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MILES v. STATE OF GA. DEPT. OF REVENUE

No. CV 491-249.

797 F.Supp. 987 (1992)

Thomas G. MILES and Ida L. Miles, Plaintiffs, v. STATE OF GEORGIA DEPARTMENT OF REVENUE, Marcus E. Collins, Commissioner, Defendant.

United States District Court, S.D. Georgia, Savannah Division.

August 14, 1992.

Attorney(s) appearing for the Case

Alvin G. Wells, Jr., Hinesville, Ga., for plaintiffs.

David A. Runnion, Atlanta, Ga., for defendant.

ORDER AND MEMORANDUM

NANGLE, District Judge.

The defendant's Motion to Dismiss, or in the Alternative, for Summary Judgment is currently before this Court. For the reasons described below, defendant's motion will be treated as a Motion to Dismiss, and as such will be granted.

FACTS

Plaintiffs purchased two food stores in 1986, unaware of the previous owner's sales and use tax delinquencies of...

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