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OPINION ON REHEARING

Appellants, Storguard Investments, LLC (“Storguard”) and Maxima Communications Corp. (“Maxima”), filed a motion for rehearing of our July 21, 2011 opinion. We grant rehearing, withdraw our July 21, 2011 opinion and judgment, and issue this opinion and judgment in their place. The disposition of the case remains unchanged.

In this ad valorem property tax case, Maxima sought judicial review of

 
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