LYLE, J.:
This appeal, a consolidation of five tax appeals, was taken by the Riley County Board of County Commissioners after the district court affirmed the decisions of the Board of Tax Appeals (BOTA). BOTA found Chris L. and Laurine A. Karsten, et al., (applicants) were exempt from payment of ad valorem property taxes on their automobiles under the Soldiers' and Sailors' Civil Relief Act of 1940.
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