Does the exemption stated in Code Section 12-21-2420(4) apply to state, county or other governmental entities, specifically colleges?
No. Code Section 12-21-2420(4) states exempts “…admissions charged by any eleemosynary and nonprofit corporation organized exclusively for religious, charitable, scientific, or educational purposes…” In the Court case of York County Fair Association v. S.C. Tax Commission there was a definition of two basic types of corporations; public and private. A public corporation is created for public purposes only and is referred to as “a body corporate and politic”. A private corporation is the only one which may be for profit or eleemosynary and nonprofit.
