Nonprofit private colleges

From the 2024 DOR Tax Exemption Study

Det. No. 01-015, 23 WTD 121 (2004) 133 Audit's rationale for denying the RCW 82.04.260(12) public and nonprofit hospital classification to the educational programs in audit Schedule 5 for periods after June 30, 1993 is not clearly articulated. We believe, looking at the account names given, that Audit may not have considered these educational programs to be an "integral, interrelated, and essential part" of the hospital operation. If so, the RCW 82.04.260(12) rate was correctly denied. However, if any of these constituted counseling or educational services provided to inpatients, these services would be eligible for B&O tax treatment under the public or nonprofit hospital classification. This issue will be remanded to Audit for further analysis, and Taxpayer will be given the opportunity to present further arguments to Audit relative to this issue. 3. Radiology School Tuition. Taxpayer disagrees with the assessment of tax on tuition income for the Radiology Program, revenues that are a charge for instruction fees. According to Taxpayer, this revenue is similar in nature to the nursing education tuition which was deemed not to be taxable by the Board of Tax Appeals in Deaconess Hosp