McMURRAY, Presiding Judge.
The Cobb County Board of Tax Assessors and the Board of Equalization (the "Board") denied applications for ad valorem tax exemption as a purely public charity under OCGA § 48-5-41(a)(4) filed by the Marietta Educational Garden Center, Inc. (the "Garden Center"). The Garden Center appealed to the superior court for a de novo determination pursuant to OCGA § 48-5-311(g)(3). On cross-motions for summary judgment, the following undisputed...
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