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CLAYTON COUNTY v. HEALTHSOUTH HOLDINGS

Nos. A07A0922, A07A1327, A07A1328.

654 S.E.2d 143 (2007)

CLAYTON COUNTY et al. v. HEALTHSOUTH HOLDINGS, INC. et al. Fayette County, et al. v. HealthSouth Holdings, Inc. HealthSouth Holdings, Inc. v. Fayette County et al.

Court of Appeals of Georgia.

Reconsideration Denied November 15, 2007.

Attorney(s) appearing for the Case

Hancock, Dempsey & Everett, Brian R. Dempsey, Michelle Y. Terry, Forest Park, for appellants. (case no. A07A0922).

Jones Day, E. Kendrick Smith, Atlanta, for appellees. (case no. A07A0922).

Daniel W. Hamilton, amicus curiae. (case no. A07A0922).

McNally, Fox & Grant, Dennis A. Davenport, Fayetteville, for appellants. (case nos. A07A1327 and A07A1328.)

Jones Day, E. Kendrick Smith, Atlanta, for appellees. (case nos. A07A1327 and A07A1328.)

SMITH, Presiding Judge.

We have consolidated these cases for purposes of appeal. In Case Nos. A07A1327 and A07A1328, HealthSouth Holdings, Inc., a wholly owned subsidiary of HealthSouth Corporation, applied to Fayette County for the refund of allegedly overpaid ad valorem taxes. Fayette County refused to issue a refund, prompting HealthSouth Holdings to file suit against the county and others (collectively referred to as "Fayette County").1

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