BENHAM, Chief Justice.
Marion, a resident of Floyd County, Georgia, owned a boat which was located in Cherokee County, Alabama for some part of the tax year with which this case is concerned. In order to determine tax liability, the Floyd County Board of Tax Assessors, purporting to act under OCGA § 48-5-16, requested that Marion sign an affidavit stating that his boat was indeed located in Alabama for at least 184 days of the tax year. Marion was told that signing...
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