to us in a letter of the Vice President and General Manager, we com- pute the following data relevant to apartments which have been in use on a charitable or part-paid basis, as follows: Total of the usual monthly rental ‘Lpg Total monthly rental charged and oollected . Anount commuted per month as charity 7m.00 When wemultiply this $785.00 per month by 12’, we arrive at ths awn of $9,420.00 which represents part of the charity con- tributed by Clarewood House during a year’a period of time. Under conditions at the date of this writing, it is anticipated that .more than $18,000.00 will be ,-presented as charity for this tax year. In addition, it~ia fair to atate that charity is also preaent not only from the Home paying the entire or partial oosts for some of the residents but also charity,is present with respect to all of the aged residents who are furnished services and facilities at a rate substantially less than cost. We have not attempted to convert this charity into dollars, but it appears that the charity to the public resulting from the operation of the Home is substantial and not merely nominal, aa the revenues have not been anffioient to pay debt charges and operating expenses and over $450,000,00 in deficits have had to be raised by donations. The Home claims exemption from ad valorem taxes under Article VIII, zection 2 of the Constitution of Texas, which provides that . . . the legislature may, by general laws, exempt from taxation . . . instltutlons~ of purely public oharlty; and all laws exempting property from taxation otffer than the property above mentioned shall be null and void. The Legislature, in Article 7150, Section 7, V.C.S. of Texas, provided: -3354 Mr. Joe Resweber, Page 4 (C-697) Public charities. All buildings and per- ,” sonal'property belonging to Institutions of purely public charity, together with the lands belonging to and occupied by such institutions not leased or otherwise used with a view to prof%t, unless such rents and profits and all moneys and credits are appropriated by such institutions solely to sustain such institutions and for the benefit of the sick and disabled members and their families and the burial of the same, or for the maintenance of persons when unable to provide for themselves, whether such persons are members of such institution or not. An Institution of purely public charity under this article Is one which dispenses Its aid to Its members and others in sickness or distress, or at death, without regard to poverty or riches of the recipient, also when the funds, property and assets of such institutions are placed and bound by its law to relieve, aid and administer in any way to the relief of its members when in want, sickness and dis- tress, and provide homes for its helpless and dependent members and to educate and ~maintaln the orph$ns of its-deceased members or other persons. ‘/ In Interpreting the phrase “purely public charity” in our Constitution, Article VIII, Section 2, the word "purely" in the Constitutional provision above quoted modifies the word “charity” and not the word “public” so as to require an lnstl- tution to ha've a wholly altruistic quality and exclude from It every private or selfish interest or profit or corporate gain. Benevolent dc Protective Order of Elks v. City of Houston, 44 . . 4uu, 4 (Tex.Civ.App. 1931, error ref.). The property of the institution must be used wholly and exclusively for charitable purposes and such use of the property must be actual, direct, and exclusive. City of Houston v. Soottlsh Rite Benevolent Assn., 111 Tex. 191 230 S . W. n cannot be used to engage In. a c~ommerclal &siness. gk!;:?' v. Woodmen of the World Life Ins. Society 280 S.W.2d 3r7TTex 55 error ref.). Nor may it bi used to enter into a landlord ani tenant relationshlp'which creates a commercial transaction or lease, particularly where rent is paid. David 371~2d ere actual rent is not paid such ion-charitable use destroys the exemptlon. -3355- Mr. Joe Reaweber, page 5 (C- 697) of Longview v. Markham - McRee Memorial Hospital, 152 S.W.2d (T C A 1941 j . s anta Rosa Infirmary v. City of San Antonioex&?:W~P&6 (T&E. Sup. Ct. 1924). However, our courts inthese cases have clearlv indicated that charitable institu- tions might derive, as an incident of the administration-of the charities, rents and profits where they were devoted directly and solely to those very charities. Moreover, as pointed out In the Santa Rosa Infirmary case, supra, where all facilities are exCluslvely operated by members of the institution, tax exemption