FELTON, Chief Judge.
The sole question for decision in this case is whether the out-of-state sales of a taxpayer who is engaged in the sale of tangible goods both within and without the state are taxable as Georgia income where the out-of-state deliveries are made under a contract that title to the goods passes to the purchaser at destination and where the three-factor formula provided for by Code (Ann.) § 92-3113 (4) (c) is applicable in determining the...
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