First National Leasing Corporation, Respondent v. City of Madison, Appellant

Summary

The Wisconsin Supreme Court held that x-ray and hospital-type equipment leased to Methodist Hospital of Madison by a for-profit leasing corporation was exempt from property taxation under sec. 70.11(4m), Stats., because the phrase 'used exclusively' refers to the physical use of the property by the qualifying nonprofit hospital, not to the lessor's intangible incidents of ownership such as profit, depreciation, or use of the property as loan collateral. The court further held that the statute, as so construed, was a constitutional exercise of the taxing power because the exemption rests on a reasonable legislative classification rationally related to lowering hospital operating costs and the cost of medical care. The circuit court judgment exempting the property was affirmed. No separate opinions were filed.