O.P.D.I.-U.S., Inc. v. Collins

This case involves a construction of the Georgia Real Estate Transfer Tax, which “is not a property tax; it is an excise tax on transactions involving the sale of property. It is paid by the transferor each time he sells a parcel of real estate for the privilege of selling that particular property.” City of Columbus v. Ronald A. Edwards Constr. Co., 155 Ga. App. 502, 503 (271 SE2d 643) (1980).

With respect to Division 1, the question is whether the term “removed” in the statute means removed from the realty as part of the transaction, as appellant contends, or removed from the transferor, as…