OPINION
SUTIN, Judge.
{1} The opinion filed in this case on September 30, 2002, is withdrawn and the following opinion is substituted therefor.
{2} The Georgia O'Keeffe Museum, a private corporation (O'Keeffe), protested the assessment of property tax by the County of Santa Fe (the County), claiming an exemption for its museum property under New Mexico Constitution Article VIII, Section 3. The County Valuation Protests Board (the Board) upheld the...
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