Gwinnett County Board of Tax Assessors v. General Electric Capital Computer Services

Hines, Justice.

We granted certiorari to the Court of Appeals in Gen. Elec. Capital Computer Svcs. v. Gwinnett County Bd. of Tax Assessors, 240 Ga. App. 629 (523 SE2d 651) (1999), cases involving the freeport exemption in OCGA § 48-5-48.2 (b), 1 to address whether the doctrine of col*176lateral estoppel bars the litigation of a tax issue litigated in a prior year where there has been no significant factual change, but where there has been a change or development in the law. We conclude that collateral estoppel may not pose a bar under such circumstance; but, we affirm the decision of the Court of…