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  5. 596 P.2d 255 (1979)
 

SISTERS OF CHARITY, ETC. v. COUNTY OF BERNALILLO

No. 12329.

596 P.2d 255 (1979)

SISTERS OF CHARITY OF CINCINNATI, OHIO, a corporation, Petitioner, v. COUNTY OF BERNALILLO, State of New Mexico, Respondent, and Property Tax Department of the State of New Mexico, Respondent.

Supreme Court of New Mexico.

Rehearing Denied June 12, 1979.

Attorney(s) appearing for the Case

Johnson & Lanphere, John M. Kirk, Albuquerque, for petitioner.

Hunter L. Geer, Albuquerque, for County of Bernalillo.

Jeff Bingaman, Atty. Gen., John C. Cook, Asst. Atty. Gen., Santa Fe, for respondent Property Tax Dept.

OPINION

PAYNE, Justice.

Petitioner, Sisters of Charity, paid 1974 and 1975 ad valorem taxes, under protest, on its office building and parking structure. In 1975 petitioner brought suit in the Bernalillo County District Court for a refund of the portion of taxes attributable to those parts of the properties used for charitable purposes. The district court granted judgment for petitioner, the Court of Appeals reversed and we granted certiorari.

Petitioner...

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