In Matter of Genesee Hosp. v. Wagner (47 AD2d 37 [4th Dept 1975], affd on opn below 39 NY2d 863), the petitioning hospital built a Doctor's Office Building contiguous to its hospital and rented out parts of it to physician staff members who carried on their own private practices there. The assessor determined that the building was taxable. In arguing that the office building was reasonably incident to its purpose and thus tax exempt, the hospital emphasized, as petitioner does here, that the building's proximity to the hospital served to attract well-known and high-quality medical personnel thereby enhancing patient care and improving the hospital's teaching quality. The Court was unpersuaded, noting: "The private practice of medicine by a hospital's attending physicians is primarily a commercial enterprise only incidentally related to the hospital's function of providing health care to the community. The concept and development of a professional office building adjoining a hospital facility is an admirable addition to the community and doubtless will improve the teaching and health functions of the hospital. However, it is also a facility which is in direct competition with privately developed professional buildings in an area which serves the identical function as far as the private practice of medicine is concerned. As it presently exists, the Doctors Office Building, insofar as the attending physicians are concerned, is primarily the place where they earn their living with the additional convenience of proximity to the hospital" (47 AD2d, at 46).