OPINION
HARBISON, Justice.
This action was instituted by appellee to recover real and personal property taxes paid to the Metropolitan Government of Nashville and Davidson County, Tennessee, under protest for the years 1979, 1980 and 1981. Appellee claimed exemption from taxation for its property as a charitable corporation pursuant to T.C.A. § 67-5-212. Both the Chancellor and the Court of Appeals allowed the exemption. The Court of Appeals modified...
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