Although much has been written about non-profit organizations in the area of state and local taxation, very little has been written as to tax exemptions granted to these same organizations. This only indicates that the law on this subject is not well developed and remains a source of constant litigation. This situation appears to exist for several reasons. Each state has its own tax statutes with its own definitions and interpretations, and litigation can usually be resolved by referring only to the particular state constitution involved or the Constitution of the United States.
Robert T. Bennett, Real Property Tax Exemptions of Non-Profit Organizations, 16 Clev.-Marshall L. Rev. 150 (1967)