Flashcards Studio

A private, non-stock educational foundation, Stellar Foundation, owns a 20-hectare campus in the City of San Isidro. Eleven hectares are used exclusively for classrooms, a library, laboratories, and student housing. The remaining nine hectares are leased to a private operator who runs a renewable-energy complex anchored by wind turbines and a visitor center open to the public, which generates income for the operator and for the Foundation in the form of rent and royalties. The local assessor denies exemption on the entire property, arguing that the non-exempt use disqualifies the property as a whole. The Foundation contends exemption under Sec. 234 because the property is used for educational purposes. (a) Is the property exempt from real property tax under Sec. 234? (b) If only part of the property is used for exempt purposes, is the exemption applicable to the entire property or only the exempt portion? (c) What is the appropriate tax treatment and what steps should the local government and the Foundation take to resolve the assessment?