FELTON, C. J.
The trial court correctly construed the Georgia Retailers' and Consumers' Sales and Use Tax Act (Ga. L. 1951, p. 360), correctly applied it to the facts in this case, and properly sustained the demurrer to the petition for a refund of the sales and use taxes paid under protest, for the following reasons:
1. The taxes here involved are not taxes on property and the transactions are not exempt from taxation under Code (Ann.) § 2-5404 and Code...
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