OPINION BY JUDGE MacPHAIL, December 18, 1981:
Open Door Baptist Church (Church), an independent fundamentalist congregation, in July of 1976 bought 10.879 acres of land in Lower Macungie Township, Lehigh County. The Church paid taxes on its real estate until September of 1978, at which time the entire tract was dedicated to the "Lord Jesus Christ." The Church then appealed its real estate tax assessment to the Board of Assessment Appeals (Board)
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