Martin Luther Homes v. County of Los Angeles

Plaintiff brought this action against Los Angeles County to recover property taxes on two lots for the 1964-1965 tax year paid under protest. It recovered judgment returning the taxes paid on both lots. The county appeals from this judgment.

The issue presented at the trial and on this appeal is whether these two lots were used exclusively for charitable purposes on the tax lien date (the first Monday in March 1964). If so, then the lots qualify for property tax exemption under Revenue and Taxation Code section 214 and California Constitution article XIII, section 1c.

Although this case involves the taxation of only two improved residential lots, it was necessary for the trial court to examine the entire operation of plaintiff in determining whether its use of this property was exclusively charitable. There is no dispute that plaintiff was a nonprofit corporation organized in such a way that its property would be exempt under section 214 if used exclusively for a charitable purpose. There is no substantial conflict in the evidence as to what plaintiff did. Its eligibility for tax exemption is determined by applying the law to these facts.

Plaintiff was incorporated in…