First Federal Savings & Loan Ass'n v. Abbott

Gunter, Justice.

This case involves an appeal by an out-of-state federal savings and loan association (Rochester) from a summary judgment entered in the trial court upholding the right of the state of Georgia to impose and collect an intangible tax upon a long-term note secured by Georgia real estate.

The parties stipulated that a long-term promissory note in favor of Rochester was executed and delivered in the state of New York by a Georgia corporation, and that the note "has never been inside the state of Georgia.” As security for the promissory note the Georgia corporation executed and…