MURPHY, Chief Judge.
The issues in this case arise from a Maryland Tax Court decision denying exemption from property tax for the 1983-84 tax year to three apartment buildings for elderly residents, which were owned and operated by a nonprofit, charitable corporation.
I
The record before us discloses that, in 1926, the Baltimore Conference of the Methodist Episcopal Church South built a home for the Conference's elders in Gaithersburg, Maryland....
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