HENLEY, Judge.
This is an action by Horizons West Properties (hereinafter plaintiff) against George C. Leachman in his capacity as Collector of Revenue of St. Louis County (hereinafter the Collector) to recover 1975 real estate taxes paid under protest. The Collector's motion to dismiss was sustained and the action dismissed. Plaintiff appealed. The appeal involves construction of a revenue law of this state, § 137.180, RSMo 1969 in particular.
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