ANDREWS, Presiding Judge.
Georgia Emission Testing Company (GET-Co) appeals from the trial court's grant of the motion to dismiss for failure to state a claim against T. Jerry Jackson, the Commissioner of the Georgia Department of Revenue. GETCo sued Jackson and Reheis, the Director of the Environmental Protection Division of the Department of Natural Resources, seeking, pursuant to OCGA § 48-2-35(a), a refund of that portion of the Georgia Motor Vehicle Emission...
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