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The Board of Tax Assessors for Columbus, Georgia Tax Board appeals the trial court’s grant of summary judgment to The Medical Center Hospital Authority. The trial court found that eight parcels of real estate owned by the Hospital Authority were exempt from ad valorem property taxes for the years 2009 through 2012. The Tax Board argues that the trial court erred in concluding that the parcels were public property exempt from taxation regardless of how the property was being used. For the reasons that follow, we affirm.

The Medical Center Hospital Authority in Columbus submitted to the Muscogee County Board of Tax Assessors a Request for Non-Taxability for eight parcels of real estate for the years 2009 through 2012. The Tax Board denied the requests. The Hospital Authority appealed the denial of non-taxability to the Muscogee County Board of Equalization, which granted the request as to one parcel, and denied it as to the other seven parcels. The Tax Board appealed the single grant of non-taxability to the superior court and the Hospital Authority appealed the denial of the other seven parcels to the superior court, which consolidated all of the actions. Following a hearing, the superior court granted the Hospital Authority’s motion for summary judgment, holding that all eight of the parcels of real property . . . whose taxability for ad valorem property tax purposes was properly before this court, are determined to be exempt from ad valorem property taxation.

 
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