ARCHIBALD, Justice.
As a condition precedent to obtaining an exemption from both real estate and sales and use taxes, Statler Industries, Inc. (Statler) requested a certificate from the Board of Environmental Protection (Board) that water and air pollution control facilities in process of installation qualified for tax exemption. The administrative agency refused to issue the certificate and Statler properly sought review thereof pursuant to Rule 80B, M.R.C.P. The...
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