ANDREWS, Judge.
In his capacity as Commissioner of the State Department of Revenue, Collins issued an assessment of local use taxes against C. W. Matthews Contracting Company, Inc. (Matthews), which appealed the assessment to the Cobb County Superior Court pursuant to OCGA § 48-2-59. Both Matthews and the Commissioner moved for summary judgment. The superior court granted summary judgment in favor of Matthews, denied the Commissioner's motion for summary judgment...
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