In Jamestown Homes of Mishawaka, Inc. v. St. Joseph Cnty. Assessor, 909 N.E.2d 1138, 1144 (Ind. Tax Ct. 2009), a nonprofit corporation, through its participation in the federal government's Section 221(d)(3) program, constructed an apartment complex. See Jamestown Homes, 909 N.E.2d at 1139. Under that program, the federal government covered the corporation's mortgage insurance and subsidized a low-interest loan in an effort "to promote the construction of affordable housing for low to moderate-income families." Id. In exchange for the governmental assistance, the corporation agreed both to rent its apartments to certain income-qualifying tenants and to charge budget-based rents. Id. In its hearing before the Indiana Board, the nonprofit corporation argued that its property was entitled to an exemption because "the provision of 'safe, decent and affordable housing for persons of lower income who could not otherwise afford such housing' was a charitable purpose." Id. at 1140. The Indiana Board denied the exemption, and on appeal, this Court affirmed the Indiana Board's exemption denial. Id. at 1145. In affirming the Indiana Board, the Court explained that the nonprofit corporation failed to provide probative evidence to demonstrate, among other things, that it had lessened the burden of government in meeting the need for affordable housing "because that need was ultimately being met by the government through its mortgage insurance and interest subsidy." Id. at 1144. Moreover, the Court noted in its analysis that numerous jurisdictions had rejected charitable exemptions on similar properties because, ultimately, any "charitable use" was achieved solely as a condition of the agreements with the federal government (i.e., through their use, the properties were not relieving a government burden because the government was providing subsidies and financial assistance to them). See id. at 1143 n.10.