Judgment reversed, on the law, without costs or disbursements, petition granted and respondent is directed to enter the subject property on the assessment roll as exempt from taxation and to refund to petitioner the real property taxes on the property that were paid by it.
Since the statutory criteria of section 421 of the Real Property Tax Law were met, the exemption should have been granted (see Matter of Erie County Agric. Soc. v Cluchey,
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