Form Pt 05-34 - Property Tax Claim - Charitable Ownership/use Page 15
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16SPI’s funding, his characterization of SPI’s admissions or rental charges as donations,
and SPI’s putative waiver of admission charges for those unable to pay, in each case,
constitutes a conclusion that has no documented, factual support in the record. Tr. pp. 61-
63 (Grandin). At the very least, I have reason to doubt Grandin’s testimony that SPI
would receive donations, as opposed to rental fees, from others for using Vasa Park when
it was not used by SPI (Tr. p. 61 (Grandin)), since SPI’s exemption application, and its
response to discovery in this case, stated just the opposite. Department Ex. 3, p. 3 (“When
Vasa Park is not being used for the three festivals, IDVPA occasionally rented the park
out to others for private use. … The standard fee for rental of the park is $1,000 for the
first 4000 people attending and $2 for each additional persons attending. ***”);
Department Ex. 2 (“[SPI] intends to continue the practice of granting similar picnic
licenses, etc. to various groups to use the park when it is otherwise empty.”).
Related to this point, SPI argues that it offered financial records to document the
funds derived and expenses related to the use of the Vasa Park property in 2003, but that
those records were denied admission. Tr. p. 91. That exhibit was objected to by the
Department, and denied admission at hearing, because it was identified as being the
“income and expense statement as of December 31, 2003, for [IDVPA].” Tr. pp. 50-52.
Another entity’s financial books and records are simply not relevant to show the sources
of SPI’s funding, or the manner in which SPI used such funds during the short year
period.
Based on the foregoing, and with regard to the sixth Methodist Old Peoples Home
factor, I must reject one of SPI’s closing arguments. SPI asserted that its admission that
it conducted no financial operations during the applicable short year must lead to a
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