Alcoser

The San Diego County Construction Laborers Training and Retraining Trust (The Trust) claimed a welfare property tax exemption for real and personal property used in operating a vocational training school to train and retrain persons in skills specifically utilized by the construction industry. It contends such use is exclusively charitable.

The trial court found this “charity” began and ended at home, did not benefit the community in general, and denied the exemption. We affirm.

Factual Background

The facts are not in dispute. The Trust was created by Laborers’ International Union of North America, Local No. 89 and employers who are parties to a construction collective bargaining agreement, to receive and administer employer contributions required by the agreement (Master Labor Agreement of San Diego County). Its stated purpose is to defray the cost of “prevocational, vocational, advancement training, retraining and training programs for work under jurisdiction of the union.” The Trust is administered by six trustees selected by the union and employer parties.

In June 1973, The Trust purchased property which is the subject of this litigation. Since mid-1974, it has…