SMITH, Justice.
This case involves the recovery of taxes paid mistakenly to one municipality while owed to another. College Park sued Eastern Air Lines, Inc., the City of Atlanta, and the Revenue Commissioner of the State of Georgia, challenging the validity of a 1960 Act (Ga. L. 1960, p. 3040) by which Atlanta attempted to annex certain land constituting a portion of the Atlanta airport. College Park contended that the
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