The Pennsylvania Commonwealth Court has refused to grant real estate tax exemption to another Section 202 housing for the elderly project. The result is not surprising. The case is interesting because of the grasping-at-straws arguments the taxpayer made to try to come within the state requirement to “donate or render gratuitously a substantial part of its services.” The owner, Rouse Brokenstraw Associates Corporation, is a 501(c)(3) charity that receives rent from the residents and a subsidy from the U.S. Department of Housing and Urban Development. It hires the Warren County Housing Authority to manage the project for a fee. The trial court held, and the Commonwealth Court affirmed, that...