OPINION
GERBER, Judge.
The taxpayer, People of Faith, Inc., has brought this appeal from a written opinion of the Arizona Tax Court granting appellee Arizona Department of Revenue's motion for partial summary judgment. For reasons which follow we dismiss the appeal.
The taxpayer is an Arizona non-profit corporation licensed by the State to operate a 100-bed nursing care facility. Pursuant to Arizona Administrative Code (A.A.C.) R15-5-2320(C), the taxpayer...
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