Hospice care center filed application for tax-exempt status on basis that it is a charitable institution. Illinois Department of Revenue (IDOR) denied exemption, finding that center failed to meet its burden to show that property was being put to an exclusively charitable use. Circuit court confirmed IDOR's determination. Evidence showed that center almost exclusively served people that did not need charitable care; and that it ordinarily expects to be fully compensated for its services; and its charitable expenditures was less than 1% of net services revenue in a year. The two divisions of center are separate, and can be treated differently for tax purposes, as each entity seeking a tax exemption must show its entitlement to an exemption.(PIERCE and WALKER, concurring.
Illinois Appellate Court
Civil Court
Property Tax