OPINION
OSBORN, Chief Justice.
This appeal is from a judgment entered in a bench tried case allowing the Appellee tax exempt status on a retirement and nursing home in El Paso. We reverse.
The Evangelical Lutheran Good Samaritan Society, Inc., is organized as a non-profit corporation under the laws of North Dakota. It operates, in El Paso, a one hundred unit apartment complex for elderly, retired people who do not need immediate medical care and...
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