ADAMS, Judge.
Citibank (South Dakota), N.A., in its own capacity and as successor in interest to Citibank USA, N.A., ("Citibank") appeals the trial court's dismissal of its lawsuit against Bart L. Graham, Commissioner of the Georgia Department of Revenue, (the "Commissioner") seeking a refund for taxes paid on bad debts. We affirm for the reasons set forth below.
Citibank provides financing for "private label credit card" programs (the "Programs") through...
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