Woonsocket Hosp. v. Quinn
| Decision Date | 27 June 1934 |
| Docket Number | No. 7525.,7525. |
| Citation | 173 A. 550 |
| Parties | WOONSOCKET HOSPITAL v. QUINN, City Treasurer. |
| Court | Rhode Island Supreme Court |
Action of assumpsit by the Woonsocket Hospital, a corporation, against James W. Quinn, Treasurer of the City of Woonsocket. Case certified to the Supreme Court on an agreed statement of facts.
Decision for plaintiff, and papers ordered returned to the superior court with direction.
Tillinghast & Collins and Greenough, Lyman & Cross, all of Providence, for plaintiff.
Morris E. Yaraus, City Sol., of Woonsocket, for defendant.
This is an action of assumpsit brought by the plaintiff, a Rhode Island corporation, against the defendant, some time treasurer of the city of Woonsocket, to recover certain taxes claimed to have been illegally assessed. The action being at issue in the superior court and the parties having filed an agreed statement of facts, the action was certified to this court for determination of the questions of law involved. G. L. 1923, c. 348, §4.
It appears in the statement that plaintiff is a charitable corporation incorporated by the General Assembly for the purpose of erecting, supporting, and maintaining in Woonsocket a hospital; that it does maintain such a hospital; that the real estate now sought to be taxed was leased in 1012 for a term of years to the P. W. Woolworth Company, and the entire net income derived therefrom has been devoted to the support and maintenance of said hospital for the relief, cure, and general care of the sick and injured; that the net income of the hospital from all sources has been, and now is, insufficient properly to maintain and support the hospital.
The real estate in question with the buildings thereon is situated on Main street in Woonsocket. It was conveyed to the hospital in 1008 by the trustee under the will of Anna Nourse, late of Woonsocket, deceased, to have and to hold the same forever "to be used for the purposes for which the hospital was created." This real estate was never assessed by the city, nor was any tax paid thereon prior to 1931; then, for the first time, it was included in the regular tax assessments of the city, and the tax assessed was paid under protest.
The original charter of the hospital, enacted May 29, 1873, provided as follows:
In April, 1913, section 2 was amended by increasing the authorized holdings of the hospital and by the addition to the exemption clause of the words, "so long as said property," etc. The amended statute is as follows:
In April, 1922, section 2 of the charter was again amended by the removal of any limitation of the amount of the real and personal property which the corporation could acquire and hold.
It is clear from the express provisions of the original charter that the General Assembly intended to foster and promote the relief and cure of the sick in Woonsocket and anticipated that the hospital would be endowed for such purpose. The endowment expected was of both real and personal property. Both kinds of property and the income therefrom were treated alike; no distinction was made with respect to the character of the property or the source of the income; the exemption from taxation was general.
The purpose of the exemption as stated in the charter is "such relief to be so far charitable as its (the hospital's) means and endowments will...
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St. Clare Home v. Donnelly
...of rendering such an account if the property is tax-exempt property which is not liable to assessment. Woonsocket Hosp. v. Quinn, 54 R.I. 424, 430, 173 A. 550, 552 (1934). Property which is wholly tax-exempt is not The city asserts that even if the home is not ratable, its sole remedy is th......
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Delta Airlines, Inc. v. Neary
...be determined not by the policy or the laws of other states but by the constitution and laws of this state." Woonsocket Hospital v. Quinn, 54 R.I. 424, 428, 173 A. 550, 552 (1934). Although this Court has not had occasion to address a lessee's tax status under the exemptions set forth in th......
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KENT CTY. WATER AUTH. v. STATE, DEPT. OF HEALTH
...Gott v. Norberg, 417 A.2d 1352, 1358 (R.I.1980), arise only from constitutional or statutory provisions, see Woonsocket Hospital v. Quinn, 54 R.I. 424, 428, 173 A. 550, 552 (1934). Any taxpayer claiming entitlement to a statutory tax exemption carries the burden of proving that the assessme......
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Howard University v. District of Columbia
...without regard to the use made of the property. In Vanderbilt University v. Cheney, 116 Tenn. 259, 94 S.W. 90, and Woonsocket Hospital v. Quinn, 54 R.I. 424, 173 A. 550, the Tennessee and Rhode Island courts, on facts more or less similar to those in the present case, reached a conclusion d......