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ATTORNEYS FOR PETITIONER: DAVID H. KREIDER EARLE F. HITES HODGES & DAVIS, P.C. Merrillville, IN

ATTORNEYS FOR RESPONDENT: STEVE CARTER ATTORNEY GENERAL OF INDIANA ANDREW W. SWAIN SPECIAL COUNSEL, TAX DIVISION JOHN D. SNETHEN DEPUTY ATTORNEY GENERAL Indianapolis, IN

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IN THE INDIANA TAX COURT
_____________________________________________________________________ ) ) ) Petitioner, ) ) v. ) Cause No. 45T10-0411-TA-50 ) LAKE COUNTY PROPERTY TAX ) ASSESSMENT BOARD OF APPEALS, ) ) Respondent. ) _____________________________________________________________________ THE METHODIST HOSPITALS, INC., ON APPEAL FROM A FINAL DETERMINATION OF THE INDIANA BOARD OF TAX REVIEW FOR PUBLICATION January 10, 2007 FISHER, J. The Petitioner, the Methodist Hospitals, Inc. (Methodist), appeals the final determination of the Indiana Board of Tax Review (Indiana Board) valuing its Primary Care Associates medical offices (PCAs) for the 2000 tax year. The question before this Court is whether Methodist made a prima facie case that the PCAs qualify for a charitable purposes exemption.

FACTS AND PROCEDURAL HISTORY Methodist is an Indiana not-for-profit corporation that owns and operates two acute care hospitals, one in Gary, Indiana (Northlake Campus) and the other in Merrillville, Indiana (Southlake Campus). Methodist as a 501(c)(3) organization. 1 Methodist also owns and operates two PCA medical offices, which are located in Griffith, Indiana and in Merrillville (on Methodist's Southlake Campus). The PCAs are used as primary care medical offices. Methodist performs all PCA billing and The Internal Revenue Service recognizes

collections. Methodist also deposits payments for the services rendered at the PCAs into the same bank account it uses for its acute care hospitals. The physicians and the other staff members who work at the PCAs are employees of Methodist. Methodist, however, does not send patients to the PCAs. Rather, members of the general public seek out the medical services offered at the PCAs from Monday through Saturday. 2 In addition, PCA physicians can admit their patients into Methodist's acute care hospitals if necessary and treat inpatients at the hospital when appropriate. 3 (See Cert. Admin. R. at 24-25 (footnote added).) On May 10, 2000, Methodist sought a charitable purposes exemption for both PCA locations in Griffith and Merrillville. On December 31, 2002, the Lake County

Internal Revenue Code

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