KAPLAN, J.
Mary C. Wheeler School, Inc. (School), is organized under Rhode Island law as a "non-business corporation." It runs a day and boarding school for children from nursery school through secondary school age. The School's main campus is in Providence, Rhode Island, but it also owns a 122-acre tract of open and wooded land in Seekonk, Massachusetts, a few miles away, which it uses primarily for recreation and sports and as an "open classroom" for science and...
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