OPINION
EUBANK, Judge.
Tempe Life Care Village, Inc., [hereinafter "Village"] is an Arizona nonprofit corporation which operates Friendship Village of Tempe, a lifetime residential and health-care facility for senior citizens, located in the city of Tempe, Arizona. Since November 25, 1978, Village has maintained the status of a federally tax-exempt organization under § 501(c)(3) of the Internal Revenue Code of 1954, as amended. At issue in this case is...
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