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Clayton County Board of Tax Assessors v. King

Citations: 260 Ga. 495; 397 S.E.2d 293; 1990 Ga. LEXIS 407Docket: S90A1161

Court: Supreme Court of Georgia; October 31, 1990; Georgia; State Supreme Court

Narrative Opinion Summary

In this case, the appellant contested the ad valorem taxation of an attorney's law library, asserting that it should be taxed under Georgia law. The dispute centered around whether the library qualified for a tax exemption as outlined in OCGA § 48-5-3 and other relevant statutes, along with the Georgia Constitution's provisions on tax exemptions. The Superior Court of Clayton County had previously granted the appellee's motion for summary judgment, effectively ruling that the library was exempt from taxation. The appellant's motion was denied. Upon review, the higher court found that the law library, used for professional purposes, did not meet the criteria for exemption under either statutory or constitutional guidelines. The court reversed the lower court's decision, concluding that the appellee's motion should not have been granted, and the appellant's denial was in error. This decision was unanimously agreed upon by all Justices, clarifying that the attorney's law library is indeed subject to ad valorem taxation.

Legal Issues Addressed

Ad Valorem Taxation of Personal Property

Application: The court applied the principle that all personal property is subject to ad valorem taxation unless specifically exempted by law.

Reasoning: The court referenced OCGA § 48-5-3, which mandates that all personal property is taxable unless exempted by law.

Legal Status of Attorney's Law Library

Application: The court concluded that an attorney's law library maintained for professional use is not exempt from ad valorem taxation.

Reasoning: The court concluded that an attorney's law library, maintained for professional use, is not exempt from ad valorem taxation under either the Georgia Constitution or relevant legislation.

Tax Exemptions under Georgia Law

Application: The court determined that tax exemptions must be explicitly authorized by either the Georgia Constitution or specific state legislation.

Reasoning: Article VII, Section II, Paragraph I of the Georgia Constitution states that only tax exemptions authorized by the constitution are valid.