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Honorable Joe Resweber, Page 11
I"...The fact that an oragnization performs some charitable acts or engages in some charitable activity is not enough to qualify it for the tax exemption provided in Sec. 2, Art. VIII of the Constitution." But the cases cited in support of this statement involved organizations engaged, not only in charitable activities, but also in unrelated activities distinctly non-charitable in nature. For these reasons we do not think the River Oaks Garden Club case affects the holding of Opinion No. WW-1277 ..and-that since the Manor meets the requirements of Opinion No. WW-1277, it is exempt from ad valorem taxes. SUMMARY Under the submitted facts, Bayou Manor, operated by Brazos Presbyterian Homes, Inc., a charitable corporation, managing a home for older adults in Houston is an institution of purely public charity and is exempt from ad valorem taxes. Yours very truly, WAGGONER CARR Attorney General of Texas retta cregor yne Assistant Attorney Generl MMcGP: sjl APPROVED: OPINION COMMITTEE W. V. Geppert, Chairman W. E. Allen Brady Coleman George Black APPROVED FOR THE ATTORNEY GENERAL BY: Stanton Stone