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In re Appeal of the Sewickley Valley YMCA

Ruling applying tax-exempt status to real estate owned by YMCA affirmed because the YMCA satisfies the charitable purpose requirements of Hosp. Utilization Project v. Commonwealth and the Institution of Purely Public Charity Act, renders gratuitously a substantial portion of its services, and benefits a substantial and indefinite class of persons who are the legitimate objects of charity.

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ARGUED: February 6, 2001

The Borough of Sewickley (Borough) appeals from the April 19, 2000 order of the Court of Common Pleas of Allegheny County (trial court) that affirmed in part and reversed in part the decision of the Allegheny County Board of Property Assessment, Appeals and Review (Board). In a decision dated November 18, 1997, the Board lifted the Young Men’s Christian Association’s (YMCA) tax-exempt status for 1993 and all subsequent years. The trial court reversed that portion of the Board’s order denying the YMCA tax-exempt status for 74,031 square feet of YMCA property and affirmed that portion of the Board’s order denying the YMCA tax-exempt status for 6,519 square feet of YMCA property. The issue in this case is whether the YMCA qualifies as a “purely public charity” in order to be eligible for tax-exempt status for its real estate. For the reasons that follow, we affirm.

The YMCA is a Pennsylvania non-profit corporation that has been in continual operation since 1894. (Trial court opinion, p.1) The stated mission of the YMCA is “to build healthy spirit, mind and body based on Christian principles, and to improve the quality of life for children, individuals, and families in the Quaker Valley and neighboring communities.” (Id.)

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