OPINION AND ORDER
BAILEY BROWN, Chief Judge.
In this action plaintiff, Southland Mall, Inc., a Maryland corporation with its principal place of business in Tennessee, sues the County Trustee (tax collector), the County Quarterly Court (a legislative body) and the County Commission of Shelby County, Tennessee to recover a refund of realty taxes assessed on plaintiff's shopping center and paid under protest for the year 1967 in the amount of $57,460.
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