NICHOLS, J.
Both parties state in their briefs in this court that the issue is whether or not the property sold, with the exception of the franchise and the rights-of-way, was tangible personal property, the sale of which is subject to the sales tax. No point is made as to whether or not the State may proceed to collect the sales tax from a purchaser, and this question will not be passed upon.
The Georgia Retailers' and Consumers' Sales and Use Tax Act imposes...
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