FAULKNER, Justice.
Lionel W. Noonan appeals from the summary judgment granted in favor of East-West Beltline, Inc., which holds that East-West Beltline, Inc., (hereinafter "East-West") is entitled to a $24,184.21 refund of recording taxes.
The uncontested facts are as follows:
East-West was the owner of all of the outstanding capital stock of the Bel Air Corporation.
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