ADKINS, Judge.
This is Round Two of a fight that first appeared before us in the September 1983 Term. In 1981, the appellees, McKendree and Mildred Fulks, transferred about 33 acres of land to Kettler Brothers, Inc., for $335,950. Pursuant to Montgomery County Code § 52-21(e), the Fulkses paid a 6 percent Montgomery County rezoning transfer tax on the transaction; but, due to a mix-up, the county did not attempt to collect the 2 percent State agricultural transfer...
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