OPINION
CHRISTIE, Judge.
In this proceeding plaintiff seeks a declaratory judgment exempting the conveyance of property known as 300 Delaware Avenue from the real estate transfer tax of the City of Wilmington. Plaintiff, Unit, Inc., is a general partner of 300 Delaware Avenue Associates (Associates), a limited partnership on whose behalf this suit is brought. At all pertinent times, plaintiff was the owner of the subject premises, which were acquired for...
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