DUBOFSKY, Justice.
We granted certiorari to review the Court of Appeals' decision in West Brandt Foundation v. Carper, No. 78CA683 (July 31, 1980) (not selected for official publication) affirming the Division of Property Taxation's denial of a property tax exemption sought by the West Brandt Foundation (West Brandt) for its property in Clear Creek County, Colorado. We agree with the Court of Appeals' conclusion that West Brandt did not establish that the property...
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