In Cole Hospital, Inc. v. Champaign County Board of Review, 113 Ill. App. 3d 96, 446 N.E.2d 562, 68 Ill. Dec. 656 (1983), a not-for-profit hospital (Cole) with a troubled financial history sought to construct a new patient care facility. After exploring numerous sources of financing without success, Cole struck a deal with a private organization (Safe Care) whereby Safe Care would advance to Cole $ 5.5 million for construction of the new facility. Cole Hospital, 113 Ill. App. 3d at 98. As part of the deal, Cole conveyed legal title to the hospital property to Safe Care, and the property was then leased back to Cole for a term of 20 years. Cole Hospital, 113 Ill. App. 3d at 100. In considering whether the lease divested Cole of ownership, the court determined that Cole had sufficient incidents of ownership to qualify for exemption. Cole Hospital, 113 Ill. App. 3d at 100. Specifically, the court noted that Cole had made extensive efforts to obtain private financing, the lease did not provide for a security deposit, Cole had the absolute option to purchase the property at 10 times the annual rental rate, and Cole had the right of first refusal in the event Safe Care received an offer of purchase. Cole Hospital, 113 Ill. App. 3d at 100. Although the court noted that not every lease will qualify for an exemption, this particular sale and leaseback, which was used as a financing device in place of conventional financing, qualified. Cole Hospital, 113 Ill. App. 3d at 101.