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  5. 748 N.E.2d 1230 (2001)
 

UNITED METH. VILL. RET. COMMUNITIES, INC. v. PROP. TAX APPEAL BD.

No. 5-00-0081.

748 N.E.2d 1230 (2001)

321 Ill. App.3d 456

255 Ill.Dec. 160

UNITED METHODIST VILLAGE RETIREMENT COMMUNITIES, INC., Petitioner, v. The PROPERTY TAX APPEAL BOARD; and Max E. Coffey, Brent S. Bohlen, Homer R. Henke, Mark W. Peterson, Sharon U. Thompson, Members of the Property Tax Appeal Board, Respondents (Alton Community School District No. 11 and The Village of Godfrey, Intervening Respondents).

Appellate Court of Illinois, Fifth District.

April 25, 2001.

Attorney(s) appearing for the Case

James S. Sinclair, Stobbs and Sinclair, Alton, for Petitioner.

James E. Ryan, Attorney General, Joel D. Bertocchi, Solicitor General, Marcia L. McCormick, Assistant Attorney General, Chicago, for The Property Tax Appeal Board and its Members, Respondents.

C. Dana Eastman, Jr., Gregory P. Erthal, Thomas, Mottaz, Eastman & Erthal, Alton, for Alton Community School District No. 11, Intervening Respondent.

James E. Schrempf, Coppinger, Carter, Schrempf & Blaine, Ltd., Alton, for The Village of Godfrey, Intervening Respondent.

Justice WELCH delivered the opinion of the court:

United Methodist Village Retirement Communities, Inc. (petitioner), is a not-for-profit corporation formed for the purpose of operating housing facilities for "seniors." In 1996, petitioner purchased three parcels of real estate located in Madison County for the purpose of constructing its housing facilities. On August 7, 1998, the Madison County supervisor of assessments issued to petitioner a "Notice to Taxpayer...

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