BANKE, Judge.
The appellant revenue commissioner issued an assessment against the appellee for additional income taxes claimed to be due for the years 1971 through 1973. An appeal was made to the Superior Court of Fulton County. On cross motions for summary judgment, the trial judge held in favor of the appellee taxpayer, from which judgment the commissioner appeals to this court.
During the years in issue, Code Ann. § 92-3102 (b) (2) (Ga. L. 1969, pp...
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