MILLER, Judge.
This action arises out of a ruling by the Fayette County Board of Tax Assessors (the "Board"), that certain inventory held by Aircraft Spruce & Specialty Company, a division of Irwin International, Inc. ("Irwin"), at its Peachtree City warehouse was not exempt from ad valorem taxes under OCGA § 48-5-48.2(b). After that ruling was affirmed by a board of equalization, Irwin filed an appeal in
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