OPINION
BEVILACQUA, Chief Justice.
This is an appeal from a judgment of the Superior Court denying injunctive relief against the collection of certain taxes by the City of Newport. Hereinafter we shall refer to the plaintiff as "St. Clare's" or "the home" and the defendant as "the city."
St. Clare's is a corporation operating a home for the aged in Newport. It had never been taxed by the city from its inception in 1927 until 1970. For the years 1970...
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