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L <br />• SEI has submitted no evidence these taxes were levied either unlawfully, through clerical <br />error, or for an illegal purpose. <br />• SEI has submitted no evidence that granting its request is mandated. In fact, legal <br />precedent appears to prohibit a refund in this case. <br />• It appears to be the taxpayer's claim that this property should have been automatically <br />exempt from taxation. The Redevelopment Commission v Guilford County and City of <br />High Point case illustrates that a fundamental difference exists between an exemption that <br />requires no application versus being automatically exempt from taxation. <br />• The Wesleyan Case provides that, while no application is required for the subject's <br />classification of property, NCGS 105- 282.1(1) does not apply when a taxpayer timely <br />lists property for taxation. <br />For these reasons, it is recommended that the Orange County Board of Commissioners deny this <br />refund request. <br />