Wednesday, November 13, 2013

Utah County v. Intermountain Health Care, Inc. case brief

Utah County v. Intermountain Health Care, Inc. case brief summary
709 P.2d 265 (1985)

Plaintiff county sought review of a decision of defendant, Utah State Tax Commission reversing a ruling of the Utah County Board of Equalization. Defendant had exempted a hospital owned and operated by a corporation from ad valorem property taxes.


Defendant, the Utah State Tax Commission, had exempted from ad valorem property taxes a hospital owned by a nonprofit corporation. Plaintiff county sought resolution of two issues, (1) whether Utah Code Ann. §§ 59-2-30 and 59-2-31 (1974), which exempt from taxation hospitals meeting certain requirements, constituted an unconstitutional expansion of the charitable exemption in Utah Const. art. XIII, § 2, and whether the hospitals were exempt from taxation under Utah Const. art. XIII, § 2.


  • The court stated that an entity could be granted a charitable tax exemption for its property under the Utah Constitution only if it met the definition of a charity or if its property was used exclusively for "charitable" purposes. 
  • The court found that the hospitals did not meet this definition and held that defendants had not demonstrated that their property was being used exclusively for charitable purposes under the Utah Constitution.
The court reversed the Tax Commission's grant of an ad valorem property tax exemption to defendants.

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