Does Non-Profit Owner of Property Leased to Charity Qualify For Ohio Property Tax Exemption?
Northeast Ohio Psychiatric Institute v. William W. Wilkins [Richard A. Levin], Tax Commissioner of Ohio, Case no. 2008-0033 State Board of Tax Appeals ISSUE: Does real property that is owned by an organization that qualifies as non-profit under Section 501(c)(3) of the U.S. Internal Revenue Code and that is leased at below-market rates to a charitable organization qualify for exemption from state property tax under Ohio R.C. 5709.121(A)(1)(b)? BACKGROUND: The Northeast Ohio Psychiatric Institute (Northeast) is a wholly controlled subsidiary of Portage Path Behavioral Health (PPBH), a charitable provider of mental health and substance abuse services to residents of Summit County. Northeast is the legal owner of a 5,700-square-foot office building in Akron in which it leases about 62 percent of the available space to PPBH and the remainder to a private psychiatric practice and a private medical laboratory. Northeast also operates a psychiatric consulting and staffing placement service an