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Question

Does a Fraternity House qualify for a property tax exemption in Denton, County, Texas? The Alumni Corporation, which is the owner, has 501(c)(7) exempt status. If not, would the Corporation qualify under a different 501 exemption, such as 501(c)(3)?bcprice38967.973836956

Submitted: 1250 days and 19 hours ago.
Category: Tax
Value: $15
Status: CLOSED
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Optional Information:
Denton, Texas

1249 days and 19 hours ago.

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Relist: No answer yet.

Posted by Zhicheng Lai 1249 days and 17 hours ago.

Answer

Please review the property tax examption for state of Texas to see if your orginazation qualify for the exemption.

http://www.window.state.tx.us/taxinfo/proptax/tc06/ch11b2.htm#11.18

1247 days and 23 hours ago.

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Reply to Zhicheng Lai's Post: Zhicheng Lai,

I reviewed the Texas Tax Code prior to sbumitting my question to you. It was my hope that someone could make a determination of what Chapter 11.18 (Charitable Organizations) (d)-(20), A,B,C&D is actually saying to me. I also reviewed Cahapter 11.184 (Organizations engaged primarily in performing charitable functions)and questioned subsection (h) which has to do with a letter from the Comptroller.

Once again, Zhicheng, if we filed for and received 501(c)(3) status would we be able to become exempt for Denton, County, Texas property taxes? If you can not answer this question, please pass it on to someone that can!

Thank you!

Clyde Price

Posted by Christopher Phelps 1247 days and 4 hours ago.

Answer

Generally, my concept of a fraternity house is as a social organization established primarily for the benefit of its members. In most cases the Fraternity's primary purposes do not encompass any of the charitable functions described in Title I, Chapter 11, Sec. 11.18(d) of the Texas Property Tax code.

To be entitled to an exemption from property tax pursuant to the above code you organization must qualify under Internal Revenue Code (IRC) Sec. 501(c)(3). If your organization is a standard college fraternity organized primarily as a social organization for its members who occasionaly do charity work, then it will not qualify as a 501(c)(3) organization. Instead you will likely qualify as a non-profit social club or fraternal society under IRC Sec. 501(c)(7) or (8).

Accordingly, unless you can establish that the Fraternity's primary purpose is charitable in nature (meeting one of the criteria in Sec. 11.18(d)) and you qualify for exemption under IRC 501(c)(3), you will not qualify for the property tax exemption.

Because it is impossible for me to identify and consider ALL the relevant facts, this advice is not intended or written to be used for the purpose of avoiding penalties, and cannot be used for that purpose.

1246 days and 19 hours ago.

Reply

Reply to Christopher Phelps's Post: Christopher,

As I stated in my original question, we are 501(c)(7) tax exempt and we are an Alumni Corporation that owns a Fraternity House for the benefit of student members. All I'm asking is, if we filed and received 501(c)(3) exempt status. Would we be able to become property tax exempt in Denton County, TX?

Thanks!

Clyde

Posted by Christopher Phelps 1246 days and 5 hours ago.

Answer

As I indicated above, if you qualify to be a 501(c)(3) organization for Federal tax purposes and if the reason for your qualification is that your organization performs one of the functions listed in Sec. 11.18(d) of the Texas Property Tax code, then yes you will qualify for the property tax exemption.

What you need to tell me is whether your fraternity has as its primary purpose, one of the activities listed in Sec. 11.18(d)(http://www.window.state.tx.us/taxinfo/proptax/tc06/ch11b2.htm#11.18)? If your fraternity has as its primary organizations objective one of the items listed, then you will qualify for both the 501(c)(3) and the property tax exemption.

Because it is impossible for me to identify and consider ALL the relevant facts, this advice is not intended or written to be used for the purpose of avoiding penalties, and cannot be used for that purpose.

 

1245 days and 18 hours ago.

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Reply to Christopher Phelps's Post: Christopher,

18-d 20)Indicates that if we provide housing on a cooperative basis if (A)We are 501(c)(3) but (B)Membership is limited.

#1. I'm not sure what cooperative housing is?
#2. Membership in a Fraternity is limited to those chosen by current members.

Could you explain cooperative housing for me?

It appears that even with a 501(c)(3), we would be out of luck..because of #2 Membership is limited.

What are you thoughts?

Clyde Price

How much additional do you

Accepted Answer

Sec. 11.18(d)(20)(B) says, "membership in the organization is open to all students enrolled in the institution and is not limited to those chosen by current members of the organization". Based on the assertion that membership is limited to those chosen by current members, you will not qualify under this provision.

Most standard college fraternities will not qualify as 501(c)(3) organizations because they generally do not embody the typical charitable, religious, scientific, literary or educational (i.e. providing education) objectives. Rather, fraternities are more analogous to social organizations which typically qualify under 501(c)(7) like your alumni corporation. Co-operative housing is typically housing provided to low-income individuals at below market rates. What the IRS and state are looking for is an organization thats dedicated to providing housing to individuals who could not otherwise afford it.

Because it is impossible for me to identify and consider ALL the relevant facts, this advice is not intended or written to be used for the purpose of avoiding penalties, and cannot be used for that purpose.

 

chris2138973.0089049769

Expert: Christopher Phelps
Pos. Feedback: 99.7 %
Accepts: 2670
Answered: 9/13/2006

Certified Public Accountant (CPA)

CPA, CFP, PFS, Tax Practitioner 21 Years, Member AICPA/CSCPA Tax/Financial Planning Committee Member

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