OPINION
SNOW, Judge.
¶ 1 Pima County, its Board of Supervisors, Assessor, and Treasurer ("the County") appeal from a summary judgment that declared the property of University Physicians, Inc. ("UPI") exempt from ad valorem taxation under Arizona Revised Statutes ("A.R.S.") § 42-11107 (1999). The tax court's judgment also refunded the taxes UPI paid Pima County on UPI's real and business personal property for tax years 2000 and 2001.
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