Justice CHAPMAN delivered the opinion of the court:
On December 7, 1985, Albion Ruritan Club (Albion) filed a certification of exemption request with the Department of Revenue, seeking a property tax exemption for 2.51 acres of land in Edwards County. The County Board of Review recommended that Albion receive a full-year exemption for the property; however, the Department of Revenue (Department) denied the exemption. At Albion's request, an administrative hearing...
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