The central issue in this appeal is the taxexempt status of a building owned by the Sisters of Charity of the House of Providence, under the provisions of Art. IX, Sec. 4, of the Constitution of Alaska and AS 29.53.020.
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The Sisters of Charity, a long-time healthcare provider in Alaska, erected the building in question, the Providence Professional Building, adjacent to their hospital on land deeded to them in 1959 by the United States for “hospital site, school and recreational purposes only.” The construction of the Professional Building began in 1970; its first full year of operation was 1972.
The Professional Building has four floors, including a basement, and is connected by an underground tunnel to nearby Providence Hospital. Three floors are the subject of this appeal, since the parties agree that the basement and tunnel are used exclusively for hospital purposes and are, therefore, exempt from taxation.
The first, second and third floors are rented to doctors having hospital staff privileges at Providence Hospital, for use as their private office space. Approximately thirty-five doctors rent such space. These doctors, although enjoying staff privileges, are not employed by Providence Hospital, and their patients are not necessarily patients of the hospital. Thus, the actual use made of the first, second and third floors is for office space by doctors engaged in the private practice of medicine.

Questions
For questions, please see the end of The Court Decides: Barnes Hospital v. Collector of Revenue.