Per Curiam.
Appellant A.S.M. contends it is entitled to tax exemption because: (1) the taxing authorities are collaterally estopped from taxing its property, (2) it is a "charitable institution" as defined in R.C. 5709.121 and exempt under R.C. 5709.12, and (3) it is a public institution of learning exempt under R.C. 5709.07. In its decision below, the BTA held that the doctrine of collateral estoppel did not apply in this case, and that appellant's use of...
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