Texas Attorney General Opinion: WW-1427 Page: 3 of 4
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Mr. Burney Walker, Page 3
The Roosevelt Hotel is being repaired and improved at this
time to meet the requirements of a home for the aged. Informa-
tion from your letter and the Exhibit A attached thereto shows
that the hotel, as of July 3, 1962, has not been conveyed to the
Allen McDonald Foundation.
Your letter further states that:
"According to Exhibit A, the opera-
tion of the Roosevelt Hotel will meet
all of the requirements set forth in
Opinion No. WW-1277. The only addi-
tional point that might be covered is
that whether or not the hotel is now
exempt from ad valorem taxes...."
Although you state that the Roosevelt Hotel is being re-
paired and improved at this time to meet the requirements of a
home for the aged, you also state that Roosevelt Hotel has not
been conveyed to the Allen MoDonald Foundation.
We are not advised as to who was the owner and holder of
title to this propetty on the first day of January, 1962. Since
it was not owned by the Allen McDonald Foundation on that date,
it could not be exempt from taxation for 1962 under the theory
that it is intended to be later used as a charitable home for
the aged.
In Hedgecroft v. City of Houston, 150 Tex, 654, 244 S.Wo2d
632, Petitioner is a corporation organized for the operation of
a hospital, clinic and training school and is an institution of
purely public charity. It acquired titled to the property on
December 30, 1948 and was in the process of altering and improving
from prior to the time title was acquired until May 13, 1949 when
the Hedgecroft Clini.samoved into the premises and started opera-
tion.
Quoting from the opinion, the court said at page 636:
"Petitioner's acst on and before Janu-
ary 1, 1949, as alleged in the petition,
the substance of which has been set out
at the beginning of this opinion, were
part of the necessary preparation and re-
modeling of the building for operation as
a hospital and clindt. The work proceeded
until it was completed on May 13, 1949,
and since that time the hospital and clinic
have been operated as a public charity
The facts alleged show, in our opinion, anOpinion No. WW-1427
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Texas. Attorney-General's Office. Texas Attorney General Opinion: WW-1427, text, August 30, 1962; (https://texashistory.unt.edu/ark:/67531/metapth268040/m1/3/: accessed April 24, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu; crediting UNT Libraries Government Documents Department.