The Supreme Court of Ohio has affirmed the denial of charitable real estate exemption for property owned by a 501(c)(2) title holding company and leased to a 501(c)(3) charity operating a hemodialysis facility on the property. The tenant, Community Dialysis Center, is the sole member of the Leonard C. Rosenberg Foundation, another 501(c)(3) charity, which is the sole member of the title holding company, Chagrin Realty. Chagrin forwards the net rentals to the Foundation. The state law allows exemption for property belonging to institutions, whether charitable or not, that is “used exclusively for charitable purposes.” Any institution may qualify for the exemption if it is making exclusively...