Is not lost by the needy patron capable of paying, doing so, for maintenance or for services rendered therein by others not wholly engaged in a charitable work. Nor did the operation of a small drug store in the building destroy the tax exempt structure. The requirement Is merely that the buildings be used and occupied by the charitable Institution and none other. It Is pertinent to observe that such a charitable lnstl- tution aa an Infirmary need not be supported exclusively by gratuities or donations to be exempt from taxation, since it was held in the Santa Rosa Infirmary case, supra, that it does not loae ita exempt status by paying for its plant from inci- dental earnings or expending its funds realized therefrom in training nurses, being within the proper upkeep and maintenance needs for which profits may be appropriated. 7 Baylor Law Rev. 494, 497. From the above authorities, it is also seen that owner- ship as well as exclusive use by the charitable Institution is required tn the sense of a perpetual dedication of the property and the miscellaneous mutations of profits derived to charitable uaea or purposes. No private individual may obtain any profit or gain, or If a corporate owner is involved, no distributable earnings, such as dividends, may result. In addition, the institution must benefit persons indefinite in numbers and oersonalitles. to the end that they will be prevented from becoming burdens to society or to the State.‘ v. Missouri-Pacific Lines Hospital Ass.!n., 99 Civ.App. 1930B error ref.) Cn the other hand, the authorities above cited hold that the chatity is not required to be universal to be public and the institution is not reauired to search out the needy persons on the highways and byways. Raymondvllle Memorial Hospital v. State 253 S.W.2d 1012 (Tex.C?v.App. 1952, error ref., n.r.e.f; eylor Law Rev. 133, 138. The charity is deemed public if It affects all of the people of a state or community through -3356- Mr. Joe Resweber, Page 6 (C- 697) its assumption, to a material extent,‘that whidh otherwise t become the obligation or duty ,of the state or community. YF awme charity Is not necessarily rendered “private” as distinguished from “public’ because limited In sect, class or fraternal order, etc. 11 Baylor Law Rev. 137. It is said ‘oharlty need not be universal to be public.” -City of Palestine v. Missouri-Pacific Lines Hospital Ass’n., supra; B.P.O.E. Lodg V. ty of houston, 44 S W . . 26 4oti (Tex.Clv.App’ 193, error ref. e, . The latest definition and test of charity, as inter- preted by the Supreme Court of Texas. Is set out in River Oaks barden Club v. City of Houston, 370 S.W.2d 851 (1963’). I fl t four decision th Court applied the so-called “q%i pr?qui” idea earlier’exp~essed In City of Houston v. Scottish Rite Benevolent AssIn., supra, wherein It was said that a charitable Institution must meet three criteria to warrant tax exemption: (1) It must make no gain or profit, (2) must accomplish ends wholly benevolent, and (3) must benefit persons indefinite in number by preventing them from becoming burdens on the community or state. 18 Southwestern Law Journal 703, 707-708. It affirmatively appears from the River Oaks Qarden Club case, supra, that first; In order to justly a charitable tax exemption, the institution’s activity Itself must be one in which the state or community could have an obligation to support; and secondly, the institution must substantially tend to lessen that obligation so that the.benefits therefrom run to a relatively, large segment of the public. Further, It cautions us that a charter declaration of the purpose and obligations Is not con- clusive, and we must look further to the actual operations of the institution and the effect and result thereof. No guide- lines are provided as to just what actlv%fles are to be deemed to be government obligations or just what degree, or percentage or extent of charitable benefits must be provided to warrant an exemption. Institutions, though plainly altruistic, will apparently’ not be held to be purely charitable which do not provide provable benefits covering a substantial number of people in those areas falling within the traditional definition of public welfare. Examples are institutions devoted to the promotion of the fine arts of gardening, dramatics, interior decorating, maintenance of historical landmarks, or those arts characterized as “aesthetio”, as evidenced in the River Oaks Carden Club case, supra. It is left to the function of our courts to determine where the line will be drawn and to