McGINLEY, Judge.
The Erie County Board of Assessment Appeals (Board) and intervenor County of Erie (County) appeal from an order of the Court of Common Pleas of Erie County (trial court) that granted the motion for summary judgment of McDonald, Illig, Jones & Britton (McDonald, Illig) in a real estate tax assessment appeal. The motion requested a determination that a tax exemption under ordinances and a
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