ROBERTS v. GUNTER

39617, 39618.

251 Ga. 276 (1983)

304 S.E.2d 369

ROBERTS et al. v. GUNTER et al.; and vice versa.

Supreme Court of Georgia.

Rehearing Denied July 21, 1983.


Attorney(s) appearing for the Case

Webb, Daniel & Betts, Harold T. Daniel, Jr., Michael J. Bowers, Attorney General, James C. Pratt, John E. Bumgartner, Assistant Attorneys General, for appellants.

Gambrell & Russell, Harold L. Russell, Thomas W. Rhodes, Frederick G. Boynton, for appellees.


GREGORY, Justice.

This appeal and cross-appeal raise questions regarding Georgia's bank share tax statute, OCGA § 48-6-90 (Code Ann. § 91A-3301).

In 1974 the Gunters purchased approximately 60% of the stock of the Hamilton Bank and Trust Company from a bank holding company. In February 1975, Hamilton Bank filed with the Fulton County taxing authorities (appellants here) a document which the Bank claimed was its 1975 bank share tax return. In May...

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