JORDAN, Justice.
The tax officials of Rabun County appeal from an adverse summary judgment order enjoining the collection of ad valorem taxes on a portion of a tract of property owned by the Northeast Georgia Council, Inc., Boy Scouts of America.
The Boy Scouts own 327.5 acres of land in Rabun County on which they maintain a summer camp. In 1975, a tax exemption was granted by Rabun County upon 123 acres of this tract as being property used by an institution...
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