ADAMS, Judge.
Only four days before a foreclosure sale for failure to pay ad valorem taxes, Wilmington Trust Company sought an injunction and a declaratory judgment regarding the taxability of an airplane in which it has title. It now appeals the decision of the Superior Court of Glynn County, which denied the injunction and found that the airplane was taxable under Georgia law.
The parties stipulated to the facts below. Wilmington, a nonresident, has title...
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