This is an appeal by the County of San Mateo, the county assessor, and the State Board of Equalization (County) from a judgment granting a property tax exemption under section 214 of the Revenue and Taxation Code (the welfare exemption) for property owned by the Peninsula Covenant Church (Church). The Church paid proper taxes under protest for the years 1975-1976 and 1976-1977, and then brought an action to recover...
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