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Health Law Keyed to Furrow
Provena Covenant Medical Center v. Department of Revenue
Facts
Provena Hospitals (Plaintiff), one of four subsidiaries of Provena Health, owns and operates six hospitals, including Provena Covenant Medical Center (PCMC) (Plaintiff), a full-service hospital. Provena Hospitals is exempt from federal income tax. The Illinois Department of Revenue (Defendant) determined that while PCMC (Plaintiff) was exempt from retailers' occupation tax, service occupation tax, use tax, and service use tax, it was not entitled to a property tax exemption for charitable organizations based on analysis of the actual amount of "charity" it provided to the community. For example, the amount of aid provided by Provena Hospitals (Plaintiff) to PCMC (Plaintiff) patients under the facilities charity care program equaled only 0.723 percent of PCMC's (Plaintiff) revenues (which was $268,276 less than the $1.1 million in property tax benefits which PCMC sought). Provena Hospitals (Plaintiff) ascribed $25,282,000 of its $739,293,000 total revenue to "other revenue," with no showing as to how much, if any, of it was derived from charitable contributions. Charitable donations made to PCMC (Plaintiff) were only $6,938. Following the denial of the property tax exemption, Provena (Plaintiff) sought review through a suit in state court.
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