HILL, Justice.
Citizens & Southern National Bank (hereinafter C&S) is a national banking association organized under the laws of the United States and located in the State of Georgia. In 1975 the City of Atlanta and Fulton County assessed taxes on C&S's tangible and intangible personal property, including motor vehicle taxes. C&S paid the taxes under protest and filed tax refund claims with the city and the county. When these claims were not allowed...
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