A trial court in New York state has held that a nonprofit title holding company exempt from federal tax under Section 501(c)(2) is eligible for a partial real estate tax exemption for property used by its sole member, the Health Science Center Foundation at Syracuse, which is exempt as a charity under Section 501(c)(3). The Court described the New York state law as follows: “real property owned by a corporation organized or conducted exclusively for religious, charitable, hospital or educational purposes and used exclusively for carrying out one or more such purposes is exempt from taxation. The statute requires that the property be owned by a corporation organized or conducted exclusively...