The applicant, a non-profit housing corporation providing affordable and rent-geared-to-income housing, sought a declaration that its three properties were exempt from municipal taxation under section 3(1)12(iii) of the Assessment Act.
The respondents conceded the applicant served the poor but argued it was not 'organized for the relief of the poor' as required by the exemption.
Applying binding appellate authority, the court found that because the applicant's operations were fully funded by government subsidies and tenant rents, and its day-to-day management was outsourced to a for-profit entity, it did not provide relief through its own endeavors or funds.
The application was dismissed.
