CLIFFORD, Justice.
The Board of Environmental Protection (Board) and the Town of Greene (Town) appeal from a judgment entered in the Superior Court (Kennebec County, Chandler, J.) in favor of Gulf Island Pond Oxygenation Project Partnership (Partnership) on its complaint pursuant to M.R.Civ.P. 80C seeking review of a decision of the Board. The Board and the Town contend that the Board's denial of the Partnership's application for a property tax exemption certificate...
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