SPENCE, J.
Plaintiff, a nonprofit corporation operating a home for elderly people on a "life care contract" basis, brought this action to recover taxes paid under protest for the tax year 1946-1947. It claimed that it was a charitable organization devoting its property exclusively to charitable purposes and so entitled to the benefit of the recently adopted welfare exemption. (Cal. Const., art. XIII, § 1c; Rev. & Tax. Code, § 214.) With certain exceptions...
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