GALLAGHER, Associate Judge:
The Washington Theatre Club, Inc., (hereinafter referred to as Theatre Club) is a professional resident theatre and drama school in this city. In 1969, appellant applied to the Property Assessment Division, District of Columbia Department of Finance and Revenue, for an exemption from real estate taxation on the basis that it was an educational institution within the meaning of D.C.Code 1973, § 47-801a(j).
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