The opinion
JUSTICE WOLFSON, dissenting:
I believe the property was used primarily for charitable purposes. The record shows:
1. As recognized by the federal government for income tax purposes, this is a non-profit corporation. Whatever income there is and charitable contributions go back to the medical center to further its operations;
2. The non-profit corporation does not have any stock or any shareholders;
3. The medical center’s board is uncompensated;
4. Physician and staff salaries are at or below market rates;
5. The goal of the medical center is to improve health care in the underserved Hispanic community, in my view a charitable purpose;
6. While patients are billed monthly up to three times, no one ever is turned away for inability to pay. When bills are unpaid they are written off. There are no attempts to collect these bills. Patients are told when they first come in that they will be charged only what they could afford. If a patient is below a certain income, he or she receives no bill;
7. While the medical center could have done a better job of advertising its billing policies, it always conducted its activities in a way consistent with its bylaws and articles of incorporation: “Exclusively for charitable, educational, and scientific purposes”;
8. The medical center relies to some substantial extent on charitable contributions; and
9. This medical center, because it treats anyone who requires treatment, lessens the burden on government and on taxpayers to an extent beyond whatever real estate taxes might be collected.
In short, Alivio is providing low- or no-cost medical care to people who need it. The fact that Alivio does not advertise its write-off policy is not a strong enough fact to offset the medical center’s charitable status. At any rate, the failure to advertise does not add up to an obstacle placed in the way of those seeking treatment.
The facts in this case are more persuasive than those in Lutheran General Health Care System v. Department of Revenue, 231 Ill. App. 3d 652 , 595 N.E.2d 1214 (1992), where we held the medical provider was entitled to an exemption from real estate taxes. There, too, the provider charged fees, although it received some charitable contributions. Staff people received salaries. No one made a profit. Revenue was plowed back into the operation. If patients could not pay, fees were waived. Most importantly, as is true in this case, no one was turned away for inability to pay or for failure to pay prior fees.
For these reasons, I respectfully dissent.