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Georgia O'Keefe Museum v. County of Santa Fe

62 P.3d 754, 133 N.M. 297 (2002)

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Georgia O'Keefe Museum v. County of Santa Fe

New Mexico Court of Appeals
62 P.3d 754, 133 N.M. 297 (2002)

  • Written by Heather Whittemore, JD

Facts

The Georgia O’Keefe Museum (the museum) (plaintiff) was a nonprofit corporation in Santa Fe, New Mexico, that exhibited artwork created by Georgia O’Keefe and promoted the arts through educational programs. The museum charged an entrance fee for admission to its physical building and operated a gift shop. Sixty percent of the museum’s budget was allocated to educational programs held on and away from the museum’s property. The museum offered tours, workshops, lectures, and professional-development courses, operated a library, and donated educational materials. The county of Santa Fe (defendant) assessed a property tax on the museum’s property. The museum challenged the assessment, arguing that its property was exempt from taxation under the New Mexico constitution, which provided that property used for educational or charitable purposes was exempt from property taxation. The county valuation protests board (the board) upheld the assessment, finding that the museum’s property was primarily used to operate a museum and gift shop, rather than for educational purposes. The museum paid the assessment and filed a refund action in New Mexico state court. The district court upheld the board. The museum appealed.

Rule of Law

Issue

Holding and Reasoning (Sutin, J.)

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