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W, <br />NO. 831OPTC550 <br />NORTH CAROLINA COURT OF APPEALS <br />Filed: 5 June 1984 <br />IN THE MATTER OF: <br />Appeal of Wesleyan Education <br />Center from denial of exemption Property Tax Comm- 111 -S on for its property for <br />year 1982 == F <br />u1 ~�3 <br />- co <br />Appeal by Taxpayer from the final decision of the :North <br />N <br />Carolina property Tax Commission entered 28 February 1983. Heard <br />in the Court of Appeals 3 April 1984. <br />On 4 March 1981 Kernersville Wesleyan Academy conveyed <br />54 acres of land to Wesleyan Education Center (hereinafter <br />Taxpayer), a non - profit corporation. Since 1974 the property had <br />been exempted from payment of ad valorem taxes. Taxpayer listed <br />the property during the listing period for 1982 but did not apply <br />for tax exempt status until 30 June 1982, approximately four <br />months after the 1982 listing period had ended and after Taxpayer <br />had been notified by the Forsyth County Tax Supervisor that the <br />property was no longer exempt. Also on 30 June 1982 Taxpayer <br />appeared before the—Forsyth County Board of Equalization and <br />Review to appeal the Supervisor's denial of tax exempt status for <br />1982. The Board denied exemption to the property on grounds that <br />no application was filed by Taxpayer during the 1.982 listing <br />period. <br />On appeal to the North Carolina Property Tax <br />Commission, the Taxpayer and County stipulated to the following <br />