Petitioners are two nursing homes which were purchased by Presbyterian Manor Homes of Western New York, Inc. (hereinafter Presbyterian Homes) in February 1980. As a result of this transaction, the character of petitioners' operation changed from proprietary to not-for-profit, and petitioners sought real property tax exemptions from local taxing authorities. Exemptions were granted effective for the 1981 tax year and thereafter, but petitioners...
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