ELLINGTON, Judge.
Vesta Holdings I, LLC appeals from the Fulton County Superior Court's judgment in favor of Arthur E. Ferdinand, the Fulton County Tax Commissioner. We find the trial court erred by denying Vesta's petition. Therefore, we reverse the judgment and remand with direction.
As will be seen below, the facts in this case are not in dispute. Therefore, this Court conducts a de novo review of the record in determining whether the trial court
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