Assessment of Real Property of Integris Realty Corp. v. Oklahoma County Board of Tax Roll Corrections & Mike Means

OPALA, J.,

with whom KAUGER, J., joins, dissenting.

¶ 1 I dissent from the court’s pronouncement because Integris Realty’s summary process evidentiary substitutes do not offer a factual basis for concluding that the rentable square footage of Building B — here in contest — was, during the period in question, used exclusively, on a day-to-day basis, for charitable purposes and hence stands exempt from ad valorem tax liability. I would reverse the summary judgment and remand the cause for further proceedings.