CARLEY, Justice.
The City of Willacoochee (City) enacted an ordinance which imposed a 4% tax on the gross revenue paid to a secondary electricity supplier by residents of the municipality. Before the first payment of the tax ever became due, however, the Satilla Rural Electric Membership Corporation (EMC) filed suit, seeking declaratory judgment as to the invalidity of the ordinance and injunctive relief against its enforcement. Several days after the complaint was...
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