The Roseville Library was remodeled in to accommodate increased use. In , the library's first computer system was brought online to handle lending transactions and catalog records. Because of growing communities and increasing use, the Library Board developed a plan for expanded and new facilities. The bonds also financed the rebuilding of the Maplewood and Roseville libraries in During Roos's tenure the library saw substantial increases to the book budget and additional open hours, including Sunday hours.
Roos launched the Dunn Bros.
Coffee Shop at the library in Roseville, the first such library venture in the state. When Roos left in , Alice-Jo Carlson served as interim director and was appointed director in September Carlson instituted alternative revenue projects, such as the Booker Literacy Project and Licensing Program, a line of merchandise, and partnerships with cities within the Library's service area.
When state and county budgets were reduced in , Ramsey County Library suspended service at the library in North Saint Paul to meet budget targets. In March of , a library was opened in the North St. Paul Community Center. County, City and Library officials partnered to develop an innovative plan for library service at this location. As Phase 1 of the plan, the library on Beam Avenue in Maplewood was sold, and in March a new 31, square foot library was opened on a site across from the Maplewood Mall and adjacent to a city park.
Phase 2 of the plan called for the expansion of the library in Roseville. The property immediately north of the library in Roseville was purchased to provide additional parking, and a remodeled and expanded 2-story facility is on the site. Under Minn.
County of Washington, N. Exemptions from property tax liability are strictly construed. Ass'n of Cereal Chemists v.
County of Dakota, N. The ultimate issue before us is whether HealthEast's separate corporate tax status should be disregarded in deciding whether the subject property is tax-exempt under Minn.
Under section Put another way, section Here, HealthEast argues that its arrangement with UMPhysicians comes within this exception because UMPhysicians holds the subject property and uses it for an exempt purpose. Section As we explained in HealthEast I, two general principles apply when a corporation seeks to be disregarded as a separate tax entity. First, we will disregard an entity's separate corporate status for tax purposes only in limited circumstances. Comm'r of Taxation, Minn. In Community Hospital Linen, we considered the tax status of property owned by two cooperative associations which were owned and operated by a group of public hospitals to provide laundry, collection, and printing services to the hospitals.
Several factors led to our conclusion that the cooperatives were merely arms or agencies of the member hospitals. We drew a contrast in Community Hospital Linen to the subsidiary trucking company that sought the status of its tax-exempt parent corporation in Milwaukee Motor Transportation. See Community Hospital Linen, Minn. With the foregoing analytical framework and case law in mind, we now examine the activities of HealthEast, including services it performs for other entities.
Ramsey County contends that HealthEast's services for outside entities demonstrate that HealthEast is not organized solely for and devoted exclusively to the needs of its member hospitals. HealthEast appears to argue that the services should not count against it, either because the outside entities existed for charitable purposes or because the level of services rendered was minimal.
We agree with the tax court that the nature and extent of services performed by HealthEast for several outside entities suggest that we should not disregard HealthEast's separate corporate existence. To understand how we come to this conclusion, we must examine the outside entities served by HealthEast and the services it has provided to these entities.
In its tax return, HealthEast described Portico as.
They provide health care services to low-income uninsured people. HealthEast charges MetroEast at cost. Since , HealthEast has provided employees to Portico, with Portico reimbursing HealthEast at cost for the employees' wages. Nothing in the record suggests that HealthEast's participation in Portico benefits the HealthEast hospitals or care system.
The venture, by providing health care to uninsured Minnesotans, surely appears to benefit the community at large, but a general benefit to the community at large is not part of our test for disregarding an entity's separate corporate status. HealthEast could have supplemented the record on remand in order to show that the Portico venture benefits the HealthEast hospitals or care system, but HealthEast did not avail itself of the opportunity.
Besides Portico, HealthEast has also performed services for several other entities.
First, HealthEast employees provided employee assistance services such as counseling for personal and work related concerns to organizations outside the HealthEast system. We will leave for another day the question of whether we recognize a de minimis exception to the principles we reiterated in HealthEast I for determining the question of separate corporate status for tax purposes. Here, while the revenue from the employee assistance, sign-making, postage, and equipment services is small, when looked at in the context of services performed by HealthEast, we conclude that the services performed for these entities support a conclusion that HealthEast does not exist exclusively to benefit its affiliated hospitals and clinics.
While it is conceivable that the clinic venture indirectly benefits the HealthEast hospitals by giving UMPhysicians' medical students a place to practice, HealthEast did not make this argument. Nothing in the record indicates that the leasing of the clinic property benefits the hospitals.
Given our standard of review in tax court appeals, we conclude that HealthEast has not carried its burden on this issue and therefore we view the clinic lease as an additional indication that HealthEast has a separate purpose and existence from the care system. We do not doubt HealthEast's value to the community. Gustafson, who testified before Senate and House committees that debated the amendment, the amendment served only to expand the term "taxing district" to include counties:. What constitutes the same "taxing districts" has been expanded by statute.
Minnesota case law, after the Hamm [v.
State, Minn. This was changed by the legislature. Comparisons may now be made with property throughout the same county. Enter your email. Weyerhaeuser Co. County of Ramsey Annotate this Case. Supreme Court of Minnesota. November 9, Rehearing Denied December 20, Paul, for relator. Tom Foley, Ramsey County Atty. County Atty. Paul, for respondent. Considered and decided by the court en banc. Paul Kuiters v.