GILLERMAN, J.
This is the second presentment in this court of the "complex and detailed" zoning by-law of Plymouth. See Balas v. Zoning Bd. of Appeals of Plymouth, 13 Mass.App.Ct. 995, 996 (1982). The material facts are not in dispute. In 1983, the zoning board of appeals of Plymouth (board) denied the application of the plaintiff V.S.H. Realty, Inc. (VSH), for a special permit
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