WILKINS, J.
The board of assessors of Lynn appeals from a decision of the Appellate Tax Board (the board) granting abatements of 1970 and 1971 real estate taxes to Shop-Lease Co., Inc. (Shop-Lease). The parties stipulated before the board "that for purposes of this hearing only substantially all properties assessed by the Board of Assessors of the City of Lynn during the years ... 1970 and 1971 were, as a matter of policy, assessed at 30 percent of the fair cash value...
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