NEBEKER, Associate Judge:
This appeal is from the Tax Division of the Superior Court where appellee taxpayer successfully appealed a second-half 1983 real property tax assessment after the construction of the J.W. Marriott Hotel. The trial court granted summary judgment to the taxpayer and denied the cross-motion filed by appellant, the District of Columbia. The District now appeals. We hold that when the trial court concluded as a matter of law that the assessed...
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