Christian Home for the Aged, Inc. v. Tennessee Assessment Appeals Commission

Christian Home for the Aged, Inc. (the retirement community) (plaintiff), which did business as Appalachian Christian Village, was a retirement community in Johnson City, Tennessee, operated by the Christian Churches and Churches of Christ (collectively, the churches). The retirement community had nonprofit status and was exempt from federal income taxes. The retirement community housed people capable of living independently in cottages or townhouses and required those residents to make a nonrefundable donation of over $62,000. Those who were incapable of living independently lived in efficiency apartments for a monthly rent between $485 and $780 or in a nursing home for $37 per day. The retirement community also offered recreational activities and operated a chapel for religious services. Applicants hoping to live in the retirement community were assessed based on their moral character, relationship to the churches, health, and financial circumstances. The retirement community applied for an exemption from state property taxes based on its religious and charitable purposes. The Tennessee Assessment Appeals Commission (the commission) (defendant) denied the retirement community’s religious and charitable property-tax exemptions except as applied to its chapel, which was used for religious services, and its nursing facility, which was a licensed healthcare provider. The retirement community challenged the commission’s decision in the Davidson County Chancery Court, and the chancellor of the chancery court upheld the commission’s determination. The retirement community appealed.