BENHAM, Presiding Justice.
In 1990, Gwinnett I Limited Partnership (GILP) bought an apartment complex in a foreclosure sale and paid the 1989 property taxes under protest. Although the previous owner had not challenged the property tax assessment when it was made, GILP filed a claim for a refund of almost half the tax it had paid, asserting that the 1989 assessment was illegal and erroneous because of improper valuation, lack of uniformity, and lack of equalization...
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