IBEW Local 305, Inc. and the International Association of Bridge, Structural, Ornamental and Reinforcing Ironworkers Local No. 147 each own property in Allen County which they lease to charitable trusts that are run by Joint Apprenticeship Training Committees (JATCs). The JATCs provides education and training to apprentices in the electrical and iron-working industries.

The property owners filed applications seeking total exemption from property tax for the 2020 and 2022 tax years. The County granted only partial exemptions, resulting in an appeal to the Indiana Board of Tax Review. On March 10, 2025, the Board issued a final determination and concluded that neither charitable trust qualified as a “school” within the meaning of Indiana Code section 6-1.1-10-36.3(c)(2), again denying the requests for full tax exemptions.

Local 305 and Local 147 each filed appeals with the Indiana Tax Court, arguing that their lessee charitable trusts each qualify as a “school” under Indiana Code section 6-1.1-10-36.3(c)(2) and therefore qualify the subject properties for total tax exemption under Indiana’s predominant use standard. The Assessor disagrees, arguing that the trusts are not schools, and thus the subject properties only qualify for exemptions proportional to their use under subsection (c)(3) of the same statute.