SMITH, Justice.
The appellant, Southeastern Maritime Company (SEM), filed suit against the appellees, Georgia Ports Authority (GPA), and Marcus E. Collins, Sr., the State Revenue Commissioner. SEM sought a refund of taxes collected by the GPA. The trial court granted the GPA's motion for summary judgment affirming tax liability. We reverse.
SEM is engaged in the stevedoring business. During the years of 1982 through 1985, the GPA collected a sales tax from...
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