SMITH, J.
The board of assessors of Westport (assessors) appeals from a decision of the Appellate Tax Board (tax board) abating a conveyance tax assessed pursuant to G. L. c. 61A, § 12, on real estate owned by Milton and Marilyn Adams (taxpayers). We affirm.
Under G. L. c. 61A, the so-called Agricultural Classification Act,
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