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OPINION

Orange County Appraisal District (appellant) appeals the trial court’s rendering of a judgment ordering appellant to enter property owned by Agape Neighborhood Improvement, Inc. (appellee) as exempt from ad valorem taxes for the tax years 1998, 1999 and 2000. Appellee first sought tax exemption from appellant. When appellant denied appellee’s application and the Orange County Appraisal Review Board upheld this denial, appellee brought suit. As noted above, the trial court rendered judgment in appellee’s favor after a bench trial on stipulated facts. Appellant then prosecuted this appeal.

Appellant presents two issues for our consideration, viz:

 
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