SMITH, Justice.
Patcraft Mills, Inc. brought this action seeking a refund of $6,838 in corporate income taxes assessed by the State Revenue Commissioner and paid, under protest, for the fiscal years 1974, 1975 and 1976. The superior court judge found for Patcraft, and the Commissioner appeals. At issue are carpet sales made by Patcraft to out-of-state customers who took possession of the goods at Patcraft's place of business in Dalton, Georgia for immediate transport...
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