provide other examples. -3357- $, nr. Joe Resueber, Page 7 (C-697) The problem of applying the rule of River Oaks, supra , to the facts of this or other situations is accurately described in 18 Southwestern Law Journal 703, 711 (1964): ‘Even If the courts interpret the uid ro E standard liberally, the uncertainty %iTi- w lc per- vades the criteria-for charitable exemptions in Texas will work a hardship’onlnstitutione in the ..fringe area. In most cases one should be able to look to the constitution and the exempting statutes to determine whether a narticular oraanisatlon auallfles for exemotion. It is our considered opinion that, assuming an absence of controverey,as to the particular facts submitted, the Home may not be said to fall within the “fringe area.” While the courts have failed to state what they regard as sufficient charitable benefit running to the public, they have said that if It was shown to be “substantial,” the charitable exemption could be established. Based upon the facts submitted to us, it Is our opinion that the substantial benefit test has been met. What is ade,quate housing for the needy aged? According to our governmental current standards of society by 1961, adequate housing !‘means housing which the aged can afford, which meets the special physical needs of the aged, and which is designed to avoid isolation from the rest of the community or an lnsti- tutlonallsed feeling.” (White House Conference on Aging Policy Statement on Housing, January 11, 1961). According to the Polioy Statements and Recommendations of the White House Con- ferenoe on Aging, February, 1961, the average person can now expect to live longer than before - past seventy and into the eighty bracket - and will have longer periods of retirement. We now have five times more people over sixty-five than we had In 1900; the number will double in the next forty years, while the number over seventy-five will triple. In Harris County, Texas, the problem is the same and within the next four years, there will be 108,600 people over sixty-five. The harsh social -3358- Hr. Joe Resweber, Page 8 (C-697) and economic facts revealed in the Conference Report show that suoh a “retired citizen Is one who by reason of age has ceased to work his customary intensity of employment. not engage in other types of part-time occupation.He *y Or 2: regular normal earned Income, however, hae in fact ceased.” The problem, of adequate housing and care for the aged 18 being undertaken as an obligation by all echelons of govern- ment. Drugs and medical care have extended life; the industrial revolution and population explosionhave combined to bring an ever increasing higher standard and quality into the lives of even the poor and needy. What 18 now “decent” and “reaeuaable” houelng and care for the aged was, indeed, luxury when the framers wrote our State Constitution over one hundred years Since the introduction of the common law Into this %,“;e in 1840 the Texas Constitutions have been framed with reference to it. and our Constitution 1s reoulred to be lnter- Qreted in the light of the development of Uie common law as declared by the courts of the The Supreme Court of Texas will apply words in the Constitution to present-day conditions and may find words ‘to have been therein used In a eenee broad enouah to include things not then within human e erience or knowledge. ” Roy v. Schneider, 110 Tex. 369, 221 S.W. 2 8 0, 918 (1920). Since the Supreme Court in River Oaks Garden Club v. City of Houston, BuQra, has said that the framers of our Constitutions Intended the meaning of the charitable exemption to cover “that which otherwise might become the obligation or duty of the community or the state” (370 S.W.2d 854, ~‘s;,c ..I,, it Is therefore necessary to observe what obligations the government has undertaken and how the courts of the country have interpreted purely Qubllti charity in the light of the common law. In addltlon, our Constitution, Art. III, Sec. 51a, authorizes certain expenditures for needy aged persons, and the Le lslature, In Articles 6%c, 6753, 1524b through 1524k, 1528a, 12t 9k has provided extensively for the care and housing of the aged. We do not read Into these governmental obligations an Intent to exclude tax exemQtlon for charitable activities to be undertaken by the citizens themselves. The state government claims no monopoly on charity. The obligation or duty of government under ItB general welfare powers is aa narrow or broad a8 the customs, mores, ethics, standards, and eoolal conscience of it8 people at a -3359- .: r Mr. Joe Retiweber, Page 9 (C-697) particular time. There could therefore be no fixed, unchang- ing, and inflexible meaning of what constitutes "charity," nor do we think the constitutional framers intended to write Into the Constitution a particular standard or social concept ai':tbelr time. The concepts of "general welfare" and "charity" are not etatlc. Needs that were narrow or parochial a century ago are interwoven in our day with the well-being of the community and etate. The' White House Conference of 1961 established the Qrin- ciple and objective that "All aging people . should be ade- quately housed,in a suitable neighborhood of their choice and supplied with community facilities and services at rents they can afford. There Is, and will continue to be, a need for an lhcreaee in all types of housing . . . . The aged have special needa as to both their housing and their total environment. Integral parts of their problem on the planning and developing of 'facilities for the aged - such as transportation, shopping, medical and hospital facilities, utilities, churches, cultured outletcl and congenial neighbors." All of these things the Home in this case sought to provide in a purported charitable way. We have heretofore rendered 0 inion Numbers WW-771 (1960), WW-1277 (1962) ww-1318 (1 w&24 (1962) C-209 (1964) and Opinion No: C-357 (196 ), in which we recognized that hohes for the aged, under the facts submitted, were Institutions of purely public charity and involved that which otherwise might beoome the obligation or duty of the community or state within the legal concepte set out In River Oaks Carden Club v. City of Houston, supra. This is in accordance with the common law meanlna of nurelv DubliC charits in other Surisdlctlons and we ‘, The authorities throughout the nation are generally In accord In upholding this legal concept, as so clearly set out in Flfleld Manor v. County of Los Angeles, sups, 10 Cal.Rptr. at Q. 249 : -3360- Mr. Joe Resweber, Page 10 (C-697) II . . . Relief of poverty 1s not a condition of charitable asalstance: If the benefit con- ferred has a sufficiently widespread social value, a charitable purpose exibts. It is a matter of common knowledge that aged people ': require care and attention apart from financial assistance, and the supply of this care and attention Is as much a charitable and benevo- lent purpose as the relief of their financial wants. Every clvlllz~ed community must provide facilities, either public or private, for the care of old people regardless of financial condition. . . . . . :.. . 'The concept of charity Is not con- fined to the relief of the needy and destitute, for "aged people require care and attention apart from financial asslBtance, and the BUQQ~Y of this care and attention 1s as much a charlta- ble and benevolent purpose as the relief df their financial wants!,' So the 'charge of fees by such an institution aB a home for the aged will not necessarily prevent its classification as charitable If such Bums "go to pay the ex- penses of operations and not to the profit of the founders or shareholders," for all persons~ may "'under certain conditions be proper subjects of charity." In short, as the word "charity" Is commonly unaeistood in modern usage, It does not refer only to aid, to the poor and destitute and exclude all humanitarian activities, though rendered at cost or less, which are maintained to care for the physical and mental well-being of the recipients, and which make it less likely that such recipients will. become burdens on society." 1st Homes, Inc. v. Horn, 226 Ore. 298, ) the court also recognized the o;e authorities, and that such homes for the aged could,.be an exerapt charitable lnatltutlon, 1:' likening them in analogg to the charitable teats applied to hospitals, but denied the exemption upon the ground ,that the facts revealed the lack of any charter provlslon for a contln- uatlon of charitable works aen, the assets were disposed of in the event of corporate dissolution. Other determlnlng factors considered to be relevant in the determination, besides the charter purposes and by-law QroViSion8, Were the aQQllOatlOn L -3361- Mr. Joe Resweber, Page 11 (C-697) or use of receipts; whether patrons received the same ,treatment irrespective of ability to pay; whether the doors of the home were open to the poor as well as the rich and without other discrimination; whether charges were made to all patrons and whether any charges were made to the Indigent; whether a charl- table trust fund was created; and whether If the home had no operational gains, there were offsetting advantages. The Court In Trainee v. St. Petereburg Methodist Rome, Inc., 173 So.26 176 (Fla. Igbb}, recognized that providing homes for the aged wa8 a proper charitable Qurpoae, but denied the exemption upon a showing that the facllltlea were not available to the general public, many applicants were not accepted unless they are able to pay, and,the charter failed to disclose what would happen to its assets in the event of corporate dissolution. In the oaae of Clarewood House, we assume the facts to be true that rufflclent applicants not able to pay are accepted by the Boerd of Directors under the circumstances. The Ohio Supreme Court, in The Phllada Home Pund v. Board 31 (19bb) and the Nebraska Supreme as v. O.E.A.'Senior Citizens, Inc 7l9 725 m denied a chktable whos; purpose war; merely “the furnlah- lng of low cost housing at Its real cost.’ This activity the courta said did not In itself fall within the meaning of “charity,’ declaring that “the reason for exemption Is present benefit to the general public sufficient to justify the loss of tax revenue.” The Institutions were unable to show clearly sufficient facts to satisfy this test. In the County of Douglas case, supra, although it was shown that the Internal Revenue Service and the Treasury Department had ruled that the institution Van owned and operated exclusively for charltable’purposes, the Court nevertheless held to the contrary, saying: “The design and purpoees of the building on the land was to furnish housing to selected people at low cost. There is nothing to Indicate that it was to be below the cost of the service furnished. . . . In fact no right to remain In occupancy other than at the will of the defendant waB a declared purpo:e except as to a limited olass of occupants. . . . (111 N.W.2d 725). -336,s Hr. Joe Resweber, Page 12 (C-697) In the case of Clarewood House, we are advised by the facts submitted that the malti”purQoBe and use Is not the mere fUI?liBhing of relatively low-cost housing to selected people but that charity Is the purpose, and the right to remain in occupancy Is not at the will of the Board. The mere lack of a church sponsor does not prevent the Home from having a chllrl- table exemption. Apparently the cederal government Is satisfied with Its exclusive charitable purpose and use and saw fit to finance it one hundred per cent and give it an exemption from taxes on the ground that it was organized and operated as exclu- slvely charitable. We find no substantial or material distinctions to be made on the facts herein related as to Clarewood House as com- pared to those related in our previous opinions. In Opinion C-357, suppa, for exampl&, Lnvolving &you l%Xio%?,sponsored by the Brazes Presbyterian Church, there was ‘I)o:: more charitable benefit running to the public for Its operation than Is shown in the Clarewood case, In writing this opinion, we have attempted to set out such legal guidelines as exist on the question presented for the benefit of any other Interested parties faced with a similar question. We hasten to point lout, however, that we have assumed that no factual controversy exists between the taxing authority and the party seeking the exemption. In issu- ing official opinions, this office 1s not authorized to resolve disputed factual Issues. Cur opiniona are based solely upon the application of legal principles to the facts submitted to us. If a taxing authority and a party seeking a tax exemption are not in agreement aa to the evidential facta upon which a claim for exemption 1s based, the Qartles must resolve their dlaoute in a oourt of law that Is authorized to resolve dlwuted l.a‘QaG.oulirly true, as stated by the-cited authorities, because the burden of clear proof ls.~.on the one tilalming exemption; exePlptlons from taxation are $5ver favored; and all doubts are resolved against the exemption and in favor of the taxing power. SUMMARY The Attorney General’s office 1s not authorized to pas0 on fact questlone. However, under the facts sub- mitted, which we assume as true and unoontrover&lal, -3363- Mr. Joe Resweber, Page 13 (C-697) Clarewood House is deemed to be an institution of purely public charity which would be entitled to exemption from ad valorem taxes under Article VIII, Section 2 of the Texas Constitution. Yours very truly, WAGGONER CARR Attorney General of Texas APPROVED: OPINIONCOMMITTEE W. V. Geppert, Chairman Pat Bailey Robert Flowers RJoy gYY; . . APPROVEDFOR TIiE ATTORNEY GENERAL BY: T. B. Wright -3364-