BLACKBURN, Presiding Judge.
In his capacity as Commissioner of the Georgia Department of Revenue, Bart Graham issued an assessment of additional income taxes and interest against Frank Hanna, Jr., who appealed the assessment to the Superior Court of Chattooga County. Following motions for summary judgment by both parties, the superior court denied the Commissioner's motion, granted summary judgment to Hanna, and ordered that the tax assessment be set aside. We granted...
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