RUFFIN, Judge.
Visiting Nurse Health System of Metropolitan Atlanta, Inc. (VNHS) is a nonprofit corporation that provides home health care services. After the Fulton County Board of Tax Assessors (the Board) assessed ad valorem taxes on certain tangible property owned by VNHS, the corporation appealed to the Board of Equalization, which ruled that the property was taxable. Following a de novo appeal to Fulton County Superior Court, VNHS moved for summary judgment...
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