PHIPPS, Judge.
This is an ad valorem tax dispute. The taxpayer is a limited partnership known as Jekyll Development Associates (JDA). JDA is the assignee of a lease originally between the Jekyll Island-State Park Authority (the Authority) as lessor and a general partnership known as Jekyll Club Associates (JCA) as lessee. The subject matter of the lease is the Jekyll Island Resort Hotel, a historic structure. JDA claims that the lease merely gives it a nontaxable...
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