O'NEILL, C. J.
Appellees sought exemption from property taxation primarily under R. C. 5709.12, which, in pertinent part, provides:
"* * * Real and tangible personal property belonging to institutions that is used exclusively for charitable purposes shall be exempt from taxation. * * *"
To aid in construing this language, the General Assembly enacted R. C. 5709.121, which provides:
"Real property and tangible personal property belonging to...
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