OPINION
EHRLICH, Presiding Judge.
People of Faith ("taxpayer") appeals from summary judgment denying its claim for a refund of use taxes assessed on purchases of personal property used to construct buildings and facilities at the taxpayer's Royal Oaks Life Care Center that are not part of its Royal Oaks Health Care Center. It also appeals from summary judgment declining to refund penalties assessed against it pursuant to former Ariz. Rev. Stat. Ann. ("A...
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