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Provena Covenant Medical Center v. The Department of Revenue

Illinois Supreme Court

925 N.E.2d 1131 (2010)

Relevant factsFree

Provena Health (plaintiff), operating Provena Covenant Medical Center, was denied Illinois charitable property tax exemption in 2002 despite having received it in prior years and despite holding a federal tax exemption; the hospital's funds came overwhelmingly from fee-for-service medical billing, with only about $7,000 in charitable donations and less than 1% of revenue going toward charity care that year. An appellate court upheld the denial, and Provena sought further review.

IssueFree

Whether, in Illinois, an entity seeking tax-exempt status must prove by clear and convincing evidence that it satisfies the statutory requirements of "charitable ownership" and "charitable use."

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