Columbia Bank for Cooperatives v. Blackmon

I am in disagreement with the majority opinion and the judgment rendered in this case. In the recently decided case of First Federal Savings &c. Assn. v. Abbott, 231 Ga. 864 (204 SE2d 594), this court held as follows: "We hold that the tax imposed by Code Ann. § 92-164 is a one-time tax on intangible property, namely, long-term promissory notes secured by real estate, and for Georgia to impose such a tax the taxable situs of the note or notes *350must be in Georgia.” The majority does not today repudiate or overrule Abbott; but it attempts to distinguish, unsuccessfully to my mind, the promissory…