OPINION
GLENN A. NORTON, Judge.
The Board of Education of the City of St. Louis and Central Parking System of St. Louis, Inc. sued the License Collector of the City of St. Louis, seeking a declaration that the gross receipts from the operation of a parking garage owned by the Board were exempt from the City's public garage tax. The trial court granted summary judgment in favor of the Board and Central Parking, and the License Collector appeals. We...
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