ROBERTS, Justice.
The Town of Rockport appeals from a judgment of the Superior Court, Knox County, declaring that Christian Schools, Inc. (CSI) was entitled to property tax exemption for the tax years 1980 and 1981. Rockport maintains that CSI's campus was subject to taxation because (1) a portion of CSI's campus was used for employee housing; (2) CSI transferred such a significant usufructuary interest in the property to the Christian Mutual Life Insurance Company...
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