MARQUARDT, J.
The Gracious Promise Foundation (Foundation) appeals the denial of its application for ad valorem tax exemption by the Board of Tax Appeals (BOTA). We affirm. This court's unpublished opinion filed on April 17, 2009, is withdrawn.
The Foundation is a Kansas nonprofit Internal Revenue Code Section 501(c)(3) corporation that operates 13 programs designed to reduce criminal offender recidivism. See 26 U.S.C. § 501(c)(3) (2006).
The...
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