GREGORY, Justice.
In June 1982, the State Revenue Commissioner (Commissioner) entered a "factor order" requiring an 8% increase in the assessments of taxable tangible property on the 1982 Fulton County tax digest so as to achieve a digest of 40% of the fair market value of taxable property. OCGA § 48-5-7(a) (Code Ann. § 91A-1019). Fulton County filed an appeal from this order in which the Joint City-County Board of Tax Assessors of Atlanta and Fulton County...